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Interpretation ID: nht74-5.9

DATE: 01/18/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: John W. Davis; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: This is in reply to your letter of December 17, 1973, on behalf of Ms. Judith Davis, who has suggested the incorporation of the Federal odometer form into the bill of sale as a means of reducing paperwork in motor vehicle transactions.

Although the Federal odometer disclosure regulation requires the seller to give the buyer several items of information that we consider essential to adequate disclosure, the regulation does not require the use of a separate form. If Ms. Davis is able to include the required information in the bill of sale used by the Rome Auto Auction, she may do so. Information items that are common to the bill of sale and the disclosure statement, such as the model and make of the vehicle, would not have to be stated twice.

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