|Received:||7/19/2007 5:20:26 PM|
|Organization:||Broward County Consumers Affairs Division|
|Commenter:||Jennifer Di Bono|
|Agency:||Federal Trade Commission|
|Rule:||Guides Concerning Fuel Economy Advertising for New Automobiles|
Comments:Comments on Question 1: Is there a continuing need for the Fuel Economy Guide? This office believes there is a continuing need for the Fuel Economy Guide. §259.2(a) states: “No manufacturer or dealer shall make any express or implied representation in advertising concerning the fuel economy of any new automobile unless such representation is accompanied by the following clear and convincing disclosures…” “Clear and convincing disclosures” is the key phrase in that section. This office believes that without the Guide and this specific wording that auto manufactures and dealers would participate in unfair and deceptive trade practices thereby putting the consumer at a disadvantage. Comments on Question 1: Is the Guide necessary to prevent unfair and/or deceptive practices in advertising for new automobiles? This office believes that without these guidelines provided by the FTC and EPA that local car dealers would participate in deceptive practices. This office receives dozens of complaints a year relating to unfair and deceptive trade practices. It is with the backing of the Guide that this office is able to police unfair and deceptive trade practices and bring enforcement actions. In addition, this office acts as a watchdog over the advertising and sale of new vehicles. It is through reference to the Guide that we are able to insure that local dealers refrain from unfair or deceptive trade practices and provide consumers with reliable information. We believe that if the Fuel Economy Guide is discontinued that consumers would be at a significant disadvantage when buying a new car. Comments on Question 1: Are there any specific provisions of the Guide that are no longer needed to prevent unfair and/or deceptive advertising practices? No. In fact this office is submitting a separate comment as to what additions should be made to the Guide to reflect the EPA’s new guidelines.