“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, claims the RVIA, 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 (aka National RV Dealers Association, or RVDA), for example, which is embarrassing itself these days by claiming that the vehicles its members sell are not really motor vehicles in the common sense. They’re something else entirely, “designed primarily as temporary living quarters for recreational, camping, travel or seasonal use”—and therefore it’s really unfair to put them in the same category as your average “standardized” automobile.
Confused? Read on.
Protecting consumers from unscrupulous dealers
What has 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!
RVDA’s response to FTC proposal
A more comprehensive look at the RVDA’s objections may be read in its response to the FTC proposal, filed at the Sept. 12 deadline and posted four days later, which basically asserts two points: that the FTC’s proposal shouldn’t apply to RVs because RVs aren’t vehicles in the accepted sense, and that the rules would create an onerous burden on RV dealers. Curiously, the RVDA’s 13-page response opens with the observation that RVs are a discretionary purchase, unlike other motor vehicles, and are “not essential for their daily life activities, but a means to escape from their daily lives.”
What does that mean? According to the RVDA, only that “The FTC’s stated purpose to protect consumers for essential motor vehicle purchases used for daily activities does not justify placing this regulation on recreational vehicles since they are not essential for daily activities.” Translation: Federal regulations that apply to “essential” purchases are too rigorous for an industry that sells non-essential toys, even if those toys may easily cost the buyer several times more than the “essential” item.
There are a lot more specious arguments of this sort included in the RVDA brief, from the observation that the RV market is considerably smaller than the automobile market, to a somewhat strained claim that the RV industry needs special regulatory treatment because RVs are not as standardized as automobiles—that “in the RV industry it is customary to prepare a vehicle before a customer is able to use the RV.” At bottom, however, the RVDA is simply claiming that the FTC is trying to solve a non-existent problem—but that if there is a problem, “enforcement should focus on the bad actors, and not treat every dealership as if it is a bad actor.”
A need to rein in flim-flam artists
Anyone around this industry for any amount of time knows that there are indeed “bad actors”—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. That’s where standards and reporting requirements come in, creating the kind of paper trails that enable regulators to figure out just who the “bad actors” may be.
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. The RVDA would do itself a huge favor by acknowledging that there is a problem and suggesting solutions, rather than reflexively opposing anything that smacks of more paperwork for its members. 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.
PREVIOUSLY FROM ANDY…
RVs becoming housing of last resort
By Andy Zipser
The ongoing and deepening U.S. housing crisis continues to ripple through the RV and camping industry, as more people are squeezed out of conventional housing and traditional notions of what it means to have “conventional housing” get upended. Read more.
Andy Zipser is the author of Renting Dirt, the story of his family’s experiences owning and operating a Virginia RV park, and of Turning Dirt, a step-by-step guide for finding, buying and operating an RV park and campground. Both books are available through some bookstores or at Amazon.com.