In the Matter of General Motors LLC, File Number 152-3101 #00070

Submission Number:
Richard Jaggi
Initiative Name:
In the Matter of General Motors LLC, File Number 152-3101
This is not good for the following reasons: -It is inherently deceptive for an auto dealer to represent that its vehicles have passed a rigorous inspection, without ensuring that the safety recall repairs have been performed. -No amount or type of disclosure is adequate, when it contradicts the core message: this vehicle has been checked out and passed a detailed inspection, so it's not just an OK car, it's a cut above. -"Certified" is a form of warranty, that creates a reasonable expectation of superior quality that is inconsistent with having any major defect -- especially a safety defect. -Allowing sales of unsafe vehicles with "disclosure" would put many vulnerable low-income car buyers at risk, due to lack of easy access to the internet / computers and a lack of English language proficiency. -As a legal matter, it's extremely difficult for victims of auto frauds involving recalled cars to prove that nothing was disclosed. Many dealers routinely forge signatures on documents. -Scientific studies have shown that disclosures are ineffective, particularly in the context of a complex financial transaction, where even the most sophisticated consumers do not read all the documents. -Allowing sales of unsafe vehicles with "disclosure" would endanger the lives of passengers and others who share the roads, not only those who buy the cars. -Car buyers may not be well-versed in the implications of safety recalls, making it easy for unscrupulous dealers to downplay the risks.