Interpretation ID: nht74-5.8

DATE: 02/21/74

FROM: AUTHOR UNAVAILABLE; Richard B. Dyson; NHTSA

TO: Bridges and Collins

TITLE: FMVSR INTERPRETATION

TEXT: In reply to your request of January 30, 1974, I am enclosing a copy of the regulation issued to implement the odometer disclosure requirements of Public Law 92.513.

Although there are a variety of ways to determine whether a vehicle's actual mileage is greater than shown on the odometer, I know of only one method to establish the exact amount by which the indicated mileage has been exceeded: the testimony of a witness who knew the exact mileage on the car at the time the odometer was changed and who knows the accuracy of the odometer's performance after the change.

I would be most interested to learn of the progress of your action.

BRIDGES AND COLLINS

January 30, 1974

Department of Transportation National Highway Traffic Safety Administration

IN RE: Odometer Disclosure Requirements

Dear Administrator:

I am at the present time attempting to prosecute a civil action under Section 408 (a) of Title IV of the Motor Vehicle Information and Cost Savings Act (Public law 92-513). (This statute may be found in 15 U.S.C.A. @ 1988.)

Please send me a copy of the current rules regulating this statute.

I am having some difficulty determining the true mileage of the vehicle in question. If you know of a procedure for determining the actual mileage of a motor vehicle, please pass that information along to me. I would be most appreciative.

I can use the above-requested information as quickly as you can supply it.

Thank you for your prompt assistance and cooperation.

James B. Steward