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RVDA Files Formal Comments on Proposed FTC Rule

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The national RV Dealers Association (RVDA) has filed comments critical of the Federal Trade Commission’s (FTC) proposed Motor Vehicle Trade Regulation Rule.

If adopted as proposed, the rule would increase sales transaction times for consumers and add to the cost of the RVs by adding unnecessary administrative overhead for dealers, RVDA said in formal comments filed on Sept. 12.

The FTC’s proposed rule would alter the way motor vehicles are sold, marketed, and financed in the U.S. by adding additional disclosures on pricing, vehicle add-ons and new recordkeeping requirements, the organization said.

The RVDA made the following statements:

  • The FTC proposed rule fails to take into consideration the sales and pre-delivery processes and costs associated with different types of motor vehicles.
  • “The automobile industry has standardized motor vehicles that can be driven away unaltered by the customer that same day, while in the RV industry it is customary to prepare a vehicle before a customer can use the RV.”
  • The rule, as currently drafted, could require dealers to provide the customer with a new set of disclosures every time the customer asks for a new option or add-on for the vehicle.
  • The FTC showed no justification for including RV dealers in the proposed rule and the agency did not produce “any findings that these unfair and deceptive acts or practices are prevalent in the RV industry.
  • The association believes this “enormous change in business practices” to add more complex and costly administrative requirements could drive small RV dealers out of the industry, removing small RV dealers that are capable of assisting customers across the country while they travel.
  • RVDA was also clear that the association “does not condone misleading advertising or unfair practices in the sales or financing process. However, the FTC already has the authority to combat deceptive trade practices and has used these regulations to go after dealers who do not comply with existing rules.”

RVDA will keep members informed as the FTC considers further action on the proposed rule.

For more information, visit www.rvda.org.

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