Interpretation ID: nht74-5.22

DATE: 04/12/74

FROM: AUTHOR UNAVAILABLE; Lawrence R. Schneider; NHTSA

TO: Driver and Vehicle Administration; Michigan Department of State

TITLE: FMVSR INTERPRETATION

TEXT: Some time ago you asked our regional office in Chicago for advice concerning the sufficiency of the odometer disclosure form developed by Michigan for use on its certificates of title and other motor vehicle transfer documents. This will serve to confirm the informal opinion you received from Dick Cook of the regional staff.

As pointed out in the letter sent you by General Motors, the Michigan form lacks certain informational items that are specified in the Federal odometer disclosure regulation. To comply fully with the regulation, the Michigan form would have to include space for the vehicle model and the last plate number. However, we do not regard the absence of these items to be serious enough to mandate a change in the Michigan form, in that the other information provided on the form appears sufficient to accurately identify the vehicle. A transferor who completes the present form and thereby fails to give the additional information would not be misleading the transferee and would therefore not be subject to civil action under the Act. It is our view that a transferor who completes the disclosure statement on the Michigan form would not need to submit an additional disclosure form.