16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00028

Submission Number:
Derek Nelson
New Mexico
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Car dealers should make all efforts to list the problems of the used vehicles they are trying to sell. If a Dealer bought the car, they are required by law (Through NHTSA) to return/restore a vehicle to original safety standards before selling to a consumer. A dealer should disclose all or any repair or replacements done to a vehicle in order to restore to safe operating condition. This can easily be done in todays computer tracking capabilities. After all such agencies as CarFax can keep a running hisotry of the vehicle. How does that histroy get added. By the mechanics and dealerships Insurance companies that do the work. A CarFax report should show whne the dealership comes into possesion adn what repairs the dealership made on the vehicle. A dealer should replace all items in accordance to manufacture suggestion replacement schedule (e.g, if a timing belt is recommended to be replaced at 85,000 miles, and the odometer reading is 80,000 it would be a suggested the dealer replace this item prior to sale or inform the potentilal owner of immediate up coming repair replacement cost). If the mileage is 86,000 miles an insepection clear stating the condition of the belt. After all the dealer is or should be conducting their own "101 point" safety inspection. As a inspection is already being conducted by the dealer, this should automatically cover non safety items as well. In my opionon, brakes are considered a safety item, windshield a safety item, windschield wipers a safety item. All lights, etc, etc. Consumers should not to spend additional independant inspections on a vehicle to find out major issues with the vehicle, that would not conform to orginal manufacture safety and operating condition. Unless they choose to do so. After all, a consumer who spends for inspections could have put the money to the down payment and if takes a consumer to check 8 different vehicles at an independant inspection at $50.00-$75.00 a vehicle that is $400.00-$600.00. As for ssituations such as major/natural disasters, with todays technology and insurance data bases, there shoul dbe no reason vehicles from Hurricane Sandy should be "flooding" the market. A dealership buying used vehicle for resale also has due diligence in determining where the car came from and what condition the car is in prior to obtaininig possession of it. Insurance companies have a responsibility to enter vehicles by VIN and repport to national database the condition/outcome of the settlement in which the insurance company was cover the asset. Insuranace company written reports (PDF documents) can easily be attached to the database and VIN in order to maintain a tracking history.