BILL ANALYSIS                                                                                                                                                                                                    �



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          Date of Hearing:   June 17, 2014

              ASSEMBLY COMMITTEE ON BUSINESS, PROFESSIONS AND CONSUMER  
                                     PROTECTION
                               Susan A. Bonilla, Chair
                    SB 686 (Jackson) - As Amended:  June 10, 2014

           SENATE VOTE  :   22-12
           
          SUBJECT  :   Vehicles: vehicle dealers.

           SUMMARY  :   Prohibits a vehicle dealer from selling a used  
          vehicle if the dealer knows or should have known that the  
          vehicle is subject to a manufacturer's safety recall and does  
          not correct the defect.  Specifically,  this bill  :   

          1)Prohibits the holder of any vehicle dealer's license from  
            selling or otherwise transferring ownership at retail of a  
            used vehicle, as defined, including any used vehicle  
            advertised as "certified" or any similar descriptive term, if  
            the dealer knows or should have known that the vehicle is  
            subject to a manufacturer's safety recall, unless the repairs  
            required to correct the defect have been performed on the  
            vehicle.  

          2)Provides that this prohibition does not apply to transfers or  
            sales by a dealer to another dealer, an auto auction, or a  
            manufacturer.

          3)Provides that a dealer is deemed to have knowledge of a  
            manufacturer's safety recall if any of the following applies: 

             a)   The dealer receives notification from the manufacturer  
               of the vehicle about the manufacturer's safety recall for  
               that vehicle, as specified; or 

             b)   The dealer is a franchisee of the manufacturer, or was a  
               franchisee of the manufacturer at the time the manufacturer  
               issued notice of the safety recall; or 

             c)   Prior to the sale or other transfer of ownership at  
               retail of the vehicle, the manufacturer has made  
               information about the manufacturer's safety recall  
               regarding the specific vehicle available on the  
               manufacturer's Internet Web site, searchable by vehicle  








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               identification number (VIN), stating that the  
               manufacturer's safety recall repairs have not been  
               performed.  

          4)States that a violation of these provisions is actionable  
            under the Consumer Legal Remedies Act, the Unfair Competition  
            Law, Business and Professions Code Section 17500 (related to  
            false advertising), or any other applicable statute or federal  
            law, and further states that such rights and remedies are  
            cumulative and not to be construed as restricting any right or  
            remedy that is otherwise available.  

          5)Defines a "manufacturer's safety recall" as a recall pursuant  
            to the National Highway Traffic and Motor Vehicle Safety Act  
            and that does not include service campaigns or emissions  
            recalls where the manufacturer has not issued a safety recall  
            notice to owners of affected vehicles.

           EXISTING FEDERAL LAW  

          1)Establishes the Moving Ahead for Progress in the 21st Century  
            Act (MAP-21), and requires the Secretary of the United States  
            Department of Transportation (U.S. DOT) to promulgate  
            regulations by July 6, 2013, requiring motor vehicle safety  
            recall information to be publicly available online and  
            searchable by vehicle make, model, and VIN.  (Public Law  
            112-141, 112th Congress, Section 31301) 

          2)Sets forth in federal regulations the requirements for when  
            manufacturers must notify vehicle owners, dealers, and  
            distributors about a defect that relates to motor vehicle  
            safety or noncompliance with a federal motor vehicle safety  
            standard.  (49 Code of Federal Regulations 577.1 et seq.)  
           
          EXISTING STATE LAW  

          1)Prohibits any person from acting as a dealer, remanufacturer,  
            manufacturer, or transporter, as specified, without having  
            first been issued a license or temporary permit, as specified.  
             (Vehicle Code (VC) Section 11700)

          2)Prohibits a holder of a license from, among other things,  
            making or disseminating any statement which is untrue or  
            misleading and which is known, or which by the reasonable  
            exercise of care should be known, to be untrue or misleading,  








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            as specified. (VC 11713(a))

          3)Establishes the Car Buyer's Bill of Rights and prohibits a car  
            dealer from selling or advertising for sale a used car as  
            "certified" under certain conditions, including if the dealer  
            knows or should have known that the vehicle was reacquired by  
            the vehicle's manufacturer or a dealer pursuant to state or  
            federal warranty laws, or if the term "certified" or any  
            similar descriptive term is used in any manner that is untrue  
            or misleading or that would cause any advertisement to be in  
            violation of the provisions prohibiting a car dealer from  
            scheming to sell a vehicle or service at a price other than  
            advertised in accordance with the Vehicle Code, or the unfair  
            competition laws contained in the Business and Professions  
            Code.  (VC 11713.18.)

