These comments were submitted in response to the Federal Trade Commission’s Notice of Proposed Rulemaking published on December 17, 2012, regarding the agency’s Used Car Rule.
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The existing rule, which was promulgated in 1985, was fundamentally flawed from its inception, and is now also antiquated. Parts of it — particularly the language interpreting what ” AS IS” means — are false and misleading, and function as a shield for unscrupulous dealers. On balance, it harms consumers. The proposed rule is even worse, and threatens to undermine an entire body of auto fraud law that has developed at the state level, that is far more protective of used car buyers.