Used Motor Vehicle Trade Regulation Rule, 42285-42293 [E8-16634]

Agencies

• FEDERAL TRADE COMMISSION

[Federal Register Volume 73, Number 140 (Monday, July 21, 2008)]
[Proposed Rules]
[Pages 42285-42293]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-16634]


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FEDERAL TRADE COMMISSION

16 CFR Part 455


Used Motor Vehicle Trade Regulation Rule

AGENCY: Federal Trade Commission.

ACTION: Request for public comments.

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SUMMARY: The Federal Trade Commission (``FTC'' or ``Commission'') 
requests public comments on its Used Motor Vehicle Trade Regulation 
Rule (``Used Car Rule'' or ``Rule''). The Commission is soliciting the 
comments as part of the FTC's systematic review of all current 
Commission regulations and guides.

DATES: Written comments relating to the Used Car Rule must be received 
by September 19, 2008.

ADDRESSES: Interested parties are invited to submit written comments 
relating to the Used Car Rule review. Comments should refer to ``Used 
Car Rule Regulatory Review, Matter No. P087604'' to facilitate the 
organization of comments. A comment filed in paper form should include 
this reference both in the text and on the envelope, and should be 
mailed or delivered to the following address: Federal Trade Commission/
Office of the Secretary, Room H-135 (Annex H), 600 Pennsylvania Avenue, 
N.W., Washington, D.C. 20580. Comments containing confidential material 
must be filed in paper form, must be clearly labeled ``Confidential,'' 
and must comply with Commission Rule 4.9(c).\1\ The FTC is requesting 
that any comment filed in paper form be sent by courier or overnight 
service, if possible, because postal mail in the Washington area and at 
the Commission is subject to delay due to heightened security 
precautions.
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    \1\ The comment must be accompanied by an explicit request for 
confidential treatment, including the factual and legal basis for 
the request, and must identify the specific portions of the comment 
to be withheld from the public record. The request will be granted 
or denied by the Commission's General Counsel, consistent with 
applicable law and the public interest. See Commission Rule 4.9(c), 
16 CFR 4.9(c).
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    Comments filed in electronic form should be submitted by following 
the instructions on the web-based form at: (https://
secure.commentworks.com/ftc-UsedCarRuleReview). To ensure that the 
Commission considers an electronic comment, you must file it on the 
web-based form. You may also visit https://www.regulations.gov to read 
this notice, and may file an electronic comment through that Web site. 
The Commission will consider all comments that www.regulations.gov 
forwards to it.

[[Page 42286]]

    The FTC Act and other laws the Commission administers permit the 
collection of public comments to consider and to use in this proceeding 
as appropriate. The Commission will consider all timely and responsive 
public comments that it receives, whether filed in paper or electronic 
form. Comments received will be available to the public on the FTC Web 
site, to the extent practicable, at https://www.ftc.gov. As a matter of 
discretion, the FTC makes every effort to remove home contact 
information for individuals from the public comments it receives before 
placing those comments on the FTC Web site. To read our policy on how 
we handle the information you submit - including routine uses permitted 
by the Privacy Act - please review the FTC's privacy policy, at https://
www.ftc.gov/ftc/privacy.htm.

FOR FURTHER INFORMATION CONTACT: John C. Hallerud, (312) 960-5615, 
Attorney, Midwest Region, Federal Trade Commission.