          4)Prohibits a dealer or person holding a retail seller's permit  
            from selling a new or used vehicle that is not in compliance  
            with the Vehicle Code and departmental regulations, unless the  
            vehicle is sold to another dealer, sold for the purpose of  
            being legally wrecked or dismantled, or sold exclusively for  
            off-highway use, as specified.  (VC 24007 (a)(1))

          5)Provides that when a federal motor vehicle standard is  
            established under federal law, as specified, no dealer shall  
            sell or offer for sale a vehicle to which the standard is  
            applicable, and no person shall sell or offer for an item of  
            equipment sale for use upon a vehicle to which the standard is  
            applicable unless:  (a) the vehicle conforms to the applicable  
            federal standard; or (b) the vehicle or equipment bears a  
            certification, as specified.  (VC 24011)

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   

           1)Purpose of this bill  .  Under existing state and federal law,  
            car dealers are not required to check whether a used car sold  
            at retail is subject to a recall, and if a pending recall is  
            known, car dealers are not required to notify potential buyers  
            or remedy the recalled defect.  In response to concerns about  
            the sale and safety of recalled cars, this bill would prohibit  
            a dealer from selling a used car at retail if the dealer knew  
            or should have known that the car is subject to a  
            manufacturer's safety recall and did not repair the safety  








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            defects.  This bill would not, however, prohibit the sale of a  
            used car with unrepaired recall defects in private party sales  
            or in wholesale transactions.  This bill is sponsored by  
            Consumers for Auto Reliability and Safety.

           2)Author's statement  .  According to the author, "Since the  
            1960's, federal law has prohibited franchised new car dealers  
            from selling or leasing new vehicles that are under a federal  
            safety recall unless they have been repaired, but there is no  
            prohibition against selling, loaning, renting, or leasing used  
            cars that have an open federal safety recall pending unless  
            they have been repaired.

          "Auto manufacturers are required by the federal Motor Vehicle  
            Safety Act to provide auto safety recall repairs for free to  
            anyone who owns the vehicle.  In order to have a recalled  
            vehicle repaired, the owner may have to take it to an  
            authorized dealership repair facility.  Auto manufacturers  
            compensate their franchised auto dealers for performing the  
            repairs.

          "As reported by the New York Times, Good Morning America (ABC  
            News), and other national media, as well as numerous local  
            media in California, some new and used car dealers are selling  
            recalled used cars to California consumers without fixing the  
            safety recalls.  The problem of auto dealers selling  
            unrepaired, recalled cars to consumers has also been  
            documented by the non-partisan U.S. Government Accountability  
            Office (GAO) in its June 2011 report to Congress. 

          "This bill will give consumers who cannot afford a new car, or  
            simply choose to purchase a used car, the same level of  
            protection new car buyers have had since the 1960's.   
            According to the International Association of Machinists and  
            Aerospace Workers, [this bill] will also create at least 1,000  
            new jobs for automotive technicians performing safety recall  
            repairs."

           3)Understanding motor vehicle safety recalls  .  The National  
            Traffic and Motor Vehicle Safety Act (Act) gives the U.S.  
            DOT's National Highway Traffic Safety Administration (NHTSA)  
            authority to issue motor vehicle safety standards and to  
            require manufacturers to recall vehicles that have  
            safety-related defects or do not meet federal safety  
            standards.








