Interpretation ID: nht92-3.45

DATE: 09/22/92

FROM: LAWRENCE A. BEYER -- ATTORNEY AT LAW

TO: Z. TAYLOR VINSON, ESQ. -- OFFICE OF CHIEF COUNSEL, NHTSA

ATTACHMT: ATTACHED TO LETTER DATED 11-24-92 FROM PAUL J. RICE TO LAWRENCE A. BEYER (A40; PART 592)

TEXT: This letter is in reference to my request to become a Registered Importer. I feel that this request is in keeping with the intention of the Act, in that I am very knowledgeable with the requirements of NHTSA.

I have relocated my office to upstate New York. I am very close to several ports, such as Buffalo, Alexandria Bay, and Champlaign. I would intend to only perform actual modifications on those canadian vehicles which require only minor modifications. I certainly have the ability to do these changes.

Should any major modifications be required, these vehicles would not be accepted and refferal would be made to the other R.I.s.

You expressed concern that I would act as an agent for another R.I. This is not a problem. Since I represent four current R.I.s, it would not be fair to make refferals to only one company. Additionally, as an attorney, I cannot accept kickbacks or refferal fees from non-lawyers.

The facilities I would use are a three car garage, complete set of tools, including pneumatics, and storage space for many vehicles. I would have in my employ several people including a certified electrician and former auto mechanics teacher, as well as a current mechanic at Midas Muffler. Since I have helped set up several other R.I.s record keeping mechanisms, my files would be consistent with NHTSA's standards