SUPPLEMENTARY INFORMATION:

I. Background

    The Commission promulgated the Used Car Rule in 1984 and the Rule 
became effective in 1985.\2\ The Used Car Rule is intended primarily to 
prevent oral misrepresentations and unfair omissions of material facts 
by used car dealers concerning warranty coverage. To accomplish that 
goal, the Rule provides a uniform method for disclosing warranty 
information on a window sticker called the ``Buyers Guide'' that 
dealers are required to display on used cars. The Rule requires used 
car dealers to disclose on the Buyers Guide whether they are offering a 
used car for sale with a dealer's warranty and, if so, the basic terms, 
including the duration of coverage, the percentage of total repair 
costs to be paid by the dealer, and the exact systems covered by the 
warranty. The Rule additionally provides that the Buyers Guide 
disclosures are to be incorporated by reference into the sales 
contract, and are to govern in the event of an inconsistency between 
the Buyers Guide and the sales contract. The Rule requires Spanish 
language versions of the Buyers Guide when dealers conduct sales in 
Spanish.
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    \2\ 49 FR 45,692 (November 19, 1984).
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    The Rule also requires other disclosures that must be printed 
directly on the Buyers Guide, including:
    (1) A suggestion that consumers ask the dealer if a pre-purchase 
inspection is permitted;
    (2) A warning against reliance on spoken promises that are not 
confirmed in writing; and
    (3) A list of fourteen major systems of a used motor vehicle and 
the major defects that may occur in these systems.
    In 1995, as part of its periodic review, the Commission amended the 
Used Car Rule.\3\ Specifically, the Commission amended the Rule by: (1) 
adopting several minor grammatical changes to the Spanish language 
version of the Buyers Guide; (2) permitting dealers to display a Buyers 
Guide anywhere on a used motor vehicle so long as the Buyers Guide is 
displayed prominently and both sides of it are readily readable; and 
(3) allowing dealers to obtain a consumer's signature on the Buyers 
Guide to acknowledge receipt.
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    \3\ 60 FR 62,195 (December 5, 1995).
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    The Rule provides for both English and Spanish Buyers Guides. In 
the past, Commission staff has advised dealers who conduct substantial 
numbers of sales in Spanish to display both English and Spanish Buyers 
Guides.\4\ In response to questions from industry, the Commission is 
seeking comments on whether the Rule should be revised to permit 
dealers to use a single bilingual Buyers Guide. The Commission is also 
seeking proposals for the design of bilingual Buyers Guides.
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    \4\ See Staff Compliance Guidelines, 53 FR 17,660, 17,664, 
17,667 (Illustration 3.10) (May 17, 1988). The Staff Compliance 
Guidelines and other information about the Used Car Rule are 
available online from the Commission's Web site at: www.ftc.gov.
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    The reverse side of the Buyers Guide contains a pre-printed list of 
fourteen major systems and the defects that may occur in those systems. 
That list has not been changed since the Used Car Rule was promulgated 
in 1984. The list was promulgated from the rulemaking proceeding and 
from information gleaned from prior versions of the Used Car Rule. The 
Commission is seeking comments on the value of the Buyers Guide's pre-
printed list of major systems and defects and whether the list should 
be revised or eliminated.
    The Commission is also seeking comments on how well the current 
method for disclosing unexpired manufacturer's warranties on the Buyers 
Guide is working. In connection with that inquiry, the Commission is 
seeking comments on a possible alternative Buyers Guide to aid in 
disclosing dealers' warranties, unexpired manufacturer's warranties, 
manufacturer's used car warranties, and used car warranties provided by 
third parties other than the manufacturer. Examples of Buyers Guides 
that incorporate a revised method for disclosing these various types of 
warranties are attached to this notice as Appendices A and B.

II. Regulatory Review of the Used Car Rule

    The Commission reviews all of its rules and guides periodically to 
examine their efficacy, costs, and benefits; and to determine whether 
to retain, modify, or rescind them. This notice commences the 
Commission's review of the Used Car Rule.

A. General Areas of Interest for FTC Review

    As part of its review, the Commission is seeking comment on a 
number of general issues, including the continuing need for the Used 
Car Rule and its economic impact, the effect of the Rule on deception 
in the used car market, and the interaction of the Rule with other 
regulations. Since the Commission's last revisions of the Rule in 1995, 
new used car products, such as certified used car warranties, have 
become increasingly popular. The Commission believes that this review 
is important to ensure that the Rule is appropriately responsive to any 
changes in the marketplace.

