RVDA Regulatory Alert: RV Dealers Exempt from FTC’s CARS Rule

RV, boat, and powersports dealers are exempt from the just-announced Federal Trade Commission (FTC) Combating Auto Retail Scams (CARS) rule which places new regulations on automobile dealers during the sales process.  RVs were included in the original proposed rule. The rule targets so-called “junk fees” for add-on products and services that the FTC says some auto dealers do not properly disclose during a sale.

RVDA filed comments with the FTC saying the rule would negatively impact RV consumers due to the need for additional equipment sold by RV dealers, such as battery options, towing systems and leveling devices, that can be essential for the use and safe operation of the RV.

The rule states that “Covered Motor Vehicle” or “Vehicle” means any self-propelled vehicle designed for transporting persons or property on a public street, highway, or road. For purposes of this part, the term Covered Motor Vehicle does not include the following:

  • Motor homes, recreational vehicle trailers, and slide-in campers;
  • Motorcycles, scooters, and electric bicycles;
  • Recreational boats and marine equipment; or
  • Golf carts.

The FTC did comment that the agency would “continue to monitor [RV, boat, and motorcycle dealers] for unfair and deceptive practices to determine whether further action is warranted to protect consumers, through law enforcement, a future rulemaking, or other measures. The Commission notes that no dealer may misrepresent material terms; deceive customers about prices, add-ons, or payments; charge for products that provide no benefit; or charge consumers without express, informed consent. To the extent that dealers engage in such conduct, they are in violation of the FTC Act.”

For more information contact RVDA Director of Legal & Regulatory Affairs Brett Richardson at brichardson@rvda.org.