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
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