Interpretation ID: nht88-4.24

TYPE: INTERPRETATION-NHTSA

DATE: 12/01/88

FROM: THOMAS E. GUNTON -- CORPORATE COUNSEL MCCULLAGH LEASING, INC.

TO: JUDITH KALETA -- OFFICE OF THE CHIEF COUNSEL NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: ODOMETER DISCLOSURE REQUIREMENTS

ATTACHMT: ATTACHED TO LETTER DATED 03/20/89 FROM ERIKA Z. JONES -- NHTSA TO THOMAS E. GUNTON, REDBOOK A33, PART 580

TEXT: Dear Ms. Kaleta:

This is to request your guidance with respect to whether the odometer disclosure requirements of the Truth and Mileage Act of 1986, 15 USC Section 1981 et seq and the regulations promulgated thereunder, apply to large scale sales of motor vehicles and be tween leasing companies.

In particular, where a motor vehicle leasing company, in a single transaction, sells several hundred of its vehicles (and the related commercial leases) to another leasing company while such vehicles are on lease to numerous lessees whose drivers are loc ated throughout the country, must the transferring leasing company provide odometer mileage disclosures for each of the vehicles transferred, or does the Act exempt such transactions?

If you have any questions or need further information in order to respond, please contact me at your earliest convenience. Thank you for your assistance.

Very truly yours,