Submission Number: 563688-00131
Received: 3/12/2013 12:45:13 PM
Commenter: Susan Stoney
Agency: Federal Trade Commission
Initiative: 16 CFR Part 455 Used Motor Vehicle Trade Regulation Rule; Project No. P087604
Attachments: No Attachments
As currently proposed, the new AS IS statement misrepresents that no remedy is available for other express statements. This provides inaccurate legal advice in Virginia.
Dealers should be required to state whether a manufacturer's warranty applies. This information is crucial for the market to properly value the car. As the owner of the car, a car dealer is in a better position to determine this rather than a future owner.
Known defects should also be disclosed. A car that has a known defect should not be sold without disclosure of the defect. This information is necessary for the market to properly price the vehicle. If a dealer knows a defect exists, it should be listed on the Buyers Guide.