16 CFR Parts 239, 700, 701, 702 and 703, Request for Comments Concerning Interpretations of Magnuson Moss Warranty Act, Rule Governing Disclosure of Written Consumer Product Warranty Terms and Conditions, Rule Governing Pre Sale Availability of Written Wa

Submission Number:
00029 
Commenter:
Clarence Ditlow
Organization:
Center for Auto Safety
State:
District of Columbia
Initiative Name:
16 CFR Parts 239, 700, 701, 702 and 703, Request for Comments Concerning Interpretations of Magnuson Moss Warranty Act, Rule Governing Disclosure of Written Consumer Product Warranty Terms and Conditions, Rule Governing Pre Sale Availability of Written Wa

October 24, 2011 Federal Trade Commission Office of the Secretary 600 Pennsylvania Ave NW Washington DC 20580 Re: ‘‘Magnuson-Moss Warranty Act Rule Review, 16 CFR part 700, P114406,’’ The Center for Auto Safety (CAS) submits the following comments in regard to the above noticed docket. CAS supports the continuing need for the FTC Guidelines and Rules issued under the Magnuson-Moss Warranty Act. CAS is concerned that some provisions need to be tightened due to evasion by industry and that others need to be tightened to address the on-line market place. The full comment is attached. Clarence M Ditlow Executive Director Center for Auto Safety