In the Matter of General Motors LLC, File Number 152-3101
Dear FTC - It is a very bad idea to allow car dealers to settle cases by agreeing to "clearly disclose the existence of the recalls in close proximity to the inspection claims." In my 43 years as a consumer protection attorney, I have witnessed the boundless creativity of dealers in artfully dodging disclosure requirements by speaking out of both sides of their mouths. They will play up their 150 point inspection checklists, while downplaying the recall information. They will label their cars as "certified preowned", which gives the impression that they are safe. They will follow up their "disclosure" with things like "Of course the government wouldn't allow us to sell this car if it were not safe." How many consumers would think you could "certify" a death trap? Low income consumers would be especially vulnerable, as they often think that they have to take what they can get. From my experience, I can tell you that consumers are usually hurried through the paperwork, after having been purposely made to wait for hours by salespeople and finance managers, so that by the end of the day they are so frazzeled that they will sign anything to get the car-buying ordeal over with. Pro Publica did a great piece on this at http://www.propublica.org/thetrade/item/the-trouble-with-disclosure-it-d.... Please don't hand car dealers another tool for committing fraud under cover of "disclosure".