The FTC’s Proposed Auto Dealer Rule (Part 1): Yo-Yo Financing

  • “Making any misrepresentation, expressly or by implication, regarding… when the transaction for the sale of the car is final or binding on all parties” (§ 463.3(h)); and
  • “Making any misrepresentation, expressly or by implication, regarding… [k]eeping cash down payments or trade-in vehicles, charging fees, or regarding initiating legal process or any action if a transaction is not finalized or if the consumer does not wish to engage in a transaction” (§ 463.3(i)).
  1. It opens the door to the use of “spot delivery agreements,” which facilitate yo-yo- financing abuses.

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Consumer Federation of America

Consumer Federation of America

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Consumer Federation of America (CFA) is a non-profit organization advancing the consumer interest through research, advocacy, and education.