The deadline for motor vehicle dealer compliance with the Federal Trade Commission's revised Used Car Rule is rapidly approaching. The January 28, 2018 compliance date imposed by the FTC requires dealers, as of that date, to use the agency's revised window sticker, known as the "Buyers Guide," on all used vehicles offered for public sale.
In November 2016, the FTC announced its final amendments to the Used Car Rule, and specifically revised the federally-required form of the Buyers Guide that must be displayed on a used motor vehicle offered for sale to the public.
As we covered here, the FTC issued additional guidance on the Used Car Rule in September 2017, in response to a number of questions raised by dealers regarding compliance. The guidance was in the form of frequently asked questions (FAQs) and addressed topics such as: whether and what type of changes can be made to the language; the format and font of the Buyers Guide; disclosure requirements regarding manufacturer and third-party warranties; and guidance for completing the "systems covered" portion of the revised Buyers Guide.
The amendments to the Rule included a grace period that permitted dealers to use their remaining stock of Buyers Guides for up to one year after the January 28, 2017 effective date. Time is running short, however, and all used vehicles must display the new Buyers Guide by January 28, 2018.
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