Interpretation ID: aiam3922
Chief Counsel
United States Fleet Leasing
Inc.
No. 2 Waters Park Drive
San Mateo
CA 94403;
Dear Mr. Dusenbury: This is in response to your request of February 7, 1985, for a list o those states which have a sufficient amount of odometer disclosure information on the certificate of title so that a separate odometer disclosure statement is not necessary.; Please be advised that no such list is maintained by the Agency. Th applicable Federal regulation, 49 CFR Part 580 provides that State titles or other ownership documents may be used as substitutes for the Federal odometer disclosure statement if they contain essentially the same information required by paragraphs (a), (b), (c) and (e) of section 580.4. It is only if the information varies in any way from that required for the Federal form that the State must obtain the approval of this Agency.; Pursuant to your request, I have reviewed State titles contained wit *The Original Peck's Title Book*. This book published by Stephens-Peck, Inc. is revised periodically and supplemented as changes in state title laws occur. To date, the title documents of the following states may be used in lieu of a separate odometer disclosure form:; >>>Michigan, Minnesota, North Carolina, North Dakota, Ohio, Soug Dakota, Virginia<<<; I must qualify this list, however. With regard to the Michigan an Minnesota letters, it is only the initial assignment which meets all disclosure requirements. Reassignments by a licensed dealer do not, as there is no space for the purchaser's signature. The National Highway Traffic Safety Administration considers the signature to be essential because it is an acknowledgement that the purchaser is aware of the mileage. The signature prevents the purchaser from later alleging that he was not informed of the mileage or that the mileage was different from that appearing on the table.; When vehicles are transferred in North Dakota, Ohio or Virginia, th title can be used in lieu of a separate odometer disclosure statement only if the purchaser completes all information concerning the application for title. Unless the application is completed, the title will not include the buyer's signature.; In transferring vehicles titled in all the states listed above, Unite States Fleet Leasing, Inc. must retain a photostat of the title for its records. In all other instances, the company must issue a odometer disclosure statement and retain a photostat, carbon or other facsimile copy.; If I can be of further assistance, do not hesitate to contact me. Sincerely, Jeffrey R. Miller, Chief Counsel