Interpretation ID: nht79-1.32

DATE: 02/22/79

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Pennsylvania Notaries

TITLE: FMVSR INTERPRETATION

TEXT:

22 FEB 1979

S. B. Aronson Pennsylvania Notaries 625 Stanwix Street Pittsburgh, Pennsylvania 15222

Dear Mr. Aronson:

This is in response to your letter of January 4, 1979, requesting our opinion as to whether a rubber stamp which contains the odometer information on the newest Pennsylvania title could be applied to older titles in lieu of having a separate form attached.

There are no legal bars to your recommendation. In fact, the stamp you recommend makes more sense than a separate form. A separate form can be removed and replaced with another sheet. A stamp cannot be so abused.

We appreciate and support your recommendation.

Sincerely,

John Womack Assistant Chief Counsel