Interpretation ID: nht78-3.43

DATE: 06/21/78

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Mellon Bank

TITLE: FMVSR INTERPRETATION

TEXT: This is in response to your recent telephone conversation with Kathy 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 to 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 retrieval and you may therefore select the method which best suits your business requirements.