In the Matter of General Motors LLC, File Number 152-3101
Dear FTC: Please do not allow car dealers to advertise and sell as "Certified" vehicles with safety recalls. I have prosecuted car dealers for years regarding fraudulent "Certified" sales. There needs to be no wiggle room for dealers to employ sharp practices and to engineer a phony informed consent of the consumer. At best, written disclosures of any kind in the context of high-pressure car sales are read and understood by only a very few consumers. Given the technical nature of recalls and the mechanical expertise of dealers and manufacturers that far exceed the average consumer, no notice could be sufficient in practice. Furthermore, it would be terrible to defeat common understanding and the uniform expectation that "Certification" means "safe," and to risk consumer lives in the process.