16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00061

Submission Number:
Mariella Castaldi
East Bay Community Law Center
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
The East Bay Community Law Center is a non-profit community organization that provides legal advice and representation for the most vulnerable members of our community--including the homeless, low-income immigrant families, and very impoverished members of our community. Through our Consumer Protection clinics, we often see people getting scammed by car sellers, whether dealers or individual buyers, and incurring hidden costs for their car purchases that place an undue burden on them while they are already in a financially unstable condition. In the past five years, we have assisted over 200 individuals who have been victims of used car scams or been underinformed about their car purchases. People buy cars to allow them to provide more safety and stability for their families. Reducing consumer protections for used car buyers would cause just the opposite to take place. The FTC is in the business of protecting consumers and empowering them to make informed choices. Why, then, would the FTC reduce the consumer's ability to understand the value and effectiveness of the product they are buying? Used car sellers must be required to perform their due diligence and investigate possible defaults with their products--and then upon knowing existing issues with their product, disclose them to a consumer. In the case of a vehicle sale, it is more than just a faulty product to be bought--it is a matter of safety. Not knowing that the car has a faulty sensor can cost you hundreds of dollars, but not knowing that your car has faulty anti-lock brakes could cost you your life. There are already so many pitfalls for consumers in the used car market. We cannot afford more opportunities for people to be taken advantage of by dealers who put a new paint job on what turns out to be a dangerous, costly lemon of a product. Such a reduction in consumer protection, as always, affects most strongly the members of our community who are constantly living on the brink of financial disaster, who are a few hundreds of dollars away from going under altogether. Please do not remove what few consumer protections exist for used car buyers. Do not make more service providers turn away more poor families who have been scammed out of thousands of their precious dollars because there is nothing to be done to help them because of weak consumer protection. Thank you for your consideration.