Interpretation ID: nht95-2.12

TYPE: INTERPRETATION-NHTSA

DATE: March 27, 1995

FROM: Yvonne Roppel -- Liaison Officer, Title and Registration Services, State of Washington, Department of Licensing

TO: Phillip Reckt -- Chief Council, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/19/95 LETTER FROM JOHN WOMACK TO YVONNE ROPPEL (A43; REDBOOK 2; Part 580)

TEXT: Dear Mr. Reckt:

I recently conferred with Dick Morse of NHTSA who asked me to request of you a written reply to my question.

I had asked Mr. Morse as to who should sign an original title application for a leased vehicle, the lessee or the lessor.

As background, I advised Mr. Morse that in Washington State the lessee is shown on the title as a registered owner and is required to sign the original application at the dealership. (This is only concerning a vehicle still under the Manufacturer's Cert ificate of Origin.) Normally the lessee is choosing the vehicle from the dealer inventory. The yearly license renewal notice is mailed to the lessee in most cases. The registered owner or lessee is liable if any legal action is filed against the vehicl e.

Mr. Morse has indicated that when the lessee is shown on the title, they would be considered a registered owner and would therefore acknowledge the odometer disclosure made bythe selling dealer. I asked if he would put this in writing at which time he i ndicated that I would have to write to your office. Therefore, I am asking if I could have a letter sent to me verifying in writing his reply.

Thank you for your assistance in this matter.