B. Specific Areas of Interest for FTC Review

    Since the last revisions to the Rule in 1995, the Commission 
occasionally has received informal input regarding the efficacy of the 
Rule and requests for clarification about the Rule's application. Some 
of the questions included in this notice, therefore, address specific 
issues. By including these issues, the Commission intends to facilitate 
comment, and the inclusion or exclusion of any issue is no indication 
of the Commission's intent to make any specific modifications to the 
Rule.

III. Issues for Comment

    The Commission requests written comment on any or all of the 
following questions. The Commission requests that responses to its 
questions be as specific as possible, including a reference to the 
question being answered, and reference to empirical data or other 
evidence wherever available and appropriate.

A. General Issues

    (1) Is there a continuing need for the Rule? Why or why not?
    (2) What benefits has the Rule provided to consumers? What evidence 
supports the asserted benefits?
    (3) What modifications, if any, should be made to the Rule to 
increase its benefits to consumers?

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    (a) What evidence supports the proposed modifications?
    (b) How would these modifications affect the costs the Rule imposes 
on businesses, and in particular on small businesses?
    (c) How would these modifications affect the benefits to consumers?
    (4) What impact has the Rule had on the flow of truthful 
information to consumers and on the flow of deceptive information to 
consumers?
    (5) What significant costs has the Rule imposed on consumers? What 
evidence supports the asserted costs?
    (6) What modifications, if any, should be made to the Rule to 
reduce the costs imposed on consumers?
    (a) What evidence supports the proposed modifications?
    (b) How would these modifications affect the benefits provided by 
the Rule?
    (7) How have the 1995 amendments to the Rule affected purchasers of 
used motor vehicles? How have the 1995 amendments to the Rule affected 
used motor vehicle dealers? Please provide any evidence that has become 
available since 1995 concerning the costs, benefits, and effectiveness 
of the Rule. Does this new information indicate that the Rule should be 
modified? If so, why, and how? If not, why not?
    (8) What benefits, if any, has the Rule provided to businesses, and 
in particular to small businesses? What evidence supports the asserted 
benefits?
    (9) What modifications, if any, should be made to the Rule to 
increase its benefits to businesses, and in particular to small 
businesses?
    (a) What evidence supports the proposed modifications?
    (b) How would these modifications affect the costs the Rule impose 
on businesses, and in particular on small businesses?
    (c) How would these modifications affect the benefits to consumers?
    (10) What significant costs, including costs of compliance, has the 
Rule imposed on businesses, and in particular on small businesses? What 
evidence supports the asserted costs?
    (11) What modifications, if any, should be made to the Rule to 
reduce the costs imposed on businesses, and in particular on small 
businesses?
    (a) What evidence supports the proposed modifications?
    (b) How would these modifications affect the benefits provided by 
the Rule?
    (12) What evidence is available concerning the degree of industry 
compliance with the Rule? To what extent has there been a reduction in 
deceptive oral representations and unfair omissions made by used car 
dealers concerning warranty coverage since the Rule was issued? Please 
provide any supporting evidence. Does this evidence indicate that the 
Rule should be modified? If so, why, and how? If not, why not?
    (13) What modifications, if any, should be made to the Rule to 
account for changes in relevant technology or economic conditions? What 
evidence supports the proposed modifications?
    (14) Does the Rule overlap or conflict with other federal, state, 
or local laws or regulations? If so, how?
    (a) What evidence supports the asserted conflicts?
    (b) With reference to the asserted conflicts, should the Rule be 
modified? If so, why, and how? If not, why not?

