October 24, 2011 — Comments

The consumer groups confines our comments to six topics:

  • § 700.3(c) FTC should clarify that the Act applies to consumer leases
  • § 700.10(b) Certain 50/50 warranties should be interpreted as violating the Act’s anti-tying provision
  • § 700.11(a) FTC interpretation of Act’s application to insurance contracts conflicts with a federal statute and Supreme Court precedent
  • § 700.11(c) FTC should clarify meaning of “entering into” a service contract
  • Part 701 FTC should issue a rule on service contract disclosures
  • § 703.5(j) FTC should retain its prohibition of mandatory arbitration of written warranty disputes