“RV” is shorthand for “recreational vehicle,” a point strongly emphasized by trade groups like the RV Industry Association–which represents RV manufacturers–any time someone begins confusing RVs with housing. Sure, a travel trailer or park model may look an awful lot like a single-wide house trailer, but they’re built to different standards and no one, for example, should expect to live year-round in an RV. “RV housing?” No such thing, regardless of what it might look like.
But once you’ve declared yourself to be either fish or fowl, you can end up in some pretty strange contortions trying to straddle the divide. Take the Recreation Vehicle Dealers Association, for example, which is embarrassing itself these days by claiming that the vehicles its members sell are, well, not just vehicles. Yes, the automobile industry sells vehicles, but those wheeled conveyances rolling down the nation’s highways are “standardized.” In the RV industry, on the other hand, “it is customary to prepare a vehicle before a customer is able to use the RV.”
See the difference? RVs are non-standard. They deserve non-standard regulatory treatment. Special treatment.
What’s got the RVDA all twisted up like that is a proposed new rule from the Federal Trade Commission that seeks to better protect consumers from being ripped off by unscrupulous dealers. Specifically, “the proposed rule would prohibit motor vehicle dealers from making certain misrepresentations in the course of selling, leasing or arranging financing for motor vehicles.” Any RV buyer who has found himself with a 20-year loan for a rolling box that will have a resale value approaching zero in half that time will applaud the sentiment.
While the RVDA may insist that a Class B Sprinter RV is nothing at all like a Sprinter cargo van, both can be subject to the same high pressure sales tactics that the FTC wants to clamp down on: vaguely explained additional charges, deceptive pricing, reams of paperwork that serve as a graveyard of land mines for the rushed buyer. If adopted, the new rule “would significantly alter the way motor vehicles are sold, marketed and financed in the U.S.,” the RVDA laments on its website, “by adding additional disclosures on pricing, vehicle add-ons and onerous new recordkeeping requirements.” The horror, the horror!
Curiously, the RVDA website also states that the association on Sept. 12 had filed formal comments “highly critical” of the proposed rule, asserting that the proposal would “increase sales transaction times for customers and add to the cost of the RVs.” But while the RVDA thereby poses as a champion of the little guy, the supposed filing is nowhere to be found on the FTC’s very comprehensive online repository of comments. Indeed, of the 26,356 comments the FTC had received as of today, apparently only one came from the RVDA: an Aug. 2 request that the FTC extend its Sept. 12 deadline for comments. The FTC declined.
Anyone around this industry for any amount of time knows there’s a huge need to rein in the flim-flam artists–which is not to say that every RV dealer is a con man, but that there’s no easy way to separate the white hats from the black. Government oversight would go a long way toward leveling the playing field, in an industry that is selling the second-most–and sometimes the most–expensive things most people will ever buy. Moreover, adoption of this rule or something quite like it might set the stage for the next glaringly obvious regulatory need: a crack-down on the industry’s deplorable track record on after-sale warranties and repairs, so that newly sold RVs don’t spend their first year in and out of service bays.
Meanwhile, fish or fowl? If RVIA wants to assert that RVs are not housing, while the RVDA is similarly adamant that they’re not vehicles–at least in the conventional sense–then maybe it’s time for a whole new classification with a whole new set of rules. Perhaps RVs are modern society’s chimera, a fire-breathing female monster with a lion’s head, a goat’s body, and a serpent’s tail. But even a chimera needs rules to live by, for the protection of the rest of us.
SEPT. 18 UPDATE: Turns out that the RVDA submission to the FTC, although dated Sept. 12, took four days to make it into the online databank. To learn more about it, see the post that follows this one, probably late Sept. 18.
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