CARCO Group, Inc.
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
I am writing to comment on 16 CFR Part 455. CARCO Group, Inc. has been in business since 1977, working with insurance companies, law enforcement agencies, car dealers, and consumers, in the detection and prevention of automobile theft and insurance fraud. We are also a provider of NMVTIS (National Motor Vehicle Title Information System) to all of the above entities. As you may be aware, in 2012 California passed a law (AB 1215) requiring all car dealers to provide NMVTIS information to a buyer of any used vehicle. This reliable data (title history, salvage, junk, and insurance total loss information) has proven to be very valuable for consumers, as well as, car dealers. In fact, the major auto dealer associations supported this legislation. We strongly support the Federal Trade Commission (FTC) requiring all dealers nationwide to disclose NMVTIS data to potential buyers of used vehicles. They should be required to prominently post information (perhaps by way of a large sticker) warning consumers if there is adverse information contained in the NMVTIS report relating to a particular vehicle (title brand, salvage and insurance loss information). NMVTIS is comprehensive since it is enabled by federal law and requires state motor vehicle departments, salvage yards, salvage pools, junk yards, recyclers, and insurance companies to report data. The cost for dealers to obtain NMVTIS data is minimal. Most providers are offering this data for, at most, a few dollars with some offering it for far less. The benefits of requiring that NMVTIS information be provided to consumers are extensive. Consumer protection is the obvious and the most critical factor. Additionally, the effect on the deterrence of fraud and theft is enormous. Due to its attributes, NMVTIS will help reduce insurance losses which will have a direct effect on containing insurance premium increases. We strongly encourage your support for the aforementioned requirement. If you desire further information or input, we will be pleased to assist in any way possible.