FTC Staff Comment to the Hon. J.B. Banks Concerning Missouri S.B. 568 on Auto Sales and Brokering

~~.... ,t37
IS IMI Mo<VVII a-
Choavo. --eoeo:J
~'Ill~l"
UN1Tt:J) ~'TATES I)~ ,\~II~RIC.\
FF;nF.~:\r. TR~\l'E \.~()MMISS1()N
~1II(;.\('j() RH(illl~.\I. OFFll't::
April 	6, 	1990
V900025
COMMISSION AUTHORIZED
i
The Honorable J.B. 	Banks
Missouri 	Senate
suite 	319
state 	Capitol 	Building
Jefferson 	city, 	XO 	65101
Dear Senator 	Bank.,
The statt 	ot 	the 	Federal 	Trade 	Commission'. 	Chioaqo Regional
office 	and 	Bureau ot 	Competition- are 	pleased to have 	this
opportunity 	to 	respond 	to 	your 	request 	for 	comments 	regarding
Senate 	Bill 	568 	(USB 	568").' 	The 	bill 	would 	limit 	the 	abilityot
~ar dealers 	to 	hold 	sales 	away 	from 	their 	registered 	premises 	and
would prohibit brokers 	from 	arranqinq new oar 	sales. 2 We 	believa
that SS 568 	would 	likely 	reduce 	competition by 	limitinq
innovative 	automobile marketlnq me~hods and 	deprive 	consumers ot
the 	eavinga 	that 	they 	could 	realize 	through 	such marketing
methods.
ZNT2RBS~ AND BXPERIENCB OP 	THB STArr O. THE 7BDERAL TRADB
COHKXSSZOH
Our 	interest 	in this 	legislation .tems 	from 	the 	Commission's
mandate 	to 	entorce 	the consumer protection and 	antitrust 	laws 	ot
the United Stat.s. 	The 	Federal 	Trade 	Commission 	i. 	charqed with
promoting 	competition and protecting 	consum.rs 	from untair
m.thods 	of competition and unfair 	or deceptive 	acts 	or
practices. 3 In 	fUltillinq 	this mandat., 	the 	staff 	of 	the 	F.d.ral
Trade 	Commission otten 	SUbmits comments, 	upon 	request, 	to
federal, 	state, 	and 	local 	governm.ntal 	bodies 	to 	help 	assess 	the
implications 	for 	competition an~ consumers 	of 	pending policy
issues. 	In 	entorcing the 	Federal 	Trade 	Commission Act, 	the
1 	These comments are the views of the .~aff of the Chicago
Regional 	Otfioe 	and 	Bureau 	of 	Compet.ition 	of 	the 	Federal 	Trade
Commission. 	They are 	no~ necessarily the views 	ot 	the 	Commission
or 	any 	individual 	Commissioner.
I 	SS 	568 would also 	add three 	seotions defining 	classic
car, 	historic 	car, 	and 	recreational 	vehicle dealers. 	We express
no comment 	on thes. 	d.tinitional 	seotions.
§SA 15 U.S.c. 	I 	41 	It 	••g.

..
The Honorable J.B. 	Banks 	-- 	Page 	2
Commission has 	gained 	substantial 	experience 	in analyzing 	the
impact 	ot 	both 	private 	and governmental 	restraints 	on
competition.
! 	During 	recent years, 	the 	Commission ha. 	b•• n 	involved 	in
issues 	relating 	to 	restrictions 	that might 	tend 	to 	limi~
alternative 	types 	of 	retailing 	that 	can be beneficial 	to
consumers. 	The 	Commission has 	addressed 	the 	competitive
implications 	of time 	and 	place 	restrictions 	in various 	retail
markets. 	-For example, 	the 	Commission has 	promulgated a 	Trade
Regulation Rule 	on Ophthalmic Service~ to 	eliminate 	restraints 	on
the 	commercial 	practice 	of 	optometry."
The 	commission has 	also 	addressed 	restrictions 	occurring 	in
tho 	auto 	induBtry. 	For 	example, 	the 	Commission 	ruled 	that
automobilo dealers 	in 	the 	Detroit area 	violated 	the 	antitrust
laws 	by 	agreeing 	to 	limit 	their hours 	of 	operation.$ 	In
addition, 	the 	Commission 	staff 	has 	conducted 	and p~blished
economio researoh 	concerning 	automobile 	marketing.
The 	Commission staff 	has 	recently 	SUbmitted comments 	to 	a
nUmber 	of 	state 	governmental 	bodies 	nationwide 	concerning various
proposals 	to 	restrict 	certain 	types 	of competition amonq
automobile 	marketers. 	The 	staff 	commented on California
legislation 	that 	would have 	limited 	car 	sales 	at 	temporary
~ Trade Regulation Rule 	on Ophthalmic 	Practice, 	54
Fed. 	Req. 	10,285 	(March 	13, 	1989), 	appeal 	filed, 	California state
Board ot 	optometry v. 	FTC, 	1989-2 	Trade 	Cas. 	CCCH) 	! 	68,738 	(D.C.
Cir. 	1989) 	(effective date 	of 	rule 	.tayed, 	filed August 	15,
1989). 	The 	rule bans 	certain 	restrictions 	on 	the practice 	of
optometry 	such 	as 	limitations 	on ••tablishln9 	branch 	offices,
prohibitions 	on 	lay 	associations, 	prohibitions 	on 	commercial
locations 	and bans 	on trade 	name••
S 	Detroit Auto 	Dealers Ass'n, 	Inc., 	FTC Docket 	9189
(February 	22, 	1989), 	app,a! 	filed, 	AYe ngm. 	Barnette 	Pontiac
Datsun, 	Inc. 	v. 	FTC, 	Nos. 	89-3389, 	3390, 	3391, 	3392 	(6th 	eire
tiled Hay 	8, 	1989). 	(The 	Commission decided that 	an 	agreement by
area 	dealerships 	limiting hours 	of 	operation unreasonably
re8tri~ed competition.)
• 	~ Robert 	P. 	Rogers, 	The 	Effect of stat. 	Kntry
Regulation 	on Retail 	Automobile Markets, 	Federal Trade
Commission, 	Bureau ot 	Economlca 	Staff Report 	(January 	1986).
(The Report 	concluded 	~at state 	laws 	restricting 	the 	nu~er of
Automobile 	dealers 	in 	a 	9iven area were 	costly to 	consumers.)

