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Matt Blatt Inc. and Glassboro Imports, LLC; Proposed Consent Order To Aid Public Comment

American Government Special Collections Reference Desk

American Government Topics:  Matt Blatt Inc., Glassboro Imports

Matt Blatt Inc. and Glassboro Imports, LLC; Proposed Consent Order To Aid Public Comment

Donald S. Clark
Federal Trade Commission
April 1, 2015


[Federal Register Volume 80, Number 62 (Wednesday, April 1, 2015)]
[Notices]
[Pages 17432-17434]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-07404]


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FEDERAL TRADE COMMISSION

[File No. 132 3285]


Matt Blatt Inc. and Glassboro Imports, LLC; Proposed Consent 
Order To Aid Public Comment

AGENCY: Federal Trade Commission.

ACTION: Proposed Consent Agreement.

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SUMMARY: The consent agreement in this matter settles alleged 
violations of federal law prohibiting unfair or deceptive acts or 
practices. The attached Analysis to Aid Public Comment describes both 
the allegations in the draft complaint and the terms of the consent 
order--embodied in the consent agreement--that would settle these 
allegations.

DATES: Comments must be received on or before April 27, 2015.

ADDRESSES: Interested parties may file a comment at http://ftcpublic.commentworks.com/ftc/mattblattconsent online or on paper, by 
following the instructions in the Request for Comment part of the 
SUPPLEMENTARY INFORMATION section below. Write ``Matt Blatt Inc. and 
Glassboro Imports, LLC Consent Agreement; File No. 1323285'' on your 
comment and file your comment online at http://ftcpublic.commentworks.com/ftc/mattblattconsent by following the 
instructions on the web-based form. If you prefer to file your comment 
on paper, write ``Matt Blatt Inc. and Glassboro Imports, LLC Consent 
Agreement; File No. 1323285'' on your comment and on the envelope, and 
mail your comment to the following address: Federal Trade Commission, 
Office of the Secretary, 600 Pennsylvania Avenue NW., Suite CC-5610 
(Annex D), Washington, DC 20580, or deliver your comment to the 
following address: Federal Trade Commission, Office of the Secretary, 
Constitution Center, 400 7th Street SW., 5th Floor, Suite 5610 (Annex 
D), Washington, DC 20024.

FOR FURTHER INFORMATION CONTACT: Daniel Dwyer, Bureau of Consumer 
Protection, (202) 326-2957, 600 Pennsylvania Avenue NW., Washington, DC 
20580.

SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal 
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34, 
notice is hereby given that the above-captioned consent agreement 
containing consent order to cease and desist, having been filed with 
and accepted, subject to final approval, by the Commission, has been 
placed on the public record for a period of thirty (30) days. The 
following Analysis to Aid Public Comment describes the terms of the 
consent agreement, and the allegations in the complaint. An electronic 
copy of the full text of the consent agreement package can be obtained 
from the FTC Home Page (for March 26, 2015), on the World Wide Web at: 
http://www.ftc.gov/os/actions.shtm.
    You can file a comment online or on paper. For the Commission to 
consider your comment, we must receive it on or before April 27, 2015. 
Write ``Matt Blatt Inc. and Glassboro Imports, LLC Consent Agreement; 
File No. 1323285'' on your comment. Your comment--including your name 
and your state--will be placed on the public record of this proceeding, 
including, to the extent practicable, on the public Commission Web 
site, at http://www.ftc.gov/os/publiccomments.shtm. As a matter of 
discretion, the Commission tries to remove individuals' home contact 
information from comments before placing them on the Commission Web 
site.
    Because your comment will be made public, you are solely 
responsible for making sure that your comment does not include any 
sensitive personal information, like anyone's Social Security number, 
date of birth, driver's license number or other state identification 
number or foreign country equivalent, passport number, financial 
account number, or credit or debit card

[[Page 17433]]

number. You are also solely responsible for making sure that your 
comment does not include any sensitive health information, like medical 
records or other individually identifiable health information. In 
addition, do not include any ``[t]rade secret or any commercial or 
financial information which . . . is privileged or confidential,'' as 
discussed in Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and FTC Rule 
4.10(a)(2), 16 CFR 4.10(a)(2). In particular, do not include 
competitively sensitive information such as costs, sales statistics, 
inventories, formulas, patterns, devices, manufacturing processes, or 
customer names.
    If you want the Commission to give your comment confidential 
treatment, you must file it in paper form, with a request for 
confidential treatment, and you have to follow the procedure explained 
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept 
confidential only if the FTC General Counsel, in his or her sole 
discretion, grants your request in accordance with the law and the 
public interest.
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    \1\ In particular, the written request for confidential 
treatment that accompanies the comment must include the factual and 
legal basis for the request, and must identify the specific portions 
of the comment to be withheld from the public record. See FTC Rule 
4.9(c), 16 CFR 4.9(c).
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    Postal mail addressed to the Commission is subject to delay due to 
heightened security screening. As a result, we encourage you to submit 
your comments online. To make sure that the Commission considers your 
online comment, you must file it at http://ftcpublic.commentworks.com/ftc/mattblattconsent by following the instructions on the web-based 
form. If this Notice appears at http://www.regulations.gov/#!home, you 
also may file a comment through that Web site.
    If you file your comment on paper, write ``Matt Blatt Inc. and 
Glassboro Imports, LLC Consent Agreement; File No. 1323285'' on your 
comment and on the envelope, and mail your comment to the following 
address: Federal Trade Commission, Office of the Secretary, 600 
Pennsylvania Avenue NW., Suite CC-5610 (Annex D), Washington, DC 20580, 
or deliver your comment to the following address: Federal Trade 
Commission, Office of the Secretary, Constitution Center, 400 7th 
Street SW., 5th Floor, Suite 5610 (Annex D), Washington, DC 20024. If 
possible, submit your paper comment to the Commission by courier or 
overnight service.
    Visit the Commission Web site at http://www.ftc.gov to read this 
Notice and the news release describing it. The FTC Act and other laws 
that the Commission administers permit the collection of public 
comments to consider and use in this proceeding as appropriate. The 
Commission will consider all timely and responsive public comments that 
it receives on or before April 27, 2015. You can find more information, 
including routine uses permitted by the Privacy Act, in the 
Commission's privacy policy, at http://www.ftc.gov/ftc/privacy.htm.

