Advocacy Submits Comments on the Federal Trade Commission’s Motor Vehicles Proposed Rule
The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits this
letter in response to the Federal Trade Commission’s (FTC) notice of proposed rulemaking
(NPRM) on Motor Vehicle Dealers Trade Regulation. The Office of Advocacy (Advocacy) is
concerned about the potential economic impact of the proposed rule on small entities. Advocacy
encourages the FTC perform an initial regulatory flexibility analysis to provide information
about the economic impact of the proposed rule and to implement less costly alternatives.
On August 22, 2022, the Office of Advocacy submitted a request for extension of the comment
period for this rulemaking. As noted in the letter, the proposed rule contained 49 questions that
required extensive research by the industry. The small entities that will be required to comply
with the regulation are in the best position to provide the FTC with information about the
potential costs associated with the proposal, but the amount of time provided for the comments is
insufficient. This information is crucial for determining the economic impact of the rule and for
considering less costly alternatives as required by the Regulatory Flexibility Act (RFA).
Advocacy reiterates the need for an extension of the comment period for this rulemaking and
reserves the right to submit supplemental comments.