'0
The Honorable J.B. 	Banks 	-- 	Page 	3
locations7 and 	on 	proposed Wisconsin 	regulations 	that would 	have
limited 	off-site 	automobile 	sales 	and affected dealer 	licensing.'
The 	Commission 	staff 	submitted comments 	on an 	Illinois 	bill 	that
would have 	strengthened market 	area 	restrictions 	on 	franchised
Automobile dealerships 	and 	that would have 	extended those
reatri~tions to 	manufacturer-franchised 	auto 	service 	centers;' on
a 	bill 	that would have 	prohibited brokers 	from 	selling new and
used 	cars 	and that would have 	expanded 	Illinois's 	dealer
110ensinq provisions; 10 and 	on a 	bill 	that 	would 	have 	prohibited
Illinois 	car dealers 	from 	holdinq sales 	outside 	Of 	their 	local
markets. 11 The 	commission 	staff 	sub~itted comments 	on 	a 	Michigan
bill 	that 	would have prohibited brokers 	trom participatln~ in
automobile 	sala8. '2 	In 	addition, 	the 	commission 	staff 	has
subMitted 	comments 	on other ,tates' 	1eqislative 	initiatives
concerninq 	automobile 	sa1ea. '
7 	Letter 	from Jeffrey 	Xlurfeld, 	Direotor, 	San 	Francisco
Reqional 	Office, 	to 	tha Honorable 	Quentin 	L. 	Kopp, 	California
Senate 	(January $, 	1990).
• 	Letter 	trom c. 	Steven 	Baker, 	Director, 	Chicaqo Reqional
Oftice, 	to 	Thomas 	L. 	Gais, 	Oealer Section, 	Wisconsin 	Department
ot Transportation 	(November 	3, 	1989).
• 	Letter 	from 	c. 	Stevan 	Baker, 	Director, 	Chicaqo 	Reqional
Ottice, 	to 	the 	Honorable James R. 	Thompson, 	Governor ot 	Illinois
(September 8, 	19a~). 	Governor Thompson amendatorily vetoed the
provisions 	ot 	the 	leqialation relating 	to 	car dealerships 	and
automobile 	service 	centers.
Letter 	from 	c. 	steven 	Baker, 	Director, 	Chicaqo 	Reqional
Office, 	to 	the 	Honorable Aldo 	A. 	DeAngelis, 	Illinois 	senate
(March 	21, 	1989). 	Governor Thompson vetoed that 	leqislation.
11 	Latter 	trom John M. 	Paterson, 	Director, 	Chicago
Regional 	Office 	Trade 	Commission, 	to 	the 	Honorable Woods 	Bowman,
Illinois House 	of Repre.entatives 	(April 	24, 	1997).
12 	Letter 	trom Hark Kindt, 	Director, 	Cleveland Regional
Ottice, 	to 	the 	Honorable 	Dick Posthumus, 	Michigan Senate
(September 	29, 	1988).
" 	lis letter 	from 	Paul 	Davis, 	Director, 	Atlanta Reqional
ottiae, 	to 	the 	Honorable 	Gwen Margolis, 	Florida Senate 	(March 	29,
1988)' 	letter 	trom Paul 	Davis, 	Director, 	Atlanta Reqional 	Office,
to 	the 	Honorable David C. 	Waldrop, 	Jr., 	South 	Carolina House 	of
Representative. 	(March 	21, 	1988); 	lettar 	from Marcy Tiffany,
Director, 	Los Angele. Reqional 	Office, 	to 	the 	Honorable Richard
Katz, 	California 	state Assembly 	(January 	29, 	1998); 	letter 	from
(continued ••• )

The 	Honorable J.B. 	Banks 	-- 	Page 	4
SUHKARY O~ THE 	PROPOSED 	LBGISLATION
sa 568 	would 	limi~ ~he ability 	of 	car dealer. 	~o hold 	car
sales away 	from 	a 	dealer'. 	licensed 	premises 	(known variously as
ott-premises 	aales, 	off-site 	sale. 	or ~.n~ sales). 	The 	bill
would prohibit a 	person 	from 	sellinq 	.even or more 	cara 	at any
place 	away 	from 	that person's 	bona 	fide 	established place 	ot
business 	unle •• 	a 	majori~y of 	the 	local 	dealers 	participate 	in
the 	aale.11, 	.
In 	addi~ion, sa 	568 	would define 	the 	term 	"broker" 	and
prohibit brokers 	from 	arranging 	new car 	sale •• 11 The 	term
"broker" 	ia defined expansively 	in 	the 	bill 	and, 	consequently, 	sa
S68 	may 	ban many 	automobile 	marketing 	techniques, 	such 	a. 	tho.e
discussed 	below, 	tha~ are 	permissible 	under current 	law.
AUTOHOBILB MARKETING METHODS
various 	techniques 	can b. 	us.d.~o assist 	consumer. 	in 	'~
finding 	licensed 	automobile dealers 	willing to 	•• 11 	a~ discounts.
One 	souroe 	is credit unions 	that sponsor 	automobile 	aalea
cond~cted through 	licen.ed dealers. 	The 	credit unions 	.ncouraqe
~h•• e 	sales 	~o promote 	opportunities 	~o provide 	automobile
finanoing. 	Sinoe 	cara 	are 	aold 	in 	volume, 	the credit unions 	may
'1 ( ••• oontinued)
Jim Hoseley, 	Direotor, 	Dalla8 Regional 	Office, 	to 	the 	Honorable
William 	P. 	Clements, 	Jr., 	Governor 	of Texas 	(June 	1, 	1987).
14 SB 568, 	IS 	A, 	301.SS9.6, 	301.566.
is 	sa 	568 	provide. 	an exception to 	the .ajori~y
participation require.ent 	tor salea 	of 	fewer 	than 	.even 	cars.
The 	scope 	ot this 	exoep~ion, however, 	is 	no~ entirely clear. 	We
do 	not 	know whether dealers 	are 	allowed to hold as 	many 	off-site
sales 	as 	they wish without 	the participation of a 	majori~y of
dealers 	80 	lonq a. 	the 	dealer ••lls 	tewer than ••ven cars 	or
whether a 	dealer 	is 	permitted to 	.ell 	• 	total 	of six cars at 	off-
.i~e aale. 	over a 	particular period ot time.
S8 	568 	a180 	expands 	the 	coverage 	of the 	current
r~quirement that a 	majori~y ot dealar. 	participate 	in the 	aale
from 	only sales held 	in a 	oity or town to 	include 	oft-.i~e sales
held 	in 	unincorporated areas.
SB 568, 	II 	A, 	301.550 	(3) 	(definition), 	301.!!9.5
(prohJbition).
se'd 	OCVV £S£ zu· U'77C'lQCI 	- 	~•• - 	_. ,