Analysis of Proposed Consent Order To Aid Public Comment

    The Federal Trade Commission (``FTC'') has accepted, subject to 
final approval, an agreement containing a consent order from Matt Blatt 
Inc., also known as Matt Blatt KIA and as Matt Blatt Egg Harbor 
Township (``Matt Blatt Inc.''), and from Glassboro Imports, LLC, also 
known as Matt Blatt Glassboro Suzuki, as Matt Blatt Glassboro, and as 
Matt Blatt Auto Sales (``Glassboro Imports''). The proposed consent 
order has been placed on the public record for thirty (30) days for 
receipt of comments by interested persons. Comments received during 
this period will become part of the public record. After thirty (30) 
days, the FTC will again review the agreement and the comments 
received, and will decide whether it should withdraw from the agreement 
and take appropriate action or make final the agreement's proposed 
order.
    The respondents are dealerships that offer an auto payment program 
to consumers financing a motor vehicle. The matter involves the 
dealerships' sale of the auto payment program to consumers. According 
to the FTC complaint, respondents have represented that consumers who 
enroll in its biweekly payment program in order to pay off their auto-
financing contract will save money or achieve other benefits through 
the program. However, respondents failed to disclose that consumers who 
enroll in the program are charged fees that in many cases offset any 
savings under the program, and also failed to disclose the total amount 
of these fees. These facts would be material to consumers in their 
decision to enroll in the biweekly payment program sold by respondents. 
The complaint alleges therefore that respondents' failure to disclose 
the above-mentioned facts is a deceptive practice in violation of 
Section 5 of the FTC Act.
    The proposed order is designed to prevent respondents from engaging 
in similar deceptive practices in the future. Section I prohibits 
respondents from representing that a payment program or add-on product 
or service will save consumers money, including interest, unless the 
amount of savings is greater than the total amount of fees associated 
with the product or service or any qualifying information is clearly 
and conspicuously disclosed. Section I also prohibits respondents from 
representing that a payment program or add-on product or service will 
save any consumer a specific amount of money, including interest, 
unless the specified amount is the amount of savings after deducting 
any fees or any qualifying information relating to savings is clearly 
and conspicuously disclosed.
    Section II of the proposed order prohibits respondents from making 
misrepresentations related to any payment programs, including regarding 
the existence, amount, timing, or manner of any fees, the program's 
benefits, performance, or efficacy.
    Section III of the proposed order prohibits respondents from making 
misrepresentations related to any add-on products or services, 
including regarding the total costs of the add-on and the benefits, 
performance, or efficacy of the add-on, any restrictions or conditions 
associated with the add-on, the nature or terms of any refund, 
cancellation, or exchange of an add-on, and that any add-on product can 
improve, repair or otherwise affect a consumer's credit.
    Section IV requires respondents to substantiate any representations 
about the benefits, performance or efficacy of any add-on product or 
service or any payment program.
    Section V of the proposed order requires respondents to pay to the 
Commission One Hundred Eighty Four Thousand Two Hundred Eighty dollars 
($184,280.00) in monetary relief.
    Section VI of the proposed order requires respondent to keep copies 
of relevant advertisements and materials substantiating claims made in 
the advertisements. Section VII requires that respondent provide copies 
of the order to certain of its personnel. Section VIII requires 
notification of the Commission regarding changes in corporate structure 
that might affect compliance obligations under the order. Section IX 
requires the respondent to file compliance reports with the Commission. 
Finally, Section X is a provision ``sunsetting'' the order after twenty 
(20) years, with certain exceptions.
    The purpose of this analysis is to aid public comment on the 
proposed order. It is not intended to constitute an official 
interpretation of the complaint or proposed order, or to modify in any 
way the proposed order's terms.


[[Page 17434]]


    By direction of the Commission.
Donald S. Clark
Secretary.
[FR Doc. 2015-07404 Filed 3-31-15; 8:45 am]
BILLING CODE 6750-01-P



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