Interpretation ID: aiam1013
Keith Motor Company
4507 East 11th
Tulsa
OK 74112;
Dear Mr. Keith: This is in reply to your letter of January 30, 1973, concerning th Federal Odometer Disclosure Requirement.; Your questions concerns (sic) the situation in which a person sells vehicle that has had several previous owners. You suggest that, in such a case, the true mileage should be indicated as unknown.; It is our opinion that the language you quote from Section 408(a) o the Act, to the effect that the mileage must be said to be unknown if the odometer reading is known to differ from the actual mileage, does not apply in the situation you describe. A person selling the vehicle in the above situation should not, therefore, indicate that the mileage is unknown, but should rely on the statement by the previous owner.; As you acquire vehicles after March 1, the effective date of th disclosure requirement, you will be obtaining the disclosure statement from each seller. Within a relative (sic) short time, all of the vehicles on your lot will have disclosure statements on which you are entitled to rely in making your disclosure statement upon resale of the vehicle.; Yours truly, Richard B. Dyson, Assistant Chief Counsel