Interpretation ID: aiam1347
Staff Counsel
811 North First Avenue
Wausau
WI 54401;
Dear Mr. Sferrazza: In response to your request of November 28, 1973, I have enclosed copy of Part 580, *Odometer Disclosure Requirements*, 49 CFR Part 580, which was issued under the authority of the Motor Vehicle Information and Cost Savings Act of 1972, 15 U.S.C. S 1988.; The transferor must disclose the mileage as it is recorded on th odometer, and in addition that he knows that reading to be inaccurate if such is the case. This means that a transferor would check the box indicating that the reading does not reflect the mileage, if he knew that the vehicle had traveled more than 100,000 miles. The buyer would then be on notice to ask why the reading was not accurate and to be told that the vehicle had more than 100,000 miles on it.; Yours truly, Richard B. Dyson, Assistant Chief Counsel