Interpretation ID: 86-3.37

TYPE: INTERPRETATION-NHTSA

DATE: 05/30/86

FROM: RICHARD E BOND -- HOLIDAY RAMBLER CORPORATION

TO: ADMINISTRATOR NATIONAL HIGHWAY TRAFFIC SAFETY ADMINISTRATION

TITLE: NONE

ATTACHMT: ATTACHED TO LETTER DATED 12/24/86 TO RICHARD E BOND, FROM ERIKA Z. JONES, REDBOOK A29, PART 565

TEXT: Gentlemen:

I have a simple question which does not seem to be addressed by the regulations. It is based on the following facts:

Corporation manufactures vehicle X for several years. Corporation then separates the portion of its company which manufactures these vehicles into a separate, wholly-owned subsidiary corporation. Subsidiary corporation will continue to manufacture vehicle X.

Question: Is the Society of Automotive Engineers authorized to transfer the WMI code that was being used by Corporation for vehicle X to subsidiary corporation for vehicle X?

Thank you in advance for your assistance.

Sincerely yours,