16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00050

Submission Number:
563688-00050
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 representing low-income consumers since 1987. My clients are frequently sold unsafe and unreliable cars and often the car's defects are hidden from them. Buying an unsafe or unreliable car leads many clients to financial ruin because they cannot get to work or cannot look for work without a car. Consumers would be better off if the FTC scrapped the rule entirely, instead of doing what they propose. The rule was already antiquated, misleading, and problematic, and their proposal would make it go from bad to worse. Allowing auto dealers the option of checking a box on the BACK of the form is absurd. Obviously the buyer will usually not see it or know where to look. The proposed AS IS language will likely lead to more fraud in the used car marketplace and lead fewer consumers to go see a lawyer who might uncover fraud.