16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00049

Submission Number:
563688-00049
Commenter:
james speer
Organization:
Virginia Poverty Law Center
State:
Virginia
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
I have been a legal services attorney since 1983 and I have represented many clients who suffered big financial losses due to purchasing used cars that were defective. Many clients were not told that the car they were purchasing had defects even though the car dealer should have been aware of the defects. The current Used Car Rule is of little help to consumers and the new proposed rule is even worse. My main concern is that the language about AS IS sales will allow some car dealers to get away with fraudulent practices and will lead many consumers to conclude they have no legal rights even if they later discover they were a victim of fraud. It makes no sense to protect the worst car dealers who commit fraud. That is not only bad for consumers but it is not fair to most dealers that do not engage in fraudulent practices to sell cars.