'I
The Honorable J.B. 	Banks 	-- 	Page 5
be 	able 	to 	obtain sUbstantial 	savings 	for 	their membera.'7
credit union 	sponsored 	fleet 	sales may 	in 	some cases 	stimulate
business 	tor 	existing dealerships.'1
i 	Car 	rental 	companies, 	such as 	Hertz, 	Avis, 	and 	Enterprise
Leasing 	are 	a 	primary 	source ot automobiles 	for sale. 	conducted
on credit union premises. 	The 	fleet 	dealers 	seek to 	sell 	their
USG4 rental 	cars. 	Low overhead sales 	ottered 	in conjunction with
credit unions 	enable 	fleet 	dealers 	to 	turn 	over 	their 	inventories
efficiently.,e 	Marketin9 techniques 	such 	as 	fleet 	sales may 	1n
some 	oases 	provide cost 	savings 	and 	services 	tor consumers. 	For
example, 	consumers who 	purchase used 	cars 	at 	fleet 	sales may be
Able 	to 	obtain benetita 	that may 	not be 	available 	to 	other used
car 	purchasers. 	Cars purchased at 	fleet 	sale! generally carry a
12-month or 	12,000 mila 	power-train warranty. 	other used cars
may 	oarry 	shorter term warranties 	or none 	at 	all. 	Some 	fleet.
dealer8 	have 	national 	service 	networks 	throuqh which consumers
can have 	the 	purchased cars 	repaired. 	In 	addition, 	some 	fleet
dealers 	contract with 	local 	dealerships 	and 	automotive 	repair
tirm. 	to parform 	service under these warran~ie••
For example, 	in 1986, 	credit unions 	surveyed by the
Illinois 	Credit union 	League 	estimated 	that 	consumers paid an
averag_ 	ot 	$1,118 	less 	for 	a us.d 	car at 	a 	credit union sponsored
fleet 	sale 	than those 	consumers 	would 	havs paid to 	a
"conventional" 	used car dealer. 	The Michigan credit Union Leaque
asserts 	an estimated average 	aavinqa 	of 	$900 	per vehicle. 	Hertz
Corporation 	asserts 	an estimated savings 	of approximately 	$1,000
per car 	in 	1981.
Credit unions ••y 	offer special 	financin9 	terms 	and
~ates for 	• 	fleet 	aale. 	Credit unions may pre-approve .embers
for 	the 	financing 	terDS 	and 	typically keep 	these 	terms 	open 	for
thirty 	days 	atter a 	fleet 	sale. 	Consumers may 	be 	91ven the
option 	to 	purcha.e 	a 	car that was 	not available 	at the 	fleet 	sale
from 	a 	dealership 	under the 	sale's 	financinq 	terms. 	Consumers
who 	exerciee th••e 	options may proVide 	an 	additional 	source 	of
customer. 	for 	dealers.
11 	Thisproceaa may.a1so enabl- 	compani •• 	to 	charqe 	lower
prices 	to 	con.umers who 	rent cars,
~ 	We understand that Hertz 	Corporation, 	lor example,
provide. 	a 	30-day warranty 	on mechanical 	problems 	in 	addition 	to
the 	typical 	12 	month or 12,000 aile 	power-train warranty.

The 	Honorable J.B. 	Banks 	-- 	Page 	6
Other marketing 	techniques, 	such as 	automobile 	buying clubs
and 	referral 	services, 	may make 	new cars 	available 	to 	consumer.
at 	discount 	prices. 	These 	services generally charge 	an 	annual
membership 	fee 	and 	arrange 	new car purchases 	for 	me~er. at
guaranteed 	prices with pa~icipating dealers. 	An August 	1988
survey 	of 	six automobile 	buying services by 'bAnging 	Times
~a9azine ooncluded that 	customers purchasing 	cars 	through 	the.e
services would have 	realized 	substantial 	.avi~gQ on 	aach
purchase, 	no matter which 	servioe was 	picked.
According 	to the Missouri 	Credit Union 	League, 	many Missouri
oredi~ unions 	participate 	in new car sales 	programs with Missouri
car dealers. 	Under these 	programs, 	participating dealers make
approximately 	50t 	of 	their 	stock available 	to 	or edit union
members 	at 	tixed 	discounted prices. 	To 	heighten 	interest 	in the
programs, 	the 	credit unions 	provide 	their members 	with pra-
approved 	financing 	at 	reduced 	rates. 	Members wishing to 	purchase
a 	new 	car 	can go to 	their credit union to 	see 	a 	list 	of 	prices
and model 	availability and then purchase 	a 	nel car 	from 	a
participating dealer at the 	diecount.ed price. 	~ .....~ .. _...
The 	credit union .ember. benetit by 	purchasing new cars at
discount 	prices, 	by reoeiving 	lower 	tinanoing 	rates 	than
otherwise may 	be 	available 	and by 	savinq .earch and 	neqotiation
costs. 	The 	credit unions 	benetit by 	receivinq 	financing
opportunities 	and may additionally gain mora members 	.s consumers
discover 	that theee purchase 	opportunities 	are 	availabla 	through
credit union.. 	Pina11y, 	the 	dealers 	receive 	a 	supply ot
customers 	for 	their 	naw cars.
SB 	568 would 	impose 	requirements 	that 	could reduce 	or
eliminate 	off-site 	automobile 	.ales. 	We 	understand 	that 	SB 568
is 	intended, 	in 	part, 	to 	strenqthen and 	clarity 	otf-8i~e
automobile 	salea 	restrictions 	enaoted by House 	Bill 	1512 	during
~ 	Taking the Hassle gut 	ot 	Car-Buying, 	Chanqinq Tim.s,
AUgust 	1988, 	at 	37.
D 	Aooording to ~. Missouri 	Credit Union League, 	these
ea1& 	prices 	are 	available 	to 	credit union members 	for 	two 	to
three 	day. 	and are usually held on a 	Thursday and 	Friday 	or 	trom
Thuraday 	throu~h la~urday.
~. d 	8O'P ~ ZU: l£ZZ099 	**** 	rn-n TU"'\ ... I J

