Interpretation ID: aiam4133
Esq.
DNA-People's Legal Services
Inc.
P.O. Box 967
Shiprock
NM 87420;
Dear Ms. O'Connell: This is in response to your letter of April 23, 1986. You asked whethe New Mexico has sought the approval of the National Highway Traffic Safety Administration to use its certificate of title or other motor vehicle ownership documents as a substitute for the Federal odometer mileage statement prescribed by 49 CFR S580.6.; New Mexico has not sought the approval of this Agency to use th certificate of title, but did submit a separate odometer mileage statement it wished to implement. We granted our approval to use that statement. However, when we subsequently learned that New Mexico was no longer using the form, we advised New Mexico's transportation Department in a letter dated November 28, 1983, that the certificate of title could not be used in lieu of the separate odometer disclosure statement. I have enclosed a copy of that letter.; I have reviewed a sample of New Mexico title contained in *The Origina Peck's Title Book* which is revised periodically and supplemented as changes occur in the state title laws. The New Mexico title, as it appears in *Peck's*, indicates that the title has not been revised since 1982. Therefore, for the reasons stated in our November 28, 1983 letter, the New Mexico title cannot be used in lieu of a separate odometer disclosure statement.; Sincerely, Kathleen C. DeMeter, Assistant Chief Counsel for General Law