Interpretation ID: aiam2827
Mellon Bank
P.O. Box 360617M
Pittsburgh
PA 15230;
Dear Ms. Hebda: This is in response to your recent telephone conversation with Kath DeMeter of my staff concerning the retention of odometer disclosure statements. The question you raised was in what order the statements should be retained. The two methods you proposed using were alphabetically by the name of the individual or organization to which you transferred the vehicle. 49 CFR requires each dealer or distributor of a motor vehicle to retain the statements 'in an order that is appropriate to his business requirements and that permits systematic retrieval.'; Either method you propose would probably permit systematic retrieva and you may therefore select the method which best suits your business requirements.; Sincerely, John Womack, Assistant Chief Counsel