B. Specific Issues

    (1) Should the Used Car Rule be modified to permit used motor 
vehicle dealers the option of using a Buyers Guide that combines both 
the English and Spanish language versions of the Buyers Guide into a 
single bilingual document? If not, why not? If so, why? If so, how 
should bilingual Buyers Guides be designed and formatted? How should 
bilingual Buyers Guides be designed and formatted to minimize consumer 
confusion?
    (a) If recommending that bilingual Buyers Guides should be 
permitted, provide as much detail as possible about the form that the 
bilingual Buyers Guides should take. Provide examples of bilingual 
Buyers Guides for use in states that permit ``as is'' sales (i.e., 
sales in which implied warranties are disclaimed) and states that 
prohibit ``as is'' sales (i.e., ``Implied Warranties Only'' sales). 
Indicate the type styles, sizes, and format used in examples of 
bilingual Buyers Guides that are submitted.
    (b) What benefits, if any, would bilingual Buyers Guides provide 
consumers? What evidence supports the asserted benefits?
    (c) What burdens, if any, would bilingual Buyers Guides impose on 
consumers? What evidence supports the asserted burdens?
    (d) What benefits, if any, would bilingual Buyers Guides provide 
businesses, and in particular small businesses? What evidence supports 
the asserted benefits?
    (e) What burdens, if any, would bilingual Buyers Guides impose on 
businesses, and in particular small businesses? What evidence supports 
the asserted burdens?
    (f) Question 8 below discusses possible alternative Buyers Guides 
intended to facilitate the disclosure of manufacturer's and other 
third-party warranties. How would your answers to the preceding 
questions about bilingual Buyers Guides change if the Commission 
adopted a revised Buyers Guide as described in Question 8?
    (2) Should the translation of the Buyers Guide into Spanish be 
revised as described below? If so, why? If not, why not?
    (a) Should the term ``dealer'' be translated into Spanish as 
``concesionario,'' instead of ``distribuidor'' and ``vendedor?''
    (b) Should the term ``regardless of'' in the statement below the AS 
IS - NO WARRANTY box on the front of the Buyers Guide be translated 
into Spanish as ``independientemente de'' instead of ``sean cuales 
sean?''
    (c) Should the following revisions be made to the Spanish 
translation of terms used in the list of major defects in automobile 
systems on the reverse side of the Buyers Guide?
    (i) Should the term ``Frame-cracks'' in the Frame & Body section be 
translated as ``Grietas en el chasis,'' instead of ``Chasis-grietas?''
    (ii) Should the term ``Cooling System'' in the Cooling System 
section be translated as ``Sistema de enfriamiento,'' instead of 
``Sistema de refrigeraci''
    (iii) Should the term ``Air conditioner'' in the Inoperable 
Accessories section be translated as ``Aire acondicionado,'' instead of 
``Acondicionador de aire?''
    (iv) Should the term ``Defroster'' in the Inoperable Accessories 
section be translated as ``Desempaador,'' instead of ``Descarchador?''
    (v) Should the terms ``Not enough pedal reserve'' in the Brake 
System section be translated as ``Distancia insuficiente del pedal,'' 
instead of ``Juego insuficiente en el pedal?''
    (3) What purposes, if any, does the list of systems and major 
defects that may occur in a used motor vehicle on the reverse side of 
the Buyers Guide serve?
    (a) What benefits does the list provide to consumers?
    (b) What burdens does the list impose on consumers?
    (c) What benefits does the list provide to businesses, and in 
particular to small businesses?
    (d) What burdens does the list impose on businesses, and in 
particular on small businesses?
    (e) Should the list be retained? Why or why not?
    (f) Should the list be modified? If so, why, and how? If not, why 
not?
    (4) The Rule permits dealers who opt to disclose an unexpired 
manufacturer's warranty to add the following statement to the Buyers 
Guide below the FULL/LIMITED WARRANTY boxes in the SYSTEMS COVERED/
DURATION section:

[[Page 42288]]