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          Manufacturers voluntarily initiate most recalls, while others  
            may be influenced by NHTSA investigations.  If a safety defect  
            is discovered, the manufacturer must notify NHTSA, as well as  
            vehicle owners, dealers, and distributors, plan a recall  
            campaign to remedy it, send repair guidance to franchised  
            dealerships, send notices to vehicle owners, and monitor the  
            effectiveness of the recall campaign and provide to NHSTA data  
            on the status of the recall campaign.  The manufacturer is  
            required to remedy the problem at no charge to the owner (for  
            vehicles sold up to 10 years before the recall).  After a car  
            is brought to a franchised dealership for repair, the dealer  
            will perform the recall remedy and submit claims to the  
            manufacturer for reimbursement.  NHTSA is responsible for  
            monitoring the manufacturer's corrective action to ensure  
            successful completion of the recall campaign; however, NHTSA  
            cannot require car dealers to notify potential buyers of an  
            outstanding safety defect or require that they get the defect  
            remedied prior to a sale. 

          Conversely, NHTSA may have received enough complaints and  
            information about the operation of a vehicle that it finds  
            there is a significant threat to public safety and initiates a  
            mandatory recall.  NHTSA can perform an investigation with a  
            review by engineers and experts and work with the vehicle  
            manufacturer to recall vehicles.  These recalls are  
            facilitated through direct relationships between  
            manufacturers, franchised dealerships, and owners who  
            purchased the new vehicles.  Manufacturers may dispute a  
            mandatory recall by petitioning NHTSA or bringing suit in  
            court.  According to NHTSA, from 2000 to 2011, all safety  
            defect recalls for passenger vehicles were conducted  
            voluntarily by manufacturers, although some of those recalls  
            were conducted based on NHTSA's investigations of safety  
            defects.    

          The process of alerting owners of used vehicles is more  
            difficult because the vehicles may have changed hands several  
            times, and manufacturers may not have established  
            communications with used vehicle dealers who buy and sell  
            multiple different types of cars.

           4)GAO report finds lack of recall information for used cars a  
            'significant risk'  .   According to a June 2011 GAO report that  
            examined the federal safety recall process, "NHTSA cannot  








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            require used-car dealers (or franchised dealerships that sell  
            used vehicles) to notify potential buyers of an outstanding  
            safety defect or require that they get the defect remedied  
            prior to sale."  The report pointed out that, with 35 million  
            used cars sold in used and franchised dealerships in 2009  
            alone, unknown recalls "could pose a significant risk to the  
            safety of millions of vehicle drivers and may have a negative  
            impact on recall completion rates."  It adds, "NHTSA also  
            currently lacks the authority to require manufacturers to  
            notify used-car dealerships - which sold 11 million cars in  
            2009 - of recalls or require these dealerships to notify  
            potential buyers of an outstanding recall. As a result, many  
            consumers may be unknowingly putting their lives at risk by  
            purchasing a defective vehicle."

          According to a February 11, 2014 press release by private-sector  
            vehicle information provider Carfax, "[M]ore than 3.5 million  
            cars were listed for sale online with an open safety recall.   
            Texas, California, Missouri, Florida and Ohio led the nation  
            with the most recalled cars for sale online last year."

           5)Substantial number of recalls announced annually  . Based on  
            data provided to the Committee, it appears that there are a  
            very substantial number of automobile recalls occurring  
            annually, meaning that the number of recalls affecting used  
            cars is also going to be significant.

          According to Carfax, over 36 million vehicles currently  
            registered for use on American roads are under a safety recall  
            - or 1 out of every 7 cars.  According to the Los Angeles  
            Times, "[A]utomakers have issued almost 20 million vehicle  
            safety announcements so far this year.  No, the world's cars  
            aren't falling apart.  But headlines and lawsuits over slow  
            recalls have made auto manufacturers more vigilant?Automakers  
            that were slow to recall defective vehicles in the past have  
            been hit with increasing large federal fines and costly  
            product-liability lawsuits.  Meanwhile, [NHTSA] faces growing  
            congressional criticism for not forcing car companies to  
            recall vehicles quickly."  ("Auto recalls speed up, are on  
            track to break a record," May 15, 2014, Los Angeles Times)

