September 7, 2022

Dear FTC Commissioners:

We are writing you on behalf of the 60 Plus Association – American Association of Senior Citizens, representing millions of senior citizens and older Americans nationwide.

Personal transportation is critical for seniors nationwide. And as a matter of principle, we believe strongly in transparency and simplicity in the car buying process.

Unfortunately, the FTC‘s proposed regulations on auto retail provide neither transparency nor simplicity, and could leave older Americans with a more time-consuming and complex transaction to navigate.

The proposed regulations state that, once implemented, they will save consumers three hours in the shopping process. We were intrigued by this claim — but it happens that the Commission has provided no supporting evidence for it.

In fact, we believe that requiring extra disclosures — over and above the myriad disclosures already in place — would likely increase the sales process by half an hour or longer. Especially with seniors.

Long and drawn-out compliance procedures notoriously do not make things easier or clearer for consumers, especially seniors. Adding new facts and figures and information often confuse the products, confuse the transaction, and get customers focused on items that have nothing materially to do with their purchase. We saw this with the federal reserve regulations on mortgages, where adding extra information about fees actually resulted in consumers selecting expensive options, because they became fixated on fees and not overall costs.

Before passing a massive regulation on $1 trillion market, it is critical that the commission do more research and actually field test these proposals as though they were implemented. We ask that you operationalize these regulations at a dealership try them out, with seniors, to see if they save the time that you declare. We suspect that they will not.

When it comes to seniors and disclosures, what is most important is keeping things simple. Rather than
introducing new disclosures, the commission should try to condense existing disclosures into one easy to read form. Adding new disclosures will only make the process more complex and confusing

Only with a more methodical and transparent regulatory process should these regulations move forward.

Thank you for your consideration.

James Martin, Founder & Chairman

Saul Anuzis, President