Interpretation ID: aiam3395
Jr.
Auto Damage Claim Examiner
Kemper Group
Mid-Atlantic Division
1610 Forest Avenue
Richmond
VA 23288;
Dear Mr. Bradley: This is in response to your letter of February 10, 1978, requesting listing of those states whose certificates of title have been approved by the agency for use in lieu of the separate Federal odometer form.; The Odometer Disclosure Requirements (49 CFR Part 580) provide that th transferor of a vehicle may make the disclosure required by the Federal odmeter (sic) laws on the state certificate of title, if the state title document contains essentially the same information required on the Federal odometer disclosure statement. If the information contained on the state certificate of title varies from that required by the Federal from (sic), the state must obtain the approval of this agency before its certificate of title can be used as a sustitute for the Federal form.; In order to spare states the burden of an approval process the agenc has indicated that certain variation from the Federal form are acceptable. In the *Federal Register* notice of August 1, 1977, which amended the disclosure regulation, we gave examples of shortened forms that would be acceptable. A state title can be considered to be approved for use as a full disclosure statement if it varies from the Federal form in only those aspects noted in the August 1, 1977, notice, a copy of which is enclosed.; The following states have odometer statements on their motor vehicl titles that are consistent with the requirements of the federal law:; >>>Maryland, Ohio, Massachusetts, Pennsylvania, Michigan, Hawaii Minnesota, New York, North Dakota<<<; In addition, the following states submitted title forms to the agenc asking for approval but had unacceptable statements. Each was advised that before its form could be approved certain additional information was required on its certificate of title. We do not know whether that information has been included on the titles.; >>>North Carolina, Virginia, Delaware, Washington, South Dakota, Utah South Carolina, Wisconsin, Indiana<<<; If you have any further questions, please do not hesitate to write. Sincerely, David W. Allen, assistant Chief Counsel