Submission Number: 563688-00099
Received: 3/5/2013 9:40:10 AM
Commenter: Gregory Reichenbach
Organization: Attorney at Law
Agency: Federal Trade Commission
Initiative: 16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Attachments: No Attachments
As an attorney who represents buyers of used cars, I oppose the proposed changes. The proposal includes information about customers rights -- the "as is" language -- that is not consistent with State law in some instances. This will cause confusion among consumers, and will almost certainly interfere with enforcement of state law claims already available to Ohio consumers. Any "disclosures" on the back of the form will never be noticed by consumers, and this will only allow dealers to escape responsibility by pointing to the disclosures on the back. Dealers should be required to disclose -- in a conspicuous manner -- known defects in the vehicle or the title.