16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00156

Submission Number:
563688-00156
Commenter:
Rob Hughes
Organization:
Torres Law Firm
State:
Texas
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
To change the language on the "As is" used car form, would be giving car dealers a license to commit fraud. If a dealer will not be responsible for any repairs, why would they disclose known defects to an unsophisticated consumer. Let the consumer buy the car with a bent frame, bad engine, etc., and then just say "Sorry, we aren't responsible for any repairs, because you signed this form." Consumer advocates, attorneys, and judges have for many years fought to create state laws that deal with these specific situations. If the FTC makes a change like this, it will be interpreted by the dealers, and their lawyers, as an absolute bar to any claims the consumer may have. Fraud should always be punished, not encouraged.