Interpretation ID: GF004208

Mr. Mike Finkelstein
Michael Finkelstein & Associates
9406 Wildoak Drive
Bethesda, MD 20814

Dear Mr. Finkelstein:

This is in response to your e-mail of April 24, 2004, asking about certain requirements in 49 CFR Part 543, Exemption From Vehicle Theft Prevention Standard, as amended by a final rule published on April 6, 2004 (69 FR 17960).Specifically, you ask whether a manufacturer may seek exemptions from the parts marking requirements for below-median theft rate vehicle lines, prior to the September 1, 2006, effective date of the final rule.

As you are aware, the National Highway Traffic Safety Administration (NHTSA) is in the process of responding to petitions for reconsideration of the April 6, 2004, final rule.The issues raised in your letter are similar to those raised in the petitions.Accordingly, we will address your question in our response to the petitions for reconsideration.

If you have further questions in the interim, you may contact Mr. George Feygin of my staff at (202) 366-2992.

Sincerely,

Jacqueline Glassman
Chief Counsel

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