    MANUFACTURER'S WARRANTY STILL APPLIES. The manufacturer's original 
warranty has not expired on the vehicle. Consult the manufacturer's 
warranty booklet for details as to warranty coverage, service location, 
etc.\5\
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    \5\ 16 C.F.R. Sec.  455.2(b)(2)(v).
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    Separately and beneath that statement, in states that permit ``as 
is'' sales, dealers may add:
    The dealership itself assumes no responsibility for any repairs, 
regardless of any oral statements about the vehicle. All warranty 
coverage comes from the unexpired manufacture's warranty.\6\
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    \6\ Staff Compliance Guidelines, 53 Fed. Reg. 17,660 at 17,663 
(May 17, 1988).
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    (a) What benefits, if any, does the method permitted by the Rule 
for disclosing unexpired manufacturer's warranties provide consumers?
    (b) What burdens does the method permitted by the Rule for 
disclosing unexpired manufacturer's warranties impose on consumers?
    (c) What benefits does the method for disclosing unexpired 
manufacturer's warranties permitted by the Rule provide businesses, and 
in particular small businesses?
    (d) What burdens does the method for disclosing unexpired 
manufacturer's warranties permitted by the Rule provide businesses, and 
in particular small businesses?
    (e) Should the current method permitted by the Rule for disclosing 
unexpired manufacturer's warranties be modified? If so, why, and how? 
If not, why not?
    (f) Should the Rule provide an option to use a similar method for 
disclosing other warranties that are included in the price of the used 
vehicle, such as manufacturer's certified used car warranties and 
warranties provided by other third parties? If so, why, and how? If 
not, why not?
    (5) Should the optional statement provided by the Rule to indicate 
that a manufacturer's warranty applies be revised to alert consumers to 
check the warranty booklet for the expiration date of the 
manufacturer's warranty by stating: ``Consult the manufacturer's 
warranty booklet for details as to warranty coverage, expiration, 
service location, etc?'' Why or why not?
    (6) Should the Rule require dealers to indicate whether a 
manufacturer's warranty applies and provide information about the scope 
of that coverage? Why or why not? Should disclosure of manufacturer's 
warranties be optional as the Rule currently provides? Why or why not?
    (7) Is checking the AS IS - NO WARRANTY box to indicate that the 
dealer is not obligated to perform warranty service clear and 
understandable to consumers? Why or why not? Does checking the AS IS - 
NO WARRANTY box confuse consumers about whether other warranty or 
service coverage, such as a manufacturer's warranty, applies? Why or 
why not? How could the Buyers Guide be redesigned to prevent consumer 
confusion about the meaning of the ``as is'' disclosure?
    (8) Examples of revised Buyers Guides that provide a different 
method to disclose manufacturer's warranties and third-party warranties 
that are included in the price of the used car are attached as 
Appendices A and B. Appendix A is designed for use in states that 
permit dealers to sell used cars ``as is,'' i.e., without any warranty 
from the dealer. Appendix B is designed for use in states that prohibit 
``as is'' sales.
    The Buyers Guide attached as Appendix A states:
    [squ] ``AS IS'' - NO DEALER WARRANTY THE DEALER WILL NOT PAY ANY 
COSTS FOR ANY REPAIRS. The dealer assumes no responsibility for any 
repairs regardless of any oral statements about the vehicle.
    If a dealer chooses to use a Buyers Guide like Appendix A and does 
not offer its own warranty, the dealer would check the box to indicate 
that the car is being offered ``AS IS''- NO DEALER WARRANTY.
    If state law limits or prohibits ``as is'' sales of vehicles or the 
dealer chooses to offer the vehicle with implied warranties only when 
offering a car for sale in a state that permits ``as is'' sales, the 
following should be substituted for ``AS IS'' - NO DEALER WARRANTY, and 
its accompanying language:
    [squ] IMPLIED WARRANTIES ONLY
    This means that the dealer does not make any specific promises to 
fix things that need repair when you buy the vehicle or after the time 
of sale. But, State law ``implied warranties'' may give you some rights 
to have the dealer take care of serious problems that were not apparent 
when you bought the vehicle.
    Appendix B is a Buyers Guide that uses the above disclosure to 
indicate that the dealer is offering implied warranties only.
    If a dealer chooses to use a Buyers Guide like Appendix A or B and 
the dealership provides its own used car warranty, the dealer would 
check the DEALER WARRANTY box, indicate whether the warranty is full or 
limited, and identify the percentage of labor and parts that the dealer 
will pay for repairs:
    [squ] DEALER WARRANTY
    [squ] FULL [squ] LIMITED WARRANTY. The dealer will pay -- % of the 
labor and ---- % of the parts for the covered systems that fail during 
the warranty period. Ask the dealer for a copy of the warranty document 
for a full explanation of warranty coverage, exclusions, and the 
dealer's repair obligations. Under state law, ``implied warranties'' 
may give you even more rights.
    Immediately beneath this section, the dealer would indicate the 
Systems Covered and the Duration of coverage for the identified 
systems:
SYSTEMS COVERED: DURATION:
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----

