Interpretation ID: nht95-2.89

TYPE: INTERPRETATION-NHTSA

DATE: May 19, 1995

FROM: John Womack -- Acting Chief Counsel, NHTSA

TO: Yvonne Roppel -- Liaison Officer, Title and Registration Services, State of Washington, Department of Licensing

TITLE: NONE

ATTACHMT: ATTACHED TO 3/27/95 LETTER FROM YVONNE ROPPEL TO PHILLIP RECKT (OCC 10223)

TEXT: Dear Ms. Roppel:

This is in response to your letter of March 27, 1995, in which you requested a written confirmation of the response by Dick Morse, Chief of the Odometer Fraud Staff of the National Highway Traffic Safety Administration ("NHTSA"), to your telephone inquir y concerning the Federal odometer disclosure law.

You asked whether the lessor or the lessee is the proper person to sign the original title application and odometer disclosure in a state such as Washington, which shows the lessee as the registered owner on the title and requires the lessee to sign the title application at the dealership. You also noted that in most cases the yearly license renewal is mailed to the lessee, and that the registered owner or lessee is liable in any legal action involving the vehicle.

Mr. Morse's response, that the lessee is the person who is responsible for acknowledging receipt of the odometer disclosure when the lessee is considered by the state to be the registered owner of the vehicle, is correct.

If you have any further questions about the Federal odometer disclosure law, please write to this office at the above address, or call Eileen Leahy, an attorney on my staff, at 202-366-5263.