Interpretation ID: nht79-1.30

DATE: 01/17/79

FROM: AUTHOR UNAVAILABLE; J. J. Levin, Jr.; NHTSA

TO: Maryland Department of Transportation

TITLE: FMVSR INTERPRETATION

TEXT:

JAN 17 1979

Clarence W. Woody Maryland Department of Transportation 6601 Ritchie Highway, N.E. Glen Burnie, Maryland 21062

Dear Mr. Woody:

This is in response to your letter of December 5, 1978, asking whether the abbreviated odometer disclosure statement currently used on Maryland certificates of title may also be used on a Uniform Manufacturer's Statement of Origin. Motor vehicle manufacturers are not required to provide dealers with odometer disclosure statements for new vehicles. Section 580.5 of Title 49 specifically exempts these transactions. Therefore, since there is no Federal requirement that any odometer disclosure statement be issued, you may include the abbreviated statement on the Uniform Manufacturer's Statement of Origin. Manufacturers, however, would not be required by Federal law to complete it.

You should be interested to know that the National Highway Traffic Safety Administration will shortly issue a proposed notice of rulemaking that will allow use of the abbreviated form on all transfer of ownership documents, not merely the certificate of title.

If you have any further questions, please do not hesitate to write.

Sincerely,

Joseph J. Levin, Jr. Chief Counsel