Interpretation ID: nht73-2.14

DATE: 11/09/73

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Jack Edwards; House of Representatives

TITLE: FMVSR INTERPRETATION

TEXT: Your request for information on the Federal Odometer Disclosure regulation on behalf of Mr. Charles J. Fleming has been referred to as for reply.

I am enclosing a copy of the regulation which includes an example of an acceptable format. Other formats are acceptable if all the required information is included.

We are unable to advise Mr. Fleming about the effect of a particular typographical error without knowing its nature, but as a general matter a typographical error would not give rise to liability unless it were deceptive in a way which misleads a purchaser.

Sincerely.

Enclosure

LANE COUNTY DISTRICT ATTORNEY --

EUGENE, OREGON

October 12, 1973

National Highway Traffic Safety Administration

Gentlemen:

We wish to submit the following questions to you for your review and response:

(1) Under the Federal Odometer Disclosure Act, is an automobile dealer required to include six (6) digit figures if the vehicle's odometer has gone over 100,000 miles?

(2) What duty does an automobile dealer have in checking the vehicle or former owner to see if the vehicle has gone over 100,000?

(3) Must a dealer reveal the former owner of a vehicle upon the request of the prospective purchaser?

We would greatly appreciate your cooperation in providing the answers to the above questions at your earliest possible convenience as we receive many inquiries regarding these matters.

Very truly yours,

J. PAT HORTON, District Attorney; Marcia Mellinger, Investigator

cc: Tom Trent