Interpretation ID: aiam1636
General Manager
The Fairmount Press
P.O. Box 3
Bronx
NY 10453;
Dear Mr. Salzman: This is in response to your letter of October 7, 1974, requesting further explanation of this agency's conclusion that your odometer disclosure form does not satisfy Federal requirements.; Our determination that your disclosure form was not in compliance wit the Federal regulation was not based on any change in the odometer law. In past letters we pointed out to you that your form was deficient, however, we did not characterize the deficiency as constituting a noncompliance. Over the past year it has become apparent that disclosure forms not printed in the manner prescribed in the regulation have been responsible for misleading buyers who are confused by their ambiguous format. These forms have also been abused by certain sellers who rely on their ambiguity in misrepresenting the accuracy of a vehicle's odometer. Due to this situation, the NHTSA has concluded that a stricter interpretation of the odometer regulation is necessary in order to fulfill the Act's intended purpose.; We have, therefore, determined that because of the variance of th disclosure form that you submitted from the format specified in the regulation (49 CFR Part 580) it must in the future be considered not in compliance. The form prescribed in our regulation should in the future be closely adhered to.; We want to make clear that our determination of a noncompliance is no retroactive, since we previously gave a broader interpretation to the disclosure form requirements. Your prompt conformity to the format suggested in our letter is greatly appreciated.; Yours truly, Richard B. Dyson, Acting Chief Counsel