Interpretation ID: nht95-3.97

TYPE: INTERPRETATION-NHTSA

DATE: August 24, 1995

FROM: Mark Heminway -- Director of Fleet Operations, The Hertz Corporation

TO: John Womack -- Acting Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: 12/29/95 letter from Samuel J. Dubbin to Mark Heminway (A44; Part 580)

TEXT: On August 17, 1995 we met with Mr. Richard Morse of the Odometer Fraud Staff to outline a laser printing process we have developed for printing signatures on odometer disclosure statements.

To summarize the meeting, we described to Mr. Morse a process Hertz developed where it scans both the written and printed signature. Then, applying the signature via a laser printer, the documents are printed and forwarded to the states. Mr. Morse insp ected the sample documents and was satisfied they met the standards for verification of signature as well as the spirit and intent of CFR 49 Section 580, particularly as outlined in Appendix A regarding secure printing processes. Additionally, each PC i s secured with password protection so only the true owner of the signature may issue that signature.

We seek from you a positive interpretation that the laser printing of the actual signature and printed name meets the requirements of CFR 49 section 580. A written response from you would clarify for both the states and ourselves your position and save significant time and expense.

Thank you for your consideration of this matter.

Samples omitted.