Interpretation ID: aiam3217
SAFECO
SAFECO Plaza
Seattle
WA 98185;
Dear Mr. Richards: This is in response to your letter of February 29, 1980, requestin information on the Federal odometer disclosure requirements. The question you raised is whether odometer disclosure statements have to be executed and retained when the vehicle involved in a purchase and sale is a salvage vehicle.; If the vehicle is repairable and will subsequently be used as a moto vehicle, disclosure must be made. However, if the vehicle is so badly damaged that it cannot be returned to the road, it will have ceased to be a motor vehicle for purposes of the odometer regulations (49 CFR Part 580). Disclosure would therefore not be required. You must keep in mind that this is a judgement that will have to be made in good faith by the seller of the vehicle.; Sincerely, John Womack, Assistant Chief Counsel