|Received:||8/26/2008 12:58:08 PM|
|Agency:||Federal Trade Commission|
|Rule:||Regulatory Review of the Used Motor Vehicle Trade Regulation Rule - Used Car Rule|
|Attachments:||536945-00005.pdf Download Adobe Reader|
Comments:My comments are for the question of Bilingual Buyers guides. Attached is a sample of one way to use them. The benefit for the consumer is everything is on one page instead of two. This eliminates having two sheets of paper blocking the view of the consumer while on a test drive. As for the business it benifits them by cutting their cost in half to hang one label instead of two. I would not suggest that all dealers have to use the bilingual buyers guide. Some dealers do not deal in spanish and a lot of american buyers are offended when they see a spanish buyers guide. They feel that to become an american citizen they have to learn to read and speak english. As you can see by the sample sent a lot of space, without lines , is given to list the Balance of factory verbage. It also has more room to add the certified verbage for all the new certified warranties that are available. On the question of Rule's type style, size and format requirements, As long as the verbage is exactly what the FTC wants on the form the type style and size should not matter in a way to be fined. The format should be adhered to. As for the compliance of the Rule I have been in the label business for 16 years and I would say that most manufacturer dealers comply with the rule to some extent. The non manufacturer dealers, mom and pop type, do not. The Rule is very important to the consumer, it protects them from the deceptive oral representation, and should stay in place. The FTC needs to enforce the Rule more then you are. I would suggest having people go around all year long to visit all used car dealers. It is unfair to the dealers that comply and have three or four dealers around them that don't comply. The FTC would not have to give out the full $11,000 fine to the dealers that don't comply, but a smaller fine or warning, for the first offense would make sure that the Rule would be complied with by everyone. I hope this helps you. If you have any questions please feel free to call or email me at any time.