    If the dealer does not provide its own warranty and state law 
permits the dealer to sell used cars ``as is,'' in the space provided 
for the SYSTEMS COVERED/DURATION, the dealer may fill in (or pre-print 
or use a rubber stamp) the following statement: ``The dealership itself 
assumes no responsibility for any repairs, regardless of any oral 
statements about the vehicle. All warranty coverage comes from the 
unexpired manufacturer's warranty, manufacturer's used car warranty, or 
other used car warranty indicated below.''
    The Buyers Guide would have additional boxes below the SYSTEMS 
COVERED/DURATION section where the dealer could indicate whether the 
dealer is offering a used car with a manufacturer's warranty or other 
third-party warranty. If a dealer chooses to disclose manufacturer's 
warranties and third-party warranties using Appendix A or B, dealers 
would check the appropriate boxes to indicate the types of warranties 
that are provided as part of the sales price of the car.
    [squ] NON-DEALER WARRANTIES
    [squ] MANUFACTURER'S WARRANTY STILL APPLIES.
    The manufacturer's original warranty has not expired on the 
vehicle.
    [squ] MANUFACTURER'S USED CAR WARRANTY APPLIES.
    [squ] OTHER USED CAR WARRANTY APPLIES.
    Consult the warranty booklet for details as to warranty contract 
coverage, expiration, service location, etc.
    [squ] NO INFORMATION PROVIDED. The dealer provides no information 
about other warranties that may apply.
    The Rule's SERVICE CONTRACT box and corresponding explanation that 
a service contract is available would appear below this statement 
separated by a line to distinguish service contract availability from 
warranty coverage:
    [squ] SERVICE CONTRACT. A service contract is available at an extra 
charge

[[Page 42289]]

