16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604 #563688-00146

Submission Number:
Alex Gulotta
Legal Aid Justice Center
Initiative Name:
16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
The Legal Aid Justice Center (LAJC) provides legal representation for low-income individuals in Virginia. Our mission is to serve those in our communities who have the least access to legal resources. LAJC provides a full range of services to our clients, including services our federal and state governments choose not to fund. Our staff of 40 work from offices in Charlottesville, Falls Church, Petersburg and Richmond (read more about us at http://www.justice4all.org/about_us/history.) Our services do not stop with the resolution of an individual case. Through local and statewide organizing, education, and advocacy, we also address the root causes of the injustice and exploitation that keep our clients in poverty. All of our offices have repeatedly helped victims of autofraud. A typical case involves a low-income client being sued for a deficiency on a car that stopped running. LAJC is very familiar with the real-world significance of the importance of reliable transportation and the types of autofraud that are routinely committed. LAJC has reviewed the comments submitted by the Arizona Consumers Council Foundation, Chicago Consumer Coalition Consumer Assistance Council, Consumer Federation of America, Consumer Federation of California, Consumer Federation of the Southeast Consumer Action, Consumers for Auto Reliability and Safety, Maryland Consumer Rights Coalition, National Association of Consumer Advocates National Consumer Law Center (on behalf of its low-Income clients), U.S. Public Interest Research Group, Virginia Citizens Consumer Council, and Watsonville Law Center on March 12, 2013,(see attached). LAJC fully supports and endorses those comments and adopts those recommendations as its own. The goal of the Buyers Guide should be to deliver as much information as possible into the hands of consumers who are looking at used vehicles and trying to determine how much to pay. As stated by the United States Supreme Court, "blind economic activity is inconsistent with the efficient functioning of a free economic system such as ours, whose ability to provide desired material at the lowest cost is dependent on the asserted preferences and informed choices of consumers." Mourning v. Family Publications Svc., Inc. 411 U.S. 356, 364 (1973). Therefore, the recommendations made by the attached letter should be adopted because they will increase the information provided to consumers, protect against fraud, and improve the functioning of our free economic system.