Submission Number: 00043 

Received: 8/10/2011 8:45:52 AM
Commenter: Raymond Ingalsbe
Organization: Private law office
State: Florida
Agency: Federal Trade Commission
Initiative: Public Roundtables: Protecting Consumers in the Sale and Leasing of Motor Vehicles; Project No. P104811
Attachments:
00043-80228.pdf Size = 108 KB
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Submission Text
Delvin Davis from the Center for Responsible Lending suggested that I contact you. My law practice consists almsot exclusively of automobile dealer financing fraud known as yo-yo and "spot delivery". I have been doing this for over 10 years and have won 3 summary judgments for consumers and against the dealers. Attached to this comment is a memorandum on yo-yo / spot delivery, demonstrating that it is illegal in every instance, even in cases where the dealer has assigned its installment contract as written. I had previously applied to be a panelist on your Roundtables. I still wish to be a panelist at a future rountableon auto financing.