on this vehicle. Ask for details as to coverage, deductible, price, and 
exclusions. If you buy a service contract within ninety days of sale, 
state law ``implied warranties'' may give you additional rights.
    (a) Should the Rule be revised to permit dealers to disclose 
unexpired manufacturer's warranties, manufacturer's used car 
warranties, and other used car warranties as shown in Appendices A and 
B?
    (b) What benefits, if any, would revising the Rule to permit 
dealers to disclose warranties as shown in Appendices A and B provide 
to consumers?
    (c) What burdens, if any, would revising the Rule to permit dealers 
to disclose warranties as shown in Appendices A and B impose on 
consumers?
    (d) What benefits, if any, would revising the Rule to permit 
dealers to disclose warranties as shown in Appendices A and B provide 
to businesses, and in particular to small businesses?
    (e) What burdens, if any, would revising the Rule to permit dealers 
to disclose warranties as shown in Appendices A and B impose on 
businesses, and in particular on small businesses?
    (f) What alternatives, if any, should be considered? Why? If no 
alternatives should be considered, why not?
    (g) Does stating ``AS IS'' - NO DEALER WARRANTY (See Appendix A) 
instead of AS IS - NO WARRANTY make the Buyers Guide more clear and 
understandable to consumers? Why or why not?
    (h) Is checking the box marked ``AS IS'' - NO DEALER WARRANTY to 
indicate that a dealer does not offer its own warranty clear and 
understandable to consumers when a dealer also checks one or more of 
the boxes indicating that a NON-DEALER WARRANTY from someone other than 
the dealer applies? Why or why not?
    (i) Does stating, ``THE DEALER WILL NOT PAY ANY COSTS FOR ANY 
REPAIRS'' (See Appendix A), instead of ``YOU WILL PAY ALL COSTS FOR ANY 
REPAIRS'' to explain ``AS IS'' - NO DEALER WARRANTY make the Buyers 
Guide in Appendix A more clear and understandable to consumers? Why or 
why not?
    (j) Does adding the statement ``FROM THE DEALER'' help show that 
the boxes marked IMPLIED WARRANTIES ONLY and DEALER WARRANTY apply only 
to warranties that may, or may not, be offered by the dealer? If so, 
why? If not, why not? If not, how could the format and/or wording be 
improved?
    (k) Does eliminating the lines for text in the SYSTEMS COVERED/ 
DURATION section of the Buyers Guide, as shown in Appendices A and B, 
make it easier or more difficult to disclose each system covered and 
the duration of coverage for each system? Why?
    (l) If the Rule is revised to permit dealers to use the Buyers 
Guides in Appendices A and B, what combination of type size, paper 
size, and formatting, particularly the amount of space allotted for the 
SYSTEMS COVERED/DURATION section, should be used to accommodate the 
additional text and other information in the Appendices, while assuring 
that the Buyers Guides are clear and understandable to consumers? In 
particular:
    (i) Should the Rule be revised to specify smaller or larger type 
sizes for Buyers Guides like those in Appendices A and B than currently 
prescribed by the Rule? Why, or why not? If so, specify the type sizes.
    (ii) Instead of, or in combination with, changes in type sizes, 
should the Rule be revised to specify that Buyers Guides like those in 
Appendices A and B be printed on paper larger than the currently 
prescribed 11`` x 7 1/4'' minimum? Why or why not? If so, specify 
minimum paper sizes, and identify type sizes if in combination with a 
recommended type size.
    (iii) Instead of, or in combination with changes in type size and 
paper size, should the space allotted for dealers to disclose warranty 
coverage and duration in the SYSTEMS COVERED/DURATION section of the 
Buyers Guide be increased or decreased? Why, or why not? How do changes 
in type size and paper size affect your answer?
    (9) Does the statement ``IMPLIED WARRANTIES ONLY'' and accompanying 
text clearly disclose that the dealer offers no express warranty? If 
not, how could the disclosure be made clearer?
    (10) Should the Rule's type style, size, and format requirements 
for Buyers Guides be revised to accommodate current word processing 
programs? If so, why, and how? If not, why not?
    (11) What other changes to the format of the Buyers Guide should be 
considered to increase its benefits? What effect would such changes 
have on the costs or burdens imposed by the Rule? What empirical or 
other evidence supports opinions that such changes would or would not 
increase costs or burdens?
    (12) What other changes to the format of the Buyers Guide should be 
considered to reduce compliance costs or burdens? Would such changes 
have any detrimental effect on the benefits provided by the Rule? What 
empirical or other evidence supports opinions about whether such 
changes would have a detrimental effect on benefits?

List of Subjects in 16 CFR Part 455

    Motor Vehicles, Trade Practices.

    Authority: 15 U.S.C. 41-58, 15 U.S.C. 2309.
    By direction of the Commission.

Donald S. Clark
Secretary

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APPENDIX A
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APPENDIX B
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[FR Doc. E8-16634 Filed 7-18-08: 8:45 am]
BILLING CODE 6750-01-S]