Add-On Product Consumer Benefit
- Ensure all products proposed or delivered have a direct consumer benefit
- Prohibit dealers from charging junk fees for fraudulent add-on products and services with no consumer benefit (including “nitrogen-filled” tires that contain no more nitrogen than normal air)
Questions to Submit to the FTC
- Ask for clarification of what “add-on” means – in detail. Does ‘add-on’ include hard-adds or are hard-adds part of the TRUE vehicle cost, since the expense was incurred and is physically associated with the vehicle? Provide examples of how a hard-cost add-on impacts the COST of a vehicle.
- The FTC cites GAP specifically – is this an ‘add-on’ or an insurance solution? According to a 2020 NADA-University of Michigan study, 90% of GAP policyholders believe it is a ‘good idea’ and would buy it again.
- If a consumer does not want a hard-add, will a dealer be expected to reduce the cost of the vehicle selling price to align with a consumer’s desire, even if it is disclosed on an addendum?