Odometer Disclosure Statement Explained for Dealers

What the statement is for

Federal law requires the person transferring a vehicle to state the mileage in writing to the person receiving it. That written statement is the odometer disclosure. Its purpose is simple: stop mileage fraud by creating a signed record every time a vehicle changes hands.

For a dealer, there are two moments it matters. When you buy a car, the seller discloses mileage to you. When you sell, you disclose mileage to the buyer. Both need to be signed and kept. This is general information, not legal advice, so confirm your obligations with your state.

What the form says

The disclosure covers the same core items on every deal. Whether it is a separate form or part of the title, expect these elements.

• Vehicle year, make, model, VIN and body type
• The odometer reading at the time of transfer, without tenths of a mile
• A statement that, to the best of the transferor's knowledge, the reading reflects actual mileage
• Or a check against one of the exceptions: the mileage exceeds the odometer's mechanical limits, or the reading is not the actual mileage
• Names, addresses and signatures of the seller and buyer, and the date

When mileage is not actual

Sometimes you know or suspect the displayed mileage is wrong. A replaced cluster, a rolled-over odometer, or a car whose records do not add up are examples. In those cases the seller must check the box that says the reading is not the actual mileage, and that notation carries onto the title.

Do not paper over it. A buyer who signs a statement that says actual mileage when the dealer has reason to believe otherwise creates a serious problem for the dealer. If a car has a mileage question, disclose it on the form.

If the odometer was repaired or replaced, your state may require a sticker on the door jamb showing the previous mileage and the date of the change. Check your state's rule.

Exempt vehicles

Federal rules exempt older vehicles from the written mileage disclosure. Under the federal rule, vehicles of a certain age no longer need the statement. In DMS Apex, vehicles with a model year of 2010 or older are treated as exempt, and the form prints EXEMPT in place of a mileage reading.

Exemptions follow the federal rule, and the cutoff moves as time passes, so the dealer should confirm the current exemption for their vehicles and their state. A few states have their own rules on top of the federal one, so do not assume the federal exemption is the end of the question.

Signing and storing the form

Both parties sign the statement. If more than one person is on the title, check how your state handles which signatures are required. A power of attorney can be used in some situations when the seller cannot sign, but the form for that is separate.

Keep the signed copy in the deal jacket. Federal rules call for dealers to keep these records for a period of years, so check how long your state wants them kept and set a retention routine. Scanning each jacket into a folder by stock number is enough for most lots.

Practical habits

• Photograph the odometer at the time of purchase and again at delivery
• Compare the reading to the title, the auction paperwork and any service history
• Round to the nearest whole mile and never write tenths
• Never sign a blank disclosure
• Fix any mistakes by correcting on a new form, rather than writing over the old one

How a dealer management system helps

DMS Apex prints the odometer disclosure from the deal, with the vehicle and buyer already filled in, and it prints EXEMPT for exempt vehicles. It also produces the Buyer's Order with your state's required wording, the Buyers Guide in English and Spanish, and the As Is notice, all in black and white. DMS Apex covers all 50 states and DC for $28 a month flat, with a 15-day free trial.