          USA Today also reports that while most recalls include less than  
            50,000 vehicles and are typically completed in two or three  
            months, General Motors (GM) has issued eight recalls this year  
            covering seven million vehicles, and will need nine million  








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            parts, including ignition switches and power steering motors,  
            to make all necessary repairs.  The largest of these recalls  
            is the recall for 2.6 million cars with faulty ignition  
            switches that has been linked to 13 deaths.  According to GM,  
            suppliers have to make the parts, and GM has to notify  
            customers, ship the parts to dealers, and train mechanics how  
            to do the repairs.  GM estimates this process will take up to  
            six months to make and distribute all the parts for this  
            recall, pushing the completion time out to October of 2014.   
            There is no estimate on when the other recalls will be  
            finished.  ("Owners of recalled GM cars face long repair  
            wait," May 8, 2014, USA Today)

           6)Defining the "safety recall"  .  This bill would prohibit the  
            sale of vehicles that are "subject to a manufacturer's safety  
            recall."  This is an important distinction because not all  
            recalls are safety-related under the Act, and would not  
            trigger the provisions of this bill. 

          According to NHTSA, the Act defines motor vehicle safety as "the  
            performance of a motor vehicle or motor vehicle equipment in a  
            way that protects the public against unreasonable risk of  
            accidents occurring because of the design, construction, or  
            performance of a motor vehicle, and against unreasonable risk  
            of death or injury in an accident, and includes nonoperational  
            safety of a motor vehicle."  A defect includes "any defect in  
            performance, construction, a component, or material of a motor  
            vehicle or motor vehicle equipment." Generally, a safety  
            defect is defined as a problem that exists in a motor vehicle  
            or item of motor vehicle equipment that poses a risk to motor  
            vehicle safety, and may exist in a group of vehicles of the  
            same design or manufacture, or items of equipment of the same  
            type and manufacture.

          According to the 2011 GAO report, there are two types of safety  
            recalls.  Compliance recalls occur when vehicles or vehicle  
            equipment is determined to be noncompliant with applicable  
            federal safety standards, as identified by NHTSA or a  
            manufacturer.  Compliance recalls range from design issues  
            with seatbelts to improper placement of warning labels for  
            airbags, and from 2000 to 2009, accounted for 18% of vehicle  
            recalls.  The other 82% of recalls were safety defect recalls,  
            which occur when a defect in a vehicle creates an unreasonable  
            safety risk as determined by NHTSA or a manufacturer.   
            Examples may include problems with ignition switches, steering  








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            components, fuel systems, accelerator controls, air bags,  
            wiring or child safety seats, among other things, that have  
            the potential to cause harm or increase the risk of a crash.   
            NHTSA also provides a partial list of what would not  
            constitute a safety-related defect: air conditioners and  
            radios that do not operate properly, ordinary wear of  
            equipment that must be periodically maintained or repaired,  
            nonstructural rust, paint or cosmetic blemishes, and excessive  
            oil consumption.

          According to NHTSA, about 70% of all vehicles subject to a  
            recall are fixed within the 18-month period during which  
            manufacturers provide recall completion data to the agency;  
            however, this figure differs greatly by year, by manufacturer,  
            and by type of defect.  For example, some recall components,  
            such as brakes and airbags, had roughly a 60% completion rate,  
            while other components, such as wheels, had an 80% completion  
            rate.

           7)Existing resources for used-car buyers and dealers  .  According  
            to a June 25, 2013, letter from NHTSA, "An auto dealer (or any  
            vehicle owner) today may easily access up-to-date, VIN  
            [vehicle identification number]-specific information regarding  
            the safety recall status of a used car.  Such information may  
            be accessed through the manufacturer's publicly accessible  
            VIN-look up website, through a commercial VIN-look up service  
            for registered owners, or through the manufacturer's toll-free  
            number. 

