16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00033

Submission Number:
00033
Commenter:
Martin Rapaport
Organization:
Rapaport USA
State:
Nevada
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
To: The Federal Trade Commission March 28, 2015 Re: Jewelry Guides, 16 CFR Part 23, Project No. G711001 The Federal Trade Commission (FTC) should make the following changes to the FTC Jewelry Guides: 1. The standard for diamond grading when using Gemological Institute of America (GIA) terminology shall be the results generated by the GIA Gem Trade Laboratory. 2. It is an unfair business practice to communicate the grade of a diamond using GIA terminology while applying non-GIA standards that systematically overgrade the quality of a diamond. An overgraded diamond is a diamond whose quality is communicated by the seller using GIA terminology and when graded by the GIA is found to be more than one color or clarity below the grade represented by the seller. 3. Diamond sellers are responsible for the quality of the diamonds they sell. In the event that a seller describes a diamond using GIA terminology and the diamond is graded by the GIA and found to be more than one color or clarity below the grade communicated by the seller, the buyer may return the diamond to the seller within a period of one year and obtain a full refund. Attached to this letter are three additional submissions. 1. A more detailed letter to the Federal Trade Commission as published in the "Rapaport Magazine" March, 2016, pages 34-35 This letter provides additional important background information as to why the Commission should address the issue of diamond overgrading. 2. The article "Honest Grading," published in the "Rapaport Magazine" November, 2015. This article and special report provide an in-depth analysis of the overgrading problem. 3. A press release dated September 9, 2014 issued by the Rapaport Group entitled "RapNet To Stop Listing EGL Grading Reports". RapNet is the world's largest diamond trading network with daily listings of over 1,000,000 diamonds valued at over $7.5 billion and 14,700 members in 91 countries. Thank you for your time and consideration, Martin Rapaport Chairman Rapaport Group martin@diamonds.net