Interpretation ID: 77-2.39

TYPE: INTERPRETATION-NHTSA

DATE: 05/20/77

FROM: AUTHOR UNAVAILABLE; John Womack; NHTSA

TO: Noah Stone

TITLE: FMVSR INTERPRETATION

TEXT: This letter is to confirm a telephone conversation you had with Kathy DeMeter of this office on May 17, 1977. You asked whether the Federal odometer mileage disclosure statement, required to be executed by 49 CFR Part 580, needed to be a separate piece of paper. The answer is "no." The regulation does not require the disclosure to be separate from other documents. If the full information required by section 580.4 can be included, a disclosure on the bill of sale or other document would satisfy the requirements. The only limitation is that it would have to be executed prior to the completion of the sale as required by section 580.4(a) of the regulation.

If you have any further questions, please do not hesitate to write.