. '.
The Honorable J.B. 	Banks 	-- 	Page 	7
the 	last 	legislative 	session.a We 	also understand 	that 	Hertz,
Avis 	and Enterprise 	Leasing have 	obtained 	injunctions 	aqainst
entorcement at 	the 	current 	oft-site sales 	restrictions. 	We 	are
not 	familiar with the 	merits, 	or the 	precise 	status, 	of 	this
litigation 	and 	its 	present effect on 	ott-site 	sal... 	We
therefore 	focus 	our comment. 	on 	the 	restrictions 	on automobile
marketing methods 	proposed by SB 568.
The 	amendments 	in SB 568 	would 	require 	that 	the Missouri
Commission 	ot Motor Vehicles 	be given ten days 	advance 	notice ot
an ott-site 	8ale 	involving 	seven or more vehicles. 	The 	bill
requires 	that 	this 	notice 	include 	the 	location, 	date, 	duration
and class 	at dealers participating and 	also 	the 	names 	ot 	all
motor vehiole dealer. 	in that 	class that 	operate 	in the 	city,
town 	or unincorporated 	area. 24 The 	sale ~ay not be held unless
the 	Commission of Motor Vehicles 	gives 	its 	approval 	in writinq.
Although we 	focus 	on the 	restrictions 	as 	they pertain to
automobiles, 	the 	bill 	would 	also place these 	restrictions 	on 	ott-
premises 	sales 	or 	shows 	involving 	other vehic~es, such.as
..... ," ...- ..:-" motorcycles, 	recreational 	vehicle. 	and boats. 	.('" 	... 	. ...~. 	'S
~ 	Mo. 	Rev. 	Stat. 	S 301.566 	(supp. 	1989) 	("Motor vehiole
aales 	or 	shows 	held away 	from 	licensed place ot business, 	allowed
when.") 	provide. a
A motor Vehicle dealer may participate 	ilhany motor vehicle
show or sale, 	and conduct 	sales 	at motor vehicl.s 	thereat,
away 	from 	bis 	usual, 	registered 	place 	ot business 	it 	the
event 	is 	Qonducted for 	not more 	than 	ten days, 	and 	if 	a
majority of 	the motor vehiele 	dealers 	within 	a 	cla •• 	of
cQalers described pursuant 	to 	subsection 	3 	at 	section
301.550 	in a 	city 	or town 	participate 	in the 	event. 	The
commission shall 	consider 	such events 	~o be proper 	in all
respects 	and .s 	it 	each dealer participant was 	conductinq
busines8 	at bis 	usual 	businesa 	location.
(added by House 8ill 	1812, 	I 	9 	(1988), 	etfective January 	1,
1989).
Hissouri' ••tatutory scheme divides 	dealera 	into
classas, 	including 	franchised 	new car, 	used 	car, 	and motorcycle
dealers. 	Ho. 	Rev. 	B~at. 	J 	301.550.3 	(Supp. 	1989).
• 	The legislative 	summary ot S9 568, 	prepared 	for 	the
bill'. 	sponsor, 	indicates 	that 	the 	intent 	is 	to 	cover boat
dealers 	(attached). 	Boat dealers 	need not be 	licensed as motor
Vehicle dealers under the 	bill. 	Ho. 	Rev. 	stat. 	J 	301.550.3 	(as
it would be 	amended by 	5B 	568, 	I 	A). 	We 	are 	therefore 	unable to
determine whether the 	literal 	terms 	of SB 568 	would necessarily
require 	this 	result.

.........
The Honorable J.B. 	Banks 	-- 	Page 8
For a 	dealer to 	conduct or participate 	in a 	.how or 	aal.
away 	trom a 	dealer'. 	regular place 	ot business, 	the 	bill 	require.
that 	a 	majority of 	~e dealers 	ot the 	relevant class 	of vehicles
located 	in 	the 	city, 	town, 	or 	unincorporated 	area 	"where 	such
dealer 	is 	located participate 	in 	the 	event." 	Al~hoU9h the
phraee, 	"where 	such dealer 	is 	located," 	would seem to mean the
usual 	registered place 	ot business 	of 	the 	dealer 	intending 	to
participate 	in an off-aite 	aale, 	we 	assume 	~at the 	requirement
i. 	intended to 	refer to 	the 	place where 	the 	8a1e 	is 	to 	be held
and to 	require thAt a 	majority ot 	the 	dealer. 	near the 	sale'.
aite 	parti~ipat••
We 	read 	the 	requirement 	that 	a 	majority of dealers 	in 	the
prescribed 	location 	"partioipate" 	in the 	sale 	as 	callinq 	for
aotual 	participation 	and 	not merely the 	opportunity 	to
participate. 	Potential 	sponsors 	of 	ott-site aale. 	could be
deterred 	trom offering 	these 	kinds 	of 	sales 	even 	it 	the 	bill 	only
required 	that 	a 	majority 	of 	local 	dealers 	be qiven 	an opportunity
to 	pa~icipate. 	This 	deterrent effect, 	however, 	is .aqnified
....,.. ,when actual 	participation 	1s 	required .·because the .~equirement .y.~~.\,~.;'
would prevent 	an oft-aite 	sale 	fro~ being held even 	it 	a 	majority 	.
of 	the 	relevant dealera 	do 	not 	object but 	aimply choo •• not to
t~k. p~re in 	a 	proposed sale.
• 	The Missouri 	Senate We.kly 	Bill 	Statu. Report 	aummary
that was 	prepared 	for 	the 	bill'. 	sponsor apparently 	interprets
the 	majority participation requirement 	aa 	referring 	to 	the
looation 	of 	the 	.al ••
Th. 	alternative 	interpretation, 	~., 	that 	the 	bill
reters 	to 	the 	looation ot 	the dealer wishing 	to 	participat. 	in an
off-site 	sale, 	could iroduce 	anomalous 	r •• ult.. 	Under this
interpretation, 	the b 	11 would 	require 	that a 	majority of 	the
dealers 	in Moberly participate before a 	Moberly dealer could hold
a 	aale 	in Harshall. 	On 	the 	other hand, 	if 	a 	oity, 	town 	or
unincorporated area 	had 	only one dealer, 	that dealer could
apparently hold an oft-site 	.ale virtually anywhere 	so 	lon; a.
the 	Commission of Kotor Vehicle. 	has 	received the 	required 	ten
day 	notice. 	EVen 	it the 	requirement ~ere ~o be 	interpreted to
reter to 	the 	location of 	a 	participating dealer, 	the 	likely
anticompetitive etfects diacus.ed 	in 	our comment. would 	ramain
aubstantially the .am••
60 •d 	8D'V £S£ Zlr l£ZZ099 	**** 	rn-n TLr"l "" J 	.-. -

.. 	., 	...
The Honorable J.B. 	Banks 	Page 9
The 	likely ett.c~ of 	~h. oontemplated restriotions 	would b.
to 	eliminate many Qar sales 	events 	at 	sites 	other than 	car
dealership. 	even though 	.u~h aales 	may 	enhance 	the 	efficiency ot
distribution and 	result 	in savings 	tha~ may be 	passed 	alonq to
consumere. V The transaction oost. 	associated with obtaining
majority 	participation may deter dealers 	trom holding ott-ait.
eale. 	or 	from even attempting to do 	80.
The requirements 	ot the Missouri 	Comm18.ion of Motor
Vahieles 	laws, 	at 	least 	as 	this 	bill would amend them, 	would 	••em
to 	impoGe 	almost 	insuperable 	obstacl.. 	to 	orqanizinq these 	cal.
events 	in 	larger 	~owns and 	cities. 	Ae 	the 	number of dealers 	in
an 	area 	inoreases, 	the 	difficulties 	assooiated with 	••curin~
participation by a 	majority of dealers 	are 	also 	likely to
increase. 	For exa~ple, obtaining 	the participation 	ot 	a 	majority
of 	the 	dealers 	in 	Kansas 	city or st. 	Louia 	in 	a 	large public 	sale
would seem 	impractical. 	Moreover, 	even 	it 	a 	majority wished to
participate, 	it might well 	be 	difficul~ or 	!mpossible 	to 	find 	a
faoility 	adequate 	to 	support the 	avant. 	The.e difficult1•• 	could
. eliminate many 	car and boat 	ahows 	that .ight .otherwise be held.
The 	proposed 	restrictions 	on off-pr8~1.es sal.. mi9ht al.o
reduoe 	automobile 	.ales 	competition 	in some 	looale.. 	Off-
premises 	sal.. 	oonducted by dealers 	from 	other markets may 	in
eome 	emaIl 	oommunities provide the 	only effective competition to
local 	dealers. 	Althou9h 	the 	established dealer. 	in a 	particular
mark.t might 	not be 	able 	to prevent the 	en~ry ot 	a 	new
competitor, 	tho.e 	dealers 	might have 	incentives 	to hamper the
ealea 	efforta 	of occa.ional 	competing dealers, 	.uch as 	fleet
owners. 	SB 	568'. majority participation 	requirement would
provide 	a 	mechanism through which established dealer. 	in 	a 	qiven
region could 	frustrate 	att.~pts by outside 	competinq dealers to
hold 	ott-site 	aales.
. 	~ 	For example, 	a 	tleet de.ler suoh .a 	a 	car ren~al
company may 	need to bold such 	aal •• 	to 	turn 	over inventory. 	A
traditional 	dealar .ay wish to hold 	an 	o~~-pr.mis.a aale 	to
reduoe 	inventory ot overstocked cars. 	An 	ott-premises 	sale may
aleo be 	desirable 	if customera 	are .upplied to the 	aeller -- such
as 	oredit union members 	at a 	credit union-sponsored 	aale. 	Off-
premises 	salea 	provide 	a 	low-overhead ••chani.m 	tor brinqinq
.ellers 	and cuetomera 	together and the 	reduced overhead 	coats 	can
re.ult 	in aavings 	tor consumers.

