NADA: Urgent Need to File Grassroots Comments with the FTC

In a joint letter to the national dealer body, NADA Chairman Mike Alford, President & CEO Mike Stanton and ATAE Chair Greg Remensperger penned the following call to action for the nation’s dealers.  It has been reprinted in its entirety below due the tremendous importance and timely manner for comments to be filed.


As we all know, the FTC has denied NADA’s request for an extension of the public comment period for the proposed UDAP rules. Determined industry opponents, seeking to demonize all dealers, are aggressively working to flood the zone with adverse comments about dealers. We need your help to balance the public record at the FTC.

The FTC’s comment deadline is September 12, 2022, and we are seeking comments from dealership employees and customers. The comments can be digital or handwritten.

Dealer employee comments. We urge dealers to launch a letter writing campaign for your employees ASAP. Attachment 1A shows how to file digital or written comments. The goal is to document the dealership’s commitment to customer satisfaction and warn the FTC that the new rules will confuse customers and lengthen the sales process. Attachment 1B provides key messages for impactful letters.

Customer Letters. You see satisfied customers in your service lanes and showrooms every day. Those very same satisfied customers, if asked at dealerships, could weigh in with the FTC and provide a more balanced public record. Attachment 2A will help your employees raise the idea of sending comments to the FTC with customers. Attachment 2B provides some examples of customer letters.

GOALS: We are asking the NADA Board Members to: 1) ask every employee to file comments; and 2) obtain 100 customer comments from each rooftop. Also, please designate someone at your dealership to keep a scorecard of your progress. We know this can be done. Mike Alford’s team identified 40 to 50 customers in a couple of days,

We’ve asked our ATAEs to make two other aspects of our comprehensive response plan a priority: submitting association comments to the FTC and helping to identify dealers to participate in the CAR study. (If you have questions about those projects or need additional information, please let us know.) Any ATAE that would like to work with their dealers on the letter-writing campaign need just let us know and we will follow up with you directly; several associations are already launching campaigns.

The FTC has proposed a rule that if finalized without changes, would drastically alter the way franchised dealers advertise, sell, and finance every new or used vehicle, and would impose exceedingly burdensome record-keeping requirements. As a result, our customers would spend more time to buy a car, not less as asserted in the FTC’s proposed rule.

We of course agree with the concept of protecting consumers, and we are generally supportive of common-sense improvements. However, these new FTC regulations would undermine our efforts to improve the customer experience, provide more of the purchase process online and continue to increase transparency.

We need your immediate help to show the FTC what we already know – the retail automotive market is efficient, transparent, evolving and not systemically flawed. We are meeting the individual needs of the overwhelming majority of our customers.

Mike Alford, NADA Chair
Mike Stanton, NADA, President and CEO
Greg Remensperger, ATAE Chair

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