Interpretation ID: aiam1368

Mr. David C. Keehn, Attorney, Division of Marketing Practices, Bureau of Consumer Protection, Federal Trade Commission, Washington, DC 20580; Mr. David C. Keehn
Attorney
Division of Marketing Practices
Bureau of Consumer Protection
Federal Trade Commission
Washington
DC 20580;

Dear Mr. Keehn: Thank you for bringing the Ryder Rental odometer problem to ou attention.; The odometer provisions of the Motor Vehicle Information and Cos Savings Act apply only to tampering that leads to the under-representation of mileage. We recommend that over-representation cases be referred to the State consumer protection office. In this case, of course, Mr. Sharkey registered his complaint there in the first instance.; Yours truly, Richard B. Dyson, Assistant Chief Counsel