Submission Number: 00029
Received: 10/24/2011 10:03:40 PM
Commenter: Clarence Ditlow
Organization: Center for Auto Safety
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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Submission Text
October 24, 2011
Federal Trade Commission
Office of the Secretary
600 Pennsylvania Ave NW
Washington DC 20580
Re: ‘‘Magnuson-Moss Warranty Act Rule Review, 16 CFR part 700, P114406,’’
The Center for Auto Safety (CAS) submits the following comments in regard to the above noticed docket. CAS supports the continuing need for the FTC Guidelines and Rules issued under the Magnuson-Moss Warranty Act. CAS is concerned that some provisions need to be tightened due to evasion by industry and that others need to be tightened to address the on-line market place.
The full comment is attached.
Clarence M Ditlow
Executive Director
Center for Auto Safety