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RV industry unhappy about Fed’s idea to combat high-pressure RV sales

“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.

##RVT1070b

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KellyR
12 hours ago

RVDA response: My daily driver is a Roadtrek built within a Chevy van, but “not a vehicle in the common sense”, or “non-essential”. Hmmm – how do I get my tools to work? The State of Florida thinks it is a vehicle in the common sense. And I thot it was the non-essential purchase of my 2 seat convertible that I use as a “means to escape from my daily life”. I hope they are careful as to how they write this reg. or I am really screwed. Who is in this RVDA think tank, anyway? Johnny Robot?

Kevin Hogle
5 days ago

Perhaps the best thing is to improve coverage under state lemon law. It would incentivize good quality. Otherwise the manufacturer and dealer would be buying many of these shoddy vehicles back. Maybe the value would still be ok in 10 years if quality was built in. No longer have so many repairs.

Drew
6 days ago

“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.”

-I couldn’t agree more Andy, thanks.

Micheal Whelan
7 days ago

The RVDA should know by now if you don’t police your bad actors some politician or bureaucrats will be willing to make money policing it for you…. and not in anyone’s best interest.

David
7 days ago
Reply to  Micheal Whelan

Exactly!

Ron Yanuszewski
7 days ago

Anything the RV industry is against is a must do at this point. And I’m part of it.

MrDisaster
7 days ago

Great information, but a week late. FTC closed the comment period on September 12. If known before the closing period we (all of us) could have made our comments.

M J
7 days ago

Even though my wife and I have had several RV’s, we would never have expected what happen to us with our last two brand new purchases. First a 2020 Grand Design Solitude 380FL. We had it for 4 months before major problems, including the roof peeling off, the dealer, Lazy days Florida, had it for 10 months. Ran out of warranty, to bad so sad. We dumped it and bought a new 2022 jayco. Paid cash and the Dealer, RV one Tampa, kept it over two months to fix the pre delivery items. That’s two months less warranty for us. We got tired of waiting and picked it up with both broken and missing parts. It’s shameful.

Edward Wilkinson
7 days ago

“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”.

I named my GE 12 volt fridge “Medusa” due to my heart turning to stone every time I look at the darned thing. We’ve had this 12 volt fridge, with little included (without paying extra) on the RV to keep Medusa running on a short dry camp trip. Industry, dealer, an unwary idiot like me are all culpable. Since I bought the Rockwood 2109S I have been pouring money out to keep this voracious fridge running for a few days. Let’s protect the unwary idiot, I say!

An inverter generator, even more solar power than the 380 rooftop watts I started with, and replacing two new golf cart batteries with 200 amps of LifePo4 lithium’s have been the necessary steps taken to continue our short dry mountain camping trips for my wife and I.

Skip Gimbrone
7 days ago

Wanted to buy a TT at a local Oregon RV dealership. At the time we had an F150. Salesperson took the vin number and informed us they would not sell us this unit because our truck was not rated to tow it. That really made an big impact on us. There are honest dealers out there.

Les
7 days ago
Reply to  Skip Gimbrone

I think we would all like to know the name of this dealership.

Skip Gimbrone
7 days ago
Reply to  Les

Guarantee RV

Mike
5 days ago
Reply to  Skip Gimbrone

Guess it wasn’t a guarantee 🙂

Dana D.
7 days ago

Camping World advertises a price on their website for an RV. I went to Camping World with cash to buy the RV at the advertised price. Nope. The advertised price is the financing price. If I want to pay cash the price will be $3000 more.

Admin
RV Staff(@rvstaff)
7 days ago
Reply to  Dana D.

Wow! Thanks for that information, Dana. Have a great day! 😀 –Diane

Del W
7 days ago
Reply to  RV Staff

They are not the only dealer who does that. Some dealers who advertise as “wholesale” do the same thing.

Admin
RV Staff(@rvstaff)
7 days ago
Reply to  Del W

I believe it. Caveat emptor, for sure! Thanks, Del. Have a good afternoon/evening. 😀 –Diane

Mike
5 days ago
Reply to  Dana D.

I was under the impression that it’s illegal to have a higher unadvertised price for cash.

Not that this is gonna stop these used-car-dealer rejects.

Bruce
7 days ago

I don’t condone what dealers do, but it is too bad schools don’t spend more time teaching about things like what paying for things on time means. Teaching what compound interest really cost. Compound interest can be good or bad. It depends on if you are earning or paying it. Yes I ran a business so I know what Interest is. I always tried to earn more on it than what I was paying.

