Interpretation ID: nht95-1.32

TYPE: INTERPRETATION-NHTSA

DATE: January 19, 1995

FROM: Jiro Doi -- Vice President, MITSUBISHI MOTORS AMERICA, INC.

TO: Philip Recht -- Chief Counsel, NHTSA

TITLE: NONE

ATTACHMT: ATTACHED TO 5/5/95 LETTER FROM JOHN WOMACK TO JIRO DOI (A43; PART 541)

TEXT: Dear Mr. Recht:

On behalf of Mitsubishi Motors America, Inc., a U.S. subsidiary of Mitsubishi Motors Corporation, I request a legal interpretation concerning Part 541 Federal Motor Vehicle Theft Prevention Standard, particularly our question regards Part 541.5(a)(2) whi ch requires that the transmission be marked with either the VIN or a VIN derivative.

The clutch housing, for vehicles with manual transmissions (or converter housings for vehicles with automatic transmissions), is attached to the transmission (See Attachment) via bolts that may be removed allowing the clutch housing (or converter housing ) to separate from the transmission. Nevertheless, we believe the clutch housing may be considered a part of the transmission. Therefore, we believe marking the clutch housing (or converter housing) complies with Part 541.5(a)(2).

Please provide us with your interpretation regarding this issue. If you have any questions, please contact me at (202) 223-5730.

Drawing omitted.