The HonorableJ.B. 	Banks 	-- 	Page 	10
lJROKIBI'l'IOH OJ' AUTOIIOSXLJI "BROUU"
sa 	568 	may also prohibit credit unions, 	buying clubs, 	and
other organizations 	from 	sponsoring 	new 	car .ale. to 	their
members. 	The billie 	detini~ion of 	"broker" 	i. 	expan.ive 	and
would 	likely encompass 	many ot ~e car 	sales 	activities 	1n which
th•• e 	organiza~ions now engage. 	In etteot, 	the 	brokar
provisions would 	limit ~e sale 	of 	new cars 	to dealers, 	new car
a~ctions, and actual 	owners 	ot new cars 	and 	thereby 	inhibit
competition 	in new car 	sales. 	For example, 	some new car dealers
may enter 	into 	agreements with buying clubs 	to 	sell 	car. 	to 	a
club's 	members 	at 	reduced 	price.. 	In 	return, 	each pa~icipatinq
dealer 	receives 	a 	ready supply of customers 	and 	i. 	able 	to
increaae his 	sales volume. 	Onder SB 568, 	these 	arrangements may
be 	eliminated because 	the 	organization may be 	Illegally acting as
a 	broker 	it 	it 	receives 	"valuable consideration" 	for 	its 	role 	in
these 	agreements. 	Thus, 	credit unions 	that 	receive 	tinancing
opportunities 	and buying clubs that 	receive membership 	fees 	may
be prohibited 	from 	arranging 	theae 	car purchase opportunities by
the brokering provisions 	of sa 	568. 	' Consequently, 	the brokering
restrictions 	could reduce 	the 	availability of 	service. 	tha~ may
save Missouri 	consumers 	substantial 	auma 	in their 	new car
purcha.es.
CONCLV8IO.
SB 568 	may reduce 	compe~i~ion amonq car seller. 	and 	raiae
the prices 	that Kissouri 	consumers pay 	tor 	new and used cars.
The 	proposed 	restrictions 	on ott·site 	car 	sales would 	likely
. limit 	the number ot 8uch salas 	and therefore 	the 	availability of
cars. 	These 	restriotions 	could effectively 	insulate 	some 	local
dealers 	from 	a 	form 	of 	competition that, 	without the
a 	SB 568 	detine. 	a 	broker as 	"a person who, 	for 	a 	fee,
commission, 	or otber valuable con.ideration, 	arranges 	or offers
to 	arrange 	a 	transaction 	involVing the 	sale, 	for 	purposes 	other
than 	resale, 	ot a 	new .o~or vahicle, 	and who i. not:
<a)
(b)
(0)
(d)
A dealer or bona 	fida 	employe. of • 	dealer when
acting on behalf of a 	dealer;
A motor vehicle auction, 	a. 	detifted in subdivision
'(8) 	of 	this 	saction;
A distributor or bona 	fid- 	employee of 	•
distributor When acting 	on behalf of •
distribut.or, 	or
At any point 	in the 	tran.a~tion the bona 	fide
owner ot 	the vehicla 	involved in ~e transaction."
-. .. 	. 	..

The Honorable J.B. 	Banks 	-- 	Paqe 11
restriceions, 	could 	induce 	them 	to 	offer better 	service 	and 	lower
prioes. 	Likewise, 	ehe 	restrictions 	on new car brokering would
likely eliminate valuable 	sources 	tor new cars 	and discourage
innovaeiv. 8ales 	techniques 	that ~ay save Missouri 	cons~ers
.ubseantial 	amount. 	in eheir new car purchase••
We 	appreciate 	this 	oppo~unity to 	comm.n~•
• r.1Y'~
c. 	Steven Baker
Direci:or·
Chicago Reqional 	Offioe

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. 	'1IIS"'"....".,cl1Pn;mj\PI""PQ#bljiwa:cwrae Wt?PSM1ti'A gaiOz;; U·.fS4::#ie~ t I ii?:i$i3bf$i¥@¥!fiEbUSfttH	-. _.... 	.
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.
ichat!! ficin of Keno.
sha. Wi •. , and Rosemarie and Richard
<.:ubinsKi ot 'Valley ~tm1m, M.T., h3ve
discovered a fast. ec:onomkal way to buy
a new car tNlt beats schJepping around to
auto deillt!nhips and h.'lgglingwith aa.les- ,
~~.' 	!
Rein's 1988 Plymouth van Ind the 	:~
Cubinski's new Ford station wagon were
both purchasecllhrough Brooklyn, N.Y.-
based Car/Puter ~temational Corp.,
one of several discount Rrvices, for
more than $1,000 under the sticker
price.
Buying services like Car/Puler
make llmUlgements with dealen or bro-
kers to lell to their memben at a eliSa
routlt. which is usually a few hundred
doUars over what the car COlt the dealer.
SkilM!d haJU(lers mpy be able to beat the
pric:'e. Hut shoppUl¥ ror acar takell prodl·
cious effort, and an increasing number of
ncw~ar buyen would rather pay a
buyin~ servK.'1! I 11110111 mcmbcl'1hip f~
and eliminate the drudb'e WOl'k. And.
cause dealers art! skilled at Rettina the
upper h:md in llJ1y negotiations, aoing
throuih a service eosisret that JOU'U set
a ~runteed price-and have the added
dwt from the service to bock JOU up in •
I dispute.
But you have to be prepared to do a
1 	little work. You 3re usually provided with
q 	• pric;e &heel. given ace:ea. to • price
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Midallel Hdlf of K~no~ltll, Wis., 6"",J naon Ihllll $1,000 Dn lilt n.w .an-
lind n.",r /tlld 10 "~I:uliolt wllh II d.IJl.T.
**** nr-..n TU'" .... I ...J

