In the Matter of General Motors LLC, File Number 152-3101 #00073

Submission Number:
Andy Carter
Initiative Name:
In the Matter of General Motors LLC, File Number 152-3101
I worked for 14+ years with the Washington Attorney General's Consumer Protection and Antitrust Division focusing largely on automobile sales, safety, and service. Based on that and other experiences I believe that the phrase "certified used car" has come to mean not only that the selling dealer has completed a comprehensive inspection of the vehicle, but has repaired to a commercially reasonable standard and identified issues. Though a used car (in Washington) will undoubtedly be sold As-Is, advertising that vehicle as being a "Certified Used Car" with unrepaired known defects would be actionable in Washington under our states Mini-FTC Act, the Consumer Protection Act. If the FTC were to in any way facilitate that deceptive and misleading advertising by entering into any Consent Order permitting that practice would be a mistake. To the extent the Consumer Law and Policy Blog has correctly stated that the propose CO in the case at issue does that, i.e., allow a selling dealer to falsely imply that a used vehicle is "certified" not only harm consumers, it harms the more legitimate dealers who sell certified used cars only after making the necessary repairs, including correcting all know defects, including those identified in a recall.