          "By entering a unique VIN on the vehicle manufacturer's publicly  
            accessible VIN-look-up website, an auto dealer can access  
            VIN-specific recall information from such manufacturers as  
            General Motors, Toyota, Ford, Honda, Chrysler, Hyundai/Kia,  
            Volkswagen, Nissan, Mercedes-Benz, Suzuki, Mitsubishi, Volvo,  
            and Porsche.  Mazda, Subaru, and Harley-Davidson also provide  
            VIN-specific recall information on their publicly accessible  
            websites, but only after the vehicle owner enters contact  
            information and creates a website account. An auto dealer also  
            can access the website of a VIN-look-up service, such as  
            CARFAX, to find VIN-specific recall information. Finally, all  
            light vehicle manufacturers offer VIN-specific recall  
            information through their toll-free, customer service  
            telephone numbers." 

          Car dealers and consumers may also purchase vehicle history  








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            reports from private companies such as Carfax, which compiles  
            vehicle accident history information from multiple sources,  
            including the Department of Motor Vehicles, insurance  
            companies, and law enforcement.  Carfax also maintains a free  
            public website (recall.carfax.com) that allows consumers to  
            check for open recall information by VIN number for 39 major  
            manufacturers, if that information has been reported to the  
            company. 

           8)Recent changes in federal law on vehicle safety recall  
            information  .  In 2012, Congress enacted the MAP-21 Act, a  
            funding and authorization bill to govern federal  
            transportation spending that contains a provision requiring  
            motor vehicle safety recall information about outstanding  
            recalls to be posted online in a format that preserves  
            consumer privacy and is searchable by vehicle make, model, and  
            VIN.  The MAP-21 Act required U.S. DOT to promulgate  
            regulations by July 6, 2013 requiring each vehicle  
            manufacturer to provide vehicle recall information on a public  
            Web site and to car dealers.    

          On August 14, 2013, NHTSA issued a final rule that will require  
            all major manufacturers (those who produce more than 25,000  
            vehicles per year) to provide the public with online access to  
            recall information searchable by VIN and without requiring  
            additional information to allow consumers to instantly  
            determine whether action is required to address an uncompleted  
            safety recall.  This information will be required to be  
            updated at least weekly.  While many automakers already make  
            this information available, those who do not will be required  
            to comply by August 14, 2014.  

           9)Arguments in support  .  According to the sponsors, Consumers  
            for Auto Reliability and Safety, "This bill will improve  
            protections for Californian consumers, their families, their  
            passengers, pedestrians, and others who share the roads, from  
            used vehicles that are so unsafe, they are under a federal  
            safety recall.  According to statewide polling, an  
            overwhelming 88% of California 2014 voters support banning car  
            dealers from selling recalled used cars.

          "While some responsible, ethical dealers have instituted  
            practices to ensure that all used vehicles they sell to  
            consumers have had the safety recalls performed, others fail  
            to do so.  The impetus for this bill arises from the reckless  








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            practices of some auto dealers who fail to take easy steps to  
            ensure that the cars they provide to their customers are safe,  
            and have had any safety recall repairs completed.  As numerous  
            national and local news organizations?have reported,  
            California car dealers continue to sell, or attempt to sell,  
            unsafe, recalled cars to consumers.  

          "Are some safety recalls 'minor'?  No.  According to [NHTSA,]  
            'All safety recalls resulting from defects present an  
                                                                        unreasonable risk to safety and we believe it is inappropriate  
            to suggest that some defects are not risky enough to require  
            repair.  For the safety of the motoring public, all recalled  
            vehicles should be fixed promptly.'"

          According to Enterprise Holdings, Avis Budget Group, and Hertz  
            rental car companies, "[This bill] would require dealers to  
            comply with practices already adhered to by the rental car  
            industry for roughly 20,000 used retail car sales facilitated  
            by the undersigned companies in the state of California  
            annually."

          "As you know, each of the undersigned companies have for the  
            last several years voluntarily adhered to a policy whereby no  
            car will be rented that is subject to open safety recall  
            unless the necessary repairs have been made.  In addition,  
            these rental car companies are supporting federal legislation  
            being championed by U.S. Senators Boxer, Feinstein, McCaskill,  
            Blunt, Murkowski and Schumer to prohibit rental car companies  
            from renting vehicles that are under a federal safety recall  
            unless they have been repaired.  S. 921 passed the U.S. Senate  
            Commerce Committee unanimously and is expected to become law  
            prior to the conclusion of this Congress."