guide or quoted In average price, but It , m! 5i!llVIC~ HAVE '. '. 	. 	'iica; lind $19,496 de~ler cost 31
still takes a little I:lVvy to ge~ th~ best 	WA'YS Cf ~NSURING': ..~. 	.$22.712 r~tail for the ~hrysler Ne
deal Before you ali!' 011, yo~ II want to '" '1'HAT DULlERS 51.CX TO :~.: .' Yorker. Prices h!C1ude ft'~lttht a~ well :
compare the c3t-buymg ~rvlc;eli in your. .. 	. 	". !Wch p6Pulu opt,lonS as automatiC ttiln
area for prices and service. And you'll. , TDiE PRICIS THEY. HAVE 	..... mission, .air-conditioninIV'a sterel
peed tn know the dealer CQst tOf the' GUARANIEIED. '.' 	.' 	cassette radio, power windows, pow,
models and options you Dre interested In. 	. ' 	door locks and. in the calle of the Chry
beCore you venture into any arrange- 	charges $11 per car, $20 Cor two, $27 £or . ler. leather seats, AdvertJslng fees Dl
ment to buy :l new car-and that m~ns 	three and. $7 for each additional pr;ntouL' other dealer charges were not includl
doing tome homework btlo" you Ip- 	. 	, 	In our figures... 	. 	.: 	..
proach a service. . 	. 	IlAnNO THI SIRVICU 	l'he ranb'C of services ~ir{ers fro
Some car-buying services seU price 	Once y~ know the car you want Ind its 	company to company. (And within son
.heets for new cars. but thl! servlce:t:lre 	priCe, you're re<ldy for a buyinR s~rvice. 	scrv~-es, prices can vary rrom one outl
best at helping you ACtually purchase a 	To find out what you actually Il~t, C:lIUIlX' . to :moth~r). Each diUtrc.:d in the way
car. J( you're still tryins to pin down the' in, Timt! looked at six prominent 	h:mdled refurlllits to d~a)erships, The
right rnode~ you'U be better served by .aervice:s-the Anlcrican Automobil~ Ali- 	also ditccred in the way they bill yo
goin~ elsewhere (or prices. Edmund 	soci:Itiorl (AM), Amway: Car/Puter, 	M~t base the CQst of domestic can> l
Pubbcations In West Hempstead, N.Y., 	Nationwide Auto Brokers, United 	the dealer, or factory, Invoice amour
puts out severill editions each year that· 	Buying Services and USAA Ruylng 	which is what the manufacturer bills tl
list the dealer cost and suggested retail 	St!rvlces-that arrange discount pur- 	dealership COf th~ car and option:s, plu~
price lor domestic and foreiill ClltS and 	chases for the buyen of new CUI. 	3~ fee and freight. Some also tack •
tnJdcs. You should be able to find thern at 	We asked each to lhop three new 	dealer-prepilration charg~s and adverti
most newsstands Of bookstores for 	ca~ for us: I two-door hatchback Ford 	ing costs, which am run as high as $20
$3,95 apiece. N~tionwidc Auto Brokers· Escurt LX, A foor·door Chevrolet Cor- 	(Imported ClltS are usually discounte
olSouthfitdd, Mich. (800-521-n57 or. in 	,ica and a Cbrylllt!r New Yorker 1.<Indau 	from the retaiL or sticker, price.) Sotl
Michiglln, 3130559-6661). wlllllf!l\d you 	sedan. For comparison, we did sume fiJ(- 	oCfered v~ry little price infurmatiuu b
the dealer cost and retail prices for any 	ur1n1C on our own and cnme up with 	forehand but would revit!w the cost b
car you choose at $9.95 each. Consunler 	$8,170 Cor tbe dealer co~t and $9,130 	fore a member placed an order. All )1<1
Reports Auto Price Service (P.O. Box 	&Uggested rctl\~ for the E=scort; $11,797 	methods for ensuring that dealers sti
57U, Lathrup Village, MiI;h. 4g076) 	and $13,325, respectively, for tbt: Cut- 	to the KU:lrant~d pcic;es. And they
'.'
'fMMM'W'e;IIPB!'''c' 'seew.'W' ¥'
CAR· BUYING SERViCeS
.'
a 	Wi.;--•• ~£.w&iSMi"•. MfWiUUSMMiC
r~~--------~------~-----_·
•Ukc 	y Ion"re,m bone1lund, yl.ld and $hOnl p,lu wllJ f/uctutJtI, COrll.Kl ~Ul.ldcr FWld Oisulbuton.lnc., Underwriter for a pro
_ ....., .. It... MnIP n.,~.c lnfotmatkm incllMl'". man:ttemc:nt fees and cxpcnx•. Rc.Id il can:fully bcfun: 10'1 Uwcst or K11cl mane'
8£vv £S£ ~l£ l£ZG099 	**** 	ro:oHO ~B 	CHO 	E2:60 	066t~t~ 	...
800.22,5-247
ai.513
-- - - -- - -.- - --
SCUDDER
r!i'Veal PbIe NIh me I r-lobitwtioD1dL
o tmabo ~In thiI Fuad for..., IRA.
I Scudder GNMA Fund 	.. 	I
'II
Call8OJ.2.25-2470 ext. 5130 or write today to find out more about
the high cunent yields and high quality of the Scudder GNMA
Fund. We'll msh you 0 free inIonnation kit with everything
you'll need to invest.•
"Yield. 	That used to be all I 	cared about in QI]
investment. But now I know how.irilp·ortant
quality is, 	too. 	So I moved mymoney
into the Scudder GNMA Fund."
.Sl'd

