Back in July, I wrote a post about the Federal Trade Commission’s call for public comment about the Used Car Rule. I said that the Used Car Rule should be revised to require even greater disclosure to consumers, and listed seven changes I thought the FTC should make.

Recently, Attorneys General from 40 states, the District of Columbia, and the Northern Mariana Islands submitted a joint comment to the FTC. Because lemon laws and consumer complaints often run through their offices, they know quite a bit about consumers’ problems with used cars. They say without hesitation that the Used Car Rule is valuable, but say (as I did) that it doesn’t go far enough.

The statement by the Attorneys General says, in part:

However, the Rule’s value is limited by the fact that it does not provide notice about the most material information consumers need to consider and, indeed, do consider in deciding whether to purchase – that is the vehicle’s history and prior use, including its prior title status, damage history, and whether it was repurchased by the vehicle manufacturer pursuant to a state Lemon Law.

They go on to say that the Wisconsin Buyer’s Guide should be a model for the FTC’s Buyer’s Guide.

Interestingly enough, ten Attorneys General didn’t sign the comment – those from Alabama, Alaska, Hawaii, Nebraska, North Carolina, Oklahoma, Pennsylvania, Texas, Utah, and Virginia.