Interpretation ID: aiam1302
Bankers Trust Company
1775 Broadway
New York
NY 10019;
Dear Mr. Leeds: This is in reply to your letter of September 17, 1973, which ask whether a bank must make an odometer disclosure statement upon transfer to an auctioneer of a repossessed vehicle in which the bank has only a security interest.; To the extent that the bank is acting in the place of the repossesse owner, and in the absence of any other party available to make a statement, it is our opinion that the bank is acting as transferor and should make the disclosure specified in Part 580. Normally the bank does not know that the odometer is inaccurate and should only fill in the blank with the recorded mileage. The bank could authorize its collection agency to actually make the disclosure.; Yours truly, Richard B. Dyson, Assistant Chief Counsel