- 	.. 	• 	... ----:----.. • 	4' .. 	•••• 	. 	••
".
WlE ~S~[E!) liAC}J IDU~DHG
.SiE::iVaC2 va 1P!IUC~ .
1~l!l~iE CAD15, AND YOU
WCUlILD MLI\Vm SJl,\VIED,.·
MO:MtiV A,7 IEAC~ C~!.
them! tu b~t:k you" up i( you =should Imve
any troublc getting eX:lcUy the c:lr you
want from a dealer who, lor example,
wants you to;add undercoatitig or Cabric
protection -neither or which you need. ,"
And we would ~...e realized lubst:mti::al
pvings, on each purchase no matter
which service wc picked.
~ERlcAN AUTOMODILI ASSOCIATION,
Anumber of AAA n{(iliates have aet up
buyini-service plans (or ~mbcrs. AAA
Peninsula Motor Club In Tampa. which
!lerve-.s Florida's west coost and panhan·
dle, :staned Its own semce bst faUIn ~
sponge to members' pleas (or help with
new-ar ptlrc~s. TIle unit developed
II am\puh!t prugrnm nod contructll anl!
•il~'t\ed up mure than 160 lOcal show.
rooms. Since November, it has lold
more thon 1,350 vehicles, lome to
N'MW birdll"- ~si~-month residents from
tiu: NurLh,
hAl\. I'enin$ula runa a toll-free
nuMber (80<hlZl-8282 in Flolida), which
ill Itaffed leven days a week, Ilt least
eight hours a day (five hours on Sunday).
A phone caUgcts you ardelTAI to one or
the dealerships. 1u\A Peninsula doesn't
quote priccs but will give you the aver·
age Sllving fOf the C:lr yo~ are seeking
with ~tandnrd equipment to Wloe II! a
benchmark. The saving un our Ford Ea-
COft LX 'YiIS $920 otf the e~cted retail
price; on the Chevro~t COr5ic:n. $920:
and on the Chrysler New Yorker.
$2.300, Penin-'\ula AAA follows up e:Jch
purchase and intervene' if there arc
prublcrM. 	•
In Qllother typic:JI Ynrmtion, the Po-
torrulc chapttt pC AAA in the Washine-
too, D. c., area offers a referral progtllm,
Members Are aent a buying-lK:1'Yicc
"certificate" that dirl.'Ct:lthem to Q con·
tact lit II pnrticip;lting dealership. AM
Potomac l'equire~ thGt it~ deoJer~ also be
certified by AAA to provide service. An
AAA chapter in Houston foDows I G1rn1lllr
plan (or rclerrals.
nu~ AAA's national headquarter.
doesn't keep track of which chapter:; of·
fer buyinJ: :lcrvkes, but )'Our Iocnl AM
CDn prubtlbly tell you ita lervico Us &\'ail-
able onywhere in your Drea. AM mem'
~rlhip feel, which nnillS from $17 to
$50, may COVCt the usc o( a buying ser-
vice, as they do in the Houston, Penin·
lua and PotOln4C club:s. Some clubll with
1N}·in.: services will accommodate mem-
bers !rom other AAA affiliates.
AMWAY AUTO NITWORK.(7S7S E, Fulton
Rd., Ada, Mich. oS9J55, 8OO-&l1t7167).
Beat known 0111 ITU1rket~r of henllh and
pers~l-are product&, Amway is .110
in the l'nr and tnICk relerrnl l)tlsin(,,~.
'hoe near OIU! of the delJlc!~" In the pru-
gram, shippiuK will CO$t on Rdditional
. $150 to $210.
Prices atut at $39 above the in-
v'niC'.r. Rmount nnd rnnge up to $!'It>O. YOll
can npply the t:ost nr the printout to your
purd\3se. Imports UKu311y go lor elise
Foe a $24.95 annual registrAtion lee, 	counts off the sticker price. whkh Is con·
Amway will refer you to one of more than 	verted to afixed amUl.lnt over the Invoice
01,000 dealers who have agreed to a 	"on the printout <:nr/Puter will arr.:lnge
"guaranteed maximum pricc" up to $150 	the purch.1!Se of most import!, except
oyet the blvoice .mount ror a domestic 	Hondll, !lom~ ToyotA!! Rdd limited·
model. CertaIn c:lrll, Bueh 35 the CDdilbc 	prnclur.tion :lnrf exotic mncIr.l!\. 	" 	"
Allantc, Chevrolet Corvette. Buick 	Cnr/Puter'!I d1.1rgp.!\ for the! Escort
Reatta, Ford Probll ilud most convert· 	were $8,420; for the Corsicn, $11,~;
Ibles, arc excluded from the guarolntp,r.. 	And for the Chryrller New Yurker,
Imports Dre sold at a percental:e off the 	$19.956. 'l'he!S4! pnce~ indude Ildvertill-
sticker price. You 'can also purcha!se a 	illl( cost~.
price sheet for $12.9511I!r car. 	NAnONWlDI AUTO 8ROKfRS. (17517 W.
Amway'a; price for th~ ESI.:ort WD5 	10 Mile Rd., Southfield, Mich., ~l:W75,
$8,320; for the Cotliica, $11,948. Tht! 	800,521.7251 	or, 	In 	MiehiKun.
Chrysler New Yorker ill 011 Amway'lI 	:J13-5S!)-666l). Na\iunwid~'. printout
limited-car Ii:st bectlu~ it ill in ereat cle- 	lists the Invoice amount :lnd retail price
mand. Th~ company:told uS that If i~ lor the base car and oyc:ry :Ivaibble op-
could find a p:\rticipating dt:alc:r willing to 	tion. H you c::aU with your r~uest beCore
seU the CU, it would cU$t$1~,701. Thello 	3 P.M" they'l mail you I pnce printout
pncelJ do not include: advertillillf, COlts, 	1M Mm~ day lit a cost 0{ $9.95. You
taxes and tags.. 	check off the equipment you want on thr
Note: Amway'l guarantee is lor 	fonn and send it b:lck with a depoait of
"orrlt!r~d" c!omcs[1C ve"icl~s, not those 	$100 rOt delivery of I eustom·ordercd
told off the lot, which me3ns that even if 	c:lr In Michigan. Jf you want to custom-
you fmd the e:cact c:lr you want at the 	Otdcr a car and you Jive outside Michi·
dealership, the dealer do6n't hoIve to 	~I\, yOll mmlt put dow" a $!iOO deposit.
aclJ it to you. You may have to wait Wr a 	un our test orders the cost 0{ the Esrort
vchiclc to be ordered and shipped, which 	W'tlS SH,220; the Corsica, $11,969 and
can lake up to eight weeks. 	. tho Chrysler New Ynrkt!r, $19,795. in-
Amwny ir. the only oervice ot the sUe 	eluding advertising COlItS.
Chat al50 off~rlJ I gu:lranteed price on 	. Note thatthe prices ofN~tionwide'.
lensed CAn, 1'hc Qpitalized wlit-lhe 	CUi rise according to the location. be-
basia lor determining the monthly 	cause of possible shipping chargel$. Fur
paymcntr-is fixed at no UlQ(e than $800 	example, d~livery to New }urscy woulct
over the invoice amount, 	add $185 and delivery to Californi41
Arnway'. program ill aVAil:lble in 29 	would tack on $'l50. AlPin. it pnys to
ltAtea .nd the Pistlict oC Columbia. 	shop foe the car-buying ~rvic." ill your
There Ar~ 00 programs tn the nslllOlining 	arc. that can offer vou the best oric:e.
atntt'.1'l beCAUll: 01 restrictive brokcrini 	UNITED ItUYING 5E.VICI (U.$j.""he~
Iowa there.' 	are I num~r or lJl'~ OIIKes around the
CAR/PUTIA INTlINATIOHAL CORP. 	cuuntr), that o((cr referral services.
(1603 Bushwick Ave., Brooklyn, N.Y. 	£ach is an Ind~petldent company. Sornt!
11:),01, 80{)..2'~I·"OOl or, in New York, 	are open to all comers; others are .n
718--155·2500). When you order a car 	only to employees of compani¢s signtd
through Car/Puler, you get II printout ol 	up with UBS. Chf!\:k the te~phune c1irp.L:·
the bulc car with .orne C~nJl, .which 	tory for a Ioea! listing lor Ua.<;, or with
)'Ou can rUle·tune by adding or deleting 	your t!mployer tn find nut whether )'our
options. A printout costs 121; ifyou are I 	company is enrolled.
member of olle of the more than 40 	In the Washington, D.~./Baltimort'
orpni:D~uto dub., credit card 	area, I call tel Unlced Buying Serv\((:
.wen and national IIIliuclations--that 	(301-657-1920 or 301·792·9070) cotitles
have Dgreemell~ with the compuny, it 	10U to Q cerlirl(;ltA 01 rc(~mll, which yo\l
may COlt )'OU nothing. 	take with you to 0 Ioal de:lIership signed
After you lend in." nonrefundable 	up with uas. T~ service relies on the
5500 d~~lit. )'Out Cat will be: (h:Jivcm:d 	dealership to follow tM lIKreed-upon
from one of more than ..so dealers 	prices in at" O/lido{ Pn'", Bwlt, which is
..igned up with the service. If you don'l 	al5o'",lId by lome uas Of{jC.~1 in other
--, ... --------- -------- ...
9l 'd 	S01' £s£ zn: l£ZZ099 	**** 	ror:H ~ -"\, .

