16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00145

Submission Number:
563688-00145
Commenter:
John Whitfield
Organization:
Blue Ridge Legal Services, Inc.
State:
Virginia
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
I submit these comments on behalf of Blue Ridge Legal Services, Inc., the legal aid society that serves the 26 cities and counties in the Shenandoah Valley and Roanoke Valley of Virginia. I serve as executive director of the organization. We provide free legal assistance to low-income residents of our service area in civil matters. We regularly see clients who are victims of autofraud. I have reviewed the comments submitted on March 12, 2013, by the Arizona Consumers Council Foundation, Chicago Consumer Coalition Consumer Assistance Council, Consumer Federation of America, Consumer Federation of California, Consumer Federation of the Southeast Consumer Action, Consumers for Auto Reliability and Safety, Maryland Consumer Rights Coalition, National Association of Consumer Advocates National Consumer Law Center (on behalf of its low-Income clients), U.S. Public Interest Research Group, Virginia Citizens Consumer Council, and Watsonville Law Center (see attached). I fully support and endorse those comments and adopt those recommendations. The goal of the Buyers Guide should be to deliver as much information as possible into the hands of consumers who are looking at used vehicles and trying to determine how much to pay. As stated by the United States Supreme Court, "blind economic activity is inconsistent with the efficient functioning of a free economic system such as ours, whose ability to provide desired material at the lowest cost is dependent on the asserted preferences and informed choices of consumers." Mourning v. Family Publications Svc., Inc. 411 U.S. 356, 364 (1973). Therefore, the recommendations made by the attached letter should be adopted because they will increase the information provided to consumers, protect against fraud, and improve the functioning of our free economic system. Thank you for considering these views and for your work to protect consumers across America.