Submission Number: 00010
Received: 10/24/2011 11:52:55 AM
Commenter: James Whittle
Organization: American Insurance Association
State: District of Columbia
Agency: Federal Trade Commission
Initiative: 16 CFR Parts 239, 700, 701, 702 and 703; Request for Comments Concerning Interpretations of Magnuson Moss Warranty Act; Rule Governing Disclosure of Written Consumer Product Warranty Terms and Conditions; Rule Governing Pre Sale Availability of Written Warranty Terms; and Guides for the Advertising of Warranties and Guarantees ; FTC Matter No. P114406
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Attached are the joint comments of the American Insurance Association ("AIA") and National Association of Mutual Insurance Companies ("NAMIC"). NAMIC and AIA are leading property and casualty trade associations representing the interests of the auto insurance industry nationwide. Auto insurers are amongst the greatest source of auto repair payments in the United States.
On the basis of our members’ experience, AIA and NAMIC can respond categorically to the FTC’s primary question--yes, there is a continuing need for the specific provisions of the Interpretations, Rules and Guides, particularly with regard to the prohibition on tying arrangements. Simply put, the FTC’s interpretations have expanded auto repair parts competition, resulting in better prices and increased consumer choice, while providing effective protections for consumers and opportunities for manufacturers and local distributors.