Submission Number: 563688-00002
Received: 12/4/2012 5:53:43 PM
Commenter: Richard Feferman
Organization: Feferman & Warren
State: New Mexico
Agency: Federal Trade Commission
Initiative: 16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Attachments: No Attachments
The most common problem we see, as consumer lawyers, is car dealers selling used cars that have been wrecked and rebuilt. Dealers pretend not to know about these prior accidents, even though the repaired damage is obvious to persons in the trade. The prior wreck damage greatly affects the fair market value.
We believe the rule should contain boxes for the dealer to state whether or not it inspected the vehicle for alterations or prior wreck damage. Where it has inspected, the dealer should disclose what parts were repaired or replaced and the approximate cost of repair or replacement.