Submission Number: 563688-00086
Received: 2/25/2013 1:58:54 PM
Commenter: Mark Heaney
Organization: Heaney Law Firm, LLC
Agency: Federal Trade Commission
Initiative: 16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Attachments: No Attachments
This attempt by the Federal Trade Commission to modify its buyers' guide for used cars is wrong. The current guide is ineffective and the proposed changes are even worse.
The buyers' guide gives misleading information, for example telling buyers that dealers aren't responsible for repairs to vehicles sold "as is." That's not true, under many state laws and federal warranty law.
The Used Car Buyer's Guide should be modified to require the disclosure of more information. Specifically, dealers should be required to disclose known damage or title brand history of the car prior to purchase.
I would suggest no modification to the sticker over this proposed change alone.