Submission Number: 563688-00110
Received: 3/6/2013 12:21:43 PM
Commenter: Williamd Bensley
Organization: Bensley Law Offices, LLC
Agency: Federal Trade Commission
Initiative: 16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Attachments: No Attachments
I am an attorney in Philadelphia, PA. I concentrate a substantial percentage of my professional representing consumers victimized by motor vehicle dealers. Dealers often misrepresent a vehicle's history, condition and value. It is becoming more and more common for dealers to use some form of contrived, partial and/or completely falsified disclosure to escape responsibility for their frauds. Critically, dealers use these and other tricks, to confuse and intimidate consumers from continuing to complain or from seeking qualified legal advice. If anything the FTC needs to strengthen the Buyers Guide so consumers (and dealers) know the Buyers Guide only relates to the warranties applicable to the vehicle being sold and it does not relate to damage caused by prior wrecks or to the dealer's representations regarding the vehicle's history, condition and value. Weakening consumer rights, and enabling bad dealers to escape responsibilities, the market is distorted, consumers suffer, and good dealers suffer or become bad dealers.