Bruce McDonald
7 days ago

“The proposed rule would prohibit motor vehicle dealers from making certain misrepresentations…” Wait a minute! Shouldn’t that be “…prohibit motor vehicle dealers from making ANY misrepresentations…”. Why should they be allowed to make some misrepresentations and not others? One should question why there is a need to write a rule about making misrepresentations in the first place. Shouldn’t honesty be a fundamental part of all business dealings?

Neal Davis
7 days ago

Very interesting stuff; thank you!

Ron
8 days ago

Since when does the RV industry care about the consumer. The guilty always screams the loudest.

Jeff
7 days ago
Reply to  Ron

Your comment pretty much, hits the nail on the head!!

The RV industry doesn’t give a crap about the consumer or the crap coming off the assembly lines. Needless to say…the only thing the RV industry cares about is profit, nothing else matters to them!!!

James LaGasse
8 days ago

A consumer is still a consumer and a con arrested is a con artist, as long as sales people are commission driven and those sales support the business there will be scams. Businesses need sales to survive and managers will pressure commissioned sales people to sell or find another job. I have sat in on several sales pitches for RVs and felt some salespeople made used car salesmen look honest. When we’re talking about that much money and commissions there will always be some unscrupulous people taking advantage and cheating. With stories I’ve read and things I have witnessed and the large sum of money involved oversight is needed. Next quality control and customer support needs to be looked into.

Dan
8 days ago

Caveat emptor. What’s even worse is the financing on boats. Thirty or more years on a boat? How many people keep a boat that long?

Donald N Wright
8 days ago

I would suggest a “bumper to bumper” warranty as long as you are making payments at any RV dealer that sells that product. Payments are suspended without interest every time RV in shop for warranty repairs.

Gary
7 days ago

The dealer already got his money. Your payments go to an unrelated bank.

MrDisaster
7 days ago
Reply to  Gary

Well sorta… most dealers have a relationship with the financing bank and get a rebate for the referral as well as a rebate for each “extended warranty” they sell.

Drew
6 days ago

Donald, In my opinion “bumper to bumper” these days is practically non-existent. The wording is there but the resources to do the work aren’t.

Leonard Rempel
8 days ago

Protecting the consumer is important, but even more important is the consumer using a modicum of common sense when buying an RV or anything else for that matter. So a salesman offered a 20 year loan. Stupid to even consider this, however 8-10 year loans are now available for automobiles.
Hard to legislate against stupid decisions.

KellyR
7 days ago
Reply to  Leonard Rempel

When I bought my first cars, car loans were for 3 years. House loans were 15 to 20 years. RV loans now 20 years? This tells me that either wages in general have not kept up with the cost of living, OR, that people are being sold and buying things that they really can’t afford. People evidently look only one month ahead – not thinking “how to get ahead”. Unfortunately it is not just the “kids” that have fallen for that financial trap.

Vince B
5 days ago
Reply to  KellyR

Just a comment, I suspect that quite a few rv units would go unsold if financing was not available. Not everyone has the ability to just go out and pay cash for the unit.
Now, the way I see it, if financing long term is your only way to get into the unit of choice, then you should put as much down as possible,
to avoid becoming upside down financially in the unit. Trying to stay ahead of the curve until depreciation at least slows down. Maintain the unit faithfully both inside and out and maybe, just maybe, when you go to sell, your financial hit won’t be a disaster. Just a thought. Oh, I might add, if you genuinely use it and you have youngsters who get to experience the outdoors creating memories they will carry with them the rest of their lives, ask yourself, did you not do the “right thing”?

Bob p
8 days ago

This is a perfect example of what I’ve been advocating for years, don’t elect lawyers to represent you in congress or for that matter state legislators, no common sense!! They make blanket legislation to cover everything instead of specialized legislation to keep the bad actors at bay. One size doesn’t fit all, but in their way of thinking penalize everyone for a few violators. In the end everyone has more paperwork which causes prices to raise as someone has to fill out all this paperwork, and for the tree huggers, more trees are cut down to record this paperwork. Lol

Rob Kelly
8 days ago
Reply to  Bob p

You must work for the RV industry.

Ron
7 days ago
Reply to  Bob p

Legislators are millionaire which you elected.

Spike
7 days ago
Reply to  Ron

A current political ad blasts Senator Ron Johnson (R-WI) for being the 5th richest US Senator. But Mark Warner (D-VA) is #1 and even Dianne Feinstein (D-CA) is #4! I can see Warner and Johnson as successful entrepreneurs having large wealth, but how does a career politician get that wealthy!!!

Net, party isn’t an indicator of wealth. Both sides play that game equally well! Both sides protect their personal interests.

Ron Yanuszewski
7 days ago
Reply to  Spike

Feinstein married a billionaire

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