Interpretation ID: nht78-3.46

DATE: 07/31/78

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Maryland Independent Automobile Dealers Association

TITLE: FMVSR INTERPRETATION

TEXT: This to confirm your telephone conversation with Kathy DeMeter of my staff concerning the Federal odometer disclosure requirements imposed on dealers and distributors. Part 580 of Title 49 of the Code of Federal Regulations requires that each transfer of a motor vehicle be accompanied by an odometer disclosure statement and that dealers and distributors retain for four years copies of statements which they issue and which they receive. In States that have incorporated the Federal statement into their certificates of title the dealer need not execute a separate Federal form. He must, nevertheless, retain a copy of whichever statement he completes. If, for example, he discloses the mileage solely by means of the statement on the certificate of title, he must make a copy of the title for his own records. He may also issue a separate statement to the purchaser and retain a copy of that statement for his records.

For your information, I have enclosed a copy of the law, the regulations issued under it and several interpretations and pamphlets. If you have any further questions, please do not hesitate to write.