On behalf of each of the above-designated organizations, CFA submits the following comments, in response to the Federal Trade Commission’s Notice of Proposed Rulemaking published on December 17, 2012, regarding the agency’s Used Car Rule.

Unfortunately, the FTC’s proposal is seriously flawed and would be harmful to consumers. Four years after seeking public comment, the agency has disregarded all the major recommendations made by consumer groups and state attorneys general, and instead proposes to make an antiquated, bad rule even worse. The people who will benefit from the FTC’s proposed rule are unscrupulous auto dealers, and the people who will be hurt are used car buyers.