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Assuming that PTD's are required for exchange transactions and the data could be electronically stored in a manner ensuring the security and integrity of the data, would it be sufficient to provide transferees with access to electronic PTD's if the PTD's contain the same data as the original except for the absence of the drivers signature? Would it be sufficient to make the PTD's available through an electronic interface or would the transferor be required to electronically transmit?

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The regulations require that the transferor must provide to the transferee documentation that includes all the PTD information, not just make it accessible to the transferee. As a result, the PTD requirements would not be satisfied if the transferee is merely given access to the PTD information. (8/29/94)

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