... 	.n. e• seM ¥' rt *' , '•. tt d ted·.. ,) t ,. .. or p.', >,tv.'"
Call toll-free 1·800·445·3933
1If1"a,.d/l.lj.JIOIlclft.,.. .""".,.II/roll,,, ,tocA6ro1r.l'I. I,.,wttllCfl
"1-"" ",." III"~""'.'" ,,"".~'o,., "lffl ",.. lIu".." t. all.,. ,,,.....
Today it matt~what you're.worthtomorrOvl.
Monarch R~Is. 3Ubld4l~of Nonarch capta'·CotportItJoD.
tc-lWk Stock £adutnlec.,abol NON.
e 	N
'..
"'I
cities. For most .domestic' cars 'thal's
usuaUy $100 over the UBS price::.. 	.
'. UBS cost for the Ford ElScort Wl\S
$8,434; the Chevrolet Corsica ,was
$12,058, and the New .Yorker"was·
$'lO,OO'l. 1be pric~ work OOl to be $81
higher than the Invoice amounl on the
Ford Escort. $260 on the Chevrolet Cor-
sica and $506 on the Chrysler New
Yorkcr Landau. 	.'
One uns purch:llu:er u( a 1988 Ply-
mouth Voyager minivan dcscribed hi:;
car-buying f:xperiencc this way: ~'Tht!
&alesfMn wrote up the ticket 'usill)( the
dealt!r ~t riJ(ure!f lor eY~ry (JIllion,
Ulited in the U);$$ Kuida: righl at hi~ de!.!k,
and charged $lOO of denier profit. And
that was it. It's a very p1eaunt, inexp~n.
aive vr.Jy tu buy a car. nu h.1JU(linJ(. flU f1(!.
Koli:ltion, nu tWIllS".:.It
UBS l&ayll t!ust yuu ~'a11 mail thc:m
the completed paperwone so they can
check to make sure the de:sler charjiled
the oUiciai pncell. And they 3te willing to
review I dealer's prlcc~ with you before
J'UU aiK'l • sales agree~nt. 11 you are
overcharRed, UBS wilJ get you a refund
Note that UBS is also in the busine5S at
selling mailinalists. so if you don't want
your name to show up on them,' reque~t
to h.1ve it removed. 	.
USAA BUYING SoVlels. USAA Build·
lolt, 9800 Frcdcrlcbburg Rd., SAn Anto-
nio, Tex. 78288, 8OO-031·890S). USA"
'Buying Services is available to military
orflCe~ who Ire USAA members and to
a small num~r bC eliKiLJle lovcrnmcnl
\Yorkcl'l. USM hal si£r.ed ai,lfeement&
with the dealers in 52 mtttropolilan
areas, For a $1S fce, P3tticipants are re-
ferred to partidpating toeal dealers. who
price t~lr QU'S At an avcrit2~ nil~ nr
~lOO over the invoke amount. Prices
vary from city to city.
In O"'~II, for Instllnce. II USAA
member <:an purchase the ucort for
$8.251, the Conica lor $l1,79'-J and the
Chrysler New Yorker for $1~.7~~,
1bese prices do not reflect any IocD1 ad·
vertising tostl. taxes, titles or dealer
preparation charaes. You miaht be able
to do bener if you shop elsewhere, bul
the USAA prices Ire atill leu than the
cars' ~tail pricea. 	. .. . 	" 	.
. 	USAA cu,tomers am pun:b3se an
$8.95 mmPuterized price list to acquaint
themHlvos with the price or a car before
venturing into the showroom. Company
offlCia.ls contend U~t you needn't buy
one to use the aar-buyinx pl'Oiram be·
cause dealers It'I! reQUired to ,how CUll-
&Omers Uw IClUOlI invoice she\!t on d~
Ille$tic vehicles. 	-ay ID KaHil
aUlA'CH,SMIU'MlUra
CAR· BUYING SERVICES
·u._ ....•••• e 	e.~ 	, •
, .'"	..;. "_::,e:e.. e_....
. 	.
Invest in a postage stamp. Just m:lil in
the coupon and we'U tell you huw you c:m
cumbine the' gU:lr:l~1teed security of life:
insurotnce, the locked-in 	-~~$.~S:;'l'!;SS~~~
returns of U.S. Tre:isury 	fc,~ )"oil1\ 	..~ POITUl
7.ero Coupon bonds, and 	~O'f-. '~\~ 	25<:
the growth potential of 	.
.. mutual funds. we'll tell you 	N. "'i. 	.-- ....
.:lbout Moruu-ch, the number one variable Ufe
.in'lur:mce program in Amerlca~ And huw it c:m
help you plm today for the retirement you
~t tomorrow•..
.-1··.-·"...·	:,' 	'~ ...... , 	'~.,
~., 	.. L' 	I 	;.' 	.
r------------------~-------~I 	~ Pl~ amd me additional fntormatlOd OIl MolUll'Ch Vlarl. I
. I. 	_ble LUe In.e\lrancc. Enclose free prullpa:bu eontMlDiIl' all I
charlC8 and expenaes.1 WW read tbc materia'- c:arefvJ\, before 	•
I 	l1Dycat or KDd mOtley, 	I
I 	-------------------_	I 	a_t- 	_
I 	al>' 	"ale 	"', 	_
I 	~...- 	"-.....-------__
I 	~rtnI_----------------
I 	.... 	...._,............- ...' ------
I
I 	.---~ 	.	MonarchResoun:ea,lnc. 	.-.1"'. __ 	_
I 	780 Third Avenue 	- 	......----.-
I ., _ 	.. IMo ..--.--.
. New York. NY 10017 	1foI·,...... MA. - 	"ft ..-
;. 	1.800;445.~93S 	~.:~-=.:-~~ .	L 	~
. 	.	e. _. _. , •••~. 	• 	- .. w.,...
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