In the Matter of General Motors LLC, File Number 152-3101
"Certified" Used Cars must mean All Safety Recalls are Done I am a consumer protection lawyer in Arizona. A large part of my practice is to represent people that has been ripped off by car dealers. As such, I have examined hundreds, if not well in excess of thousand -- car sales, examined documents and interviewed consumers. I am glad the FTC is looking into abuses involved in selling of "certified" used cars. Many consumers believe that by a "certified" used car, they are buying a car that has been closely inspected (foe example "145 point inspection"), safe, and comes with extra warranties. However, my understanding is that you are planning allow dealers to sell "certified" used cars with unrepaired recalls if the dealers "clearly disclose the existence of the recalls in close proximity to the inspection claims." That is a wrong approach. I urge you to require all dealers that sell "certified" used cars to at least perform recall repairs. Otherwise, you will allow the dealers to advertise and tout the benefits of "certified" vehicles with 100+ inspections, yet hide the unsafe recalls in a fine print. Disclosure of recalls in close proximity to the inspection claims will not help. In a car transaction, consumers are deluged with many documents -- some necessary, many not -- asked to be signed. If consumers truly read all these documents, they will have to spend hours and hours. Even then, they may not fully understand. Adding another disclosure to hide unsafe recalls will not help. If anything, you should mandate a rule that requires all dealers to perform all recall work on any used cars being sold. The burden on he dealer will be minimal. The benefit to the society, on the other hand, will be tremendous as it will reduce unsafe vehicles on our road ways. And we should do everything we can do reduce the dangerous vehciles on the road. Or at a minimum, do not adopt a rule allowing the dealers to tout and sell "certfied" used cars with unsafe recalls not repaired. Thank you for your consideration.