Interpretation ID: aiam1606
General Manager
The Fairmount Press
P.O. Box 3
Bronx
NY 10453;
Dear Mr. Salzman: This is in response to your letter of August 19, 1974, inquiring as t the compliance of your MVF odometer disclosure form with the Federal odometer requirements.; The MVF form enclosed in your letter fails to comply with ou regulation in several respects. The statement referring to the mileage indicated on the odometer at the time of the vehicle's transfer must be phrased to indicate that the disclosure document was executed at the time of the vehicle's transfer, not at some later time. In addition, the statement must be written in such a manner that it is clear it is to be completed by the transferor alone. To satisfy these criteria the statement should read; >>>'I, * *, state that the odometer mileage indicated on the vehicl described above, at the time of transfer to * * is as follows:'<<<; Instructions are necessary on your form to ensure that the sectio specified for the disclosure of mileage is completed in a consistent manner by all persons. This can be accomplished by inserting the following statement above the lines provided for stating the vehicle's mileage:; >>>'(Complete line 1, and where applicable, complete line 2 and chec line 3.)'<<<; We urge you to reprint your disclosure forms to reflect the change suggested above as they are not currently in compliance with Federal odometer requirements.; Your interest is appreciated. Yours truly, Richard B. Dyson, Acting Chief Counsel