Interpretation ID: aiam3927
Assistant Vice President
First American Bank of Virginia
1970 Chain Bridge Road
McLean
VA 22102;
Dear Mr. Allison: This is in response to your letter of March 14, 1985, in which yo asked whether the bank is required to complete the Odometer Mileage Statement form in view of the wording on the Virginia title.; I have reviewed Virginia's Certificate of Title and the odomete mileage disclosure regulation, 49 CFR part 580. The bank should continue to issue its Odometer Mileage Statement when transferring a motor vehicle unless the buyer completely fills out the reverse side of the title, including the application. While the Virginia title meets regulatory requirements concerning the odometer reading, it fails to provide a space for the buyer's address and signature apart from the application. In some instances, a dealer may reassign the title without applying for one in his own name and the above requirements would not be met. The dealer would then be able to assert that he was not informed of the mileage or that the mileage was different from that appearing on the title.; Sincerely, Jeffrey R. Miller, Chief Counsel