Interpretation ID: nht79-4.27

DATE: 10/15/79

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Bureau of Motor Vehicles

TITLE: FMVSR INTERPRETATION

TEXT: This is to memorialize the telephone conversation you had with Kathy DeMeter of my staff on Thursday, October 4, 1979, concerning the motor vehicle manufacturers' certificate of origin. You indicated to Ms. DeMeter that the new standard certificate of origin has an assignment form on the reverse side for the transfer from the first dealer to the consumer. This assignment contains odometer information, including identifiers of the vehicle, a reference to Federal law, a statement of the odometer reading, a statement that the reading is actual unless one of two other statements (mileage not actual or mileage over 99,999 miles) is checked, the names and addresses of the buyer and the seller, and the signature of the seller. Ms. DeMeter informed you that in order for the certificate to substitute for a separate Federal odometer disclosure statement, it must include the signature of the buyer. Ms. DeMeter also indicated that when the assignment form is being used to transfer the vehicle from the dealer to another, the odometer information is not required under Federal law.