Interpretation ID: aiam1053
Office Manager
The Procter and Gamble Distributing Company
Post Office Box 60114
New Orleans
LA 70160;
Dear Mr. Foster: This is in response to your request for odometer disclosure form applicable to the State of Florida. The letter appears to be a blanket request for forms from all the states in which you do business.; The Motor Vehicle Information and Cost Savings Act and the accompanyin regulations were purposely made flexible and simple to permit the states and affected transferors maximum latitude in conforming to the Act. In fact, the States have no duties under the Act. Many of the States that you have contacted will probably indicate that no changes will be made to their laws and regulations. Some states may change their Title forms or their disclosure forms to accomodate (sic) the federal statement.; It is the transferor's responsibility to make the required disclosur and again maximum latitude is permitted. No federally-printed form is required nor is one available. A transferor may write his own form, make use of a state form which conveys the same information, or use one of the commercially printed forms now available. So far as the federal requirements are concerned you may use an identical form in all the states. An example of an acceptable format is enclosed for your information.; Yours truly, Richard B. Dyson, Assistant Chief Counsel