In the Matter of General Motors LLC, File Number 152-3101 #00061

Submission Number:
Joanne Faulkner
Initiative Name:
In the Matter of General Motors LLC, File Number 152-3101
Merely requiring disclosure of recalls is NOT a satisfactory remedy when inexperienced and perhaps illiterate consumers are dealing with experienced car dealers and their sophisticated lawyers. "Disclosure is a lawmakers' panacea per the following article: Most people find disclosures complex, obscure, and dull. Most people make choices by stripping information away, not layering it on. Most people find they can safely ignore most disclosures and that they lack the literacy to analyze them anyway. And so many disclosures are mandated that nobody could heed them all. Nor can all this be changed by simpler forms in plainer English, since complex things cannot be made simple by better writing. Furthermore, disclosure is a lawmakers' panacea, so they keep issuing new mandates and expanding old ones, often instead of taking on the hard work of writing regulations with bite. Note that approximately 40% of the American population lacks the literacy skills to fill out job applications or bank deposit slips correctly. Nearly half of American consumers read at no more than an 8th grade level. Already challenged by these basic skills deficiencies, a typical car buyer suffers further at the hands of aggressive and experienced car sales tactics See Nat'l. Ctr. for Educ. Statistics, National Assessment of Adult Literacy (2003); U.S. Dep't of Educ., National Ctr. for Educ. Statistics, Adult Literacy in America (Sept. 1993) (available from the U.S. Gov't Printing Office, GPO stock number 065-000-00588-3), discussed in, e.g., Alan M. White & Cathy Lesser Mansfield, Literacy and Contract, 13 Stan. L. & Pol'y Rev. 233, 235--242 (2002). See also Nat'l. Center for Education Statistics,