          According to the International Association of Machinists and  
            Aerospace Workers, "[This bill would] help protect the  
            motoring public, and will also create at least 1,000 new  
            good-paying jobs for skilled automotive technicians in  
            California, performing safety recall repairs on the millions  
            of vehicles that still have outstanding safety recalls  
            pending?There is no excuse for auto dealers to fail to ensure  
            that safety recall repairs are performed, prior to putting  
            their customers into a car, pickup, SUV, or van, whether the  
            vehicle is new or used."

          The Center for Public Interest Law and Children's Advocacy  








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            Center also writes that, "[T]he measure prohibits an auto  
            dealer from selling or transferring a vehicle that has  
            suffered an official notice of a defect.  Indeed, if there is  
            such a problem and the auto is then sold or loaned without  
            repair or even warning, the liability implications should lead  
            most prudent dealers to embrace this measure.  It does involve  
            the burden of monitoring defect notices. But these dealers are  
            in the business of selling this very product - one with  
            obvious safety implications not only for the purchaser, but  
            for those who may suffer collision with the vehicle. In  
            contrast, the average consumer is not in an advantageous  
            position to monitor these notices, particularly where they  
            occur in advance of his interest in a particular model car."

           10)Arguments in opposition  .  The Californian New Car Dealers  
            Association opposes this bill on multiple grounds, and writes  
            that, "Despite recent amendments, nothing about [this bill]  
            has changed from last year.  This bill has not been amended to  
            address any of the concerns raised by Committee members -  
            rental car companies are still excluded and there is still no  
            distinction between serious and minor safety recalls.   
            Furthermore, the [NHTSA] database is still not operational.   
            There is only one thing that is different since 2013:   
            President Obama has introduced federal legislation to address  
            the sale and rental of recalled vehicles.  The GROW AMERICA  
            Act is President Obama's $302 billion transportation omnibus  
            proposal to reauthorize funding?that is set to expire on  
            September 30, 2014?Unlike the fundamental flaw in [this bill],  
            both rental car companies and car dealers are included in the  
            President's proposal?California should delay any action on  
            [this bill] because anything approved by the Legislature will  
            be preempted by the President's proposal.

          "[This bill] wrongly targets all car dealers for a problem that  
            has been brought about by the rental car industry?Rather than  
            focusing on rental car companies, SB 686 targets every dealer  
            - regardless of how minor the recall is, or whether the part  
            is available.  While we believe a recall mandate is premature  
            since federal comprehensive legislation is pending, any  
            mandate whenever imposed should include both dealers and  
            rental car companies.  With the most recent amendments, [this  
            bill] moves further away from a comprehensive solution.

          "SB 686 is not just premature and unnecessary, but also poorly  
            conceived and ambiguous.  The bill fails to differentiate  








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            between minor recalls (stickers on window visors, verbiage in  
            owner's manuals) and major recalls (those that threaten  
            imminent danger to drivers and passengers), nor does it  
            account for the significant disruptions that occur between the  
            time when recalls are 'announced' and when parts and repair  
            procedures are made available to dealers.  Additionally, it  
            fails to adequately define key terms, specify when a dealer  
            must verify a vehicle's recall status, or provide any  
            protection for a dealer once an inquiry has been made.   
            Without providing any clear avenues for dealers to comply, SB  
            686 is fundamentally flawed."

          CarMax Auto Superstores Inc., also writes in opposition that,  
            "[This bill] is well-intended, but is significantly flawed as  
            currently drafted?Manufacturer's safety recalls should be  
            taken seriously by manufacturers, dealers, and consumers which  
            is why CarMax carefully advises its customers to register  
            their vehicles with its manufacturer as soon as they purchase  
            the vehicle so they can be apprised of any future  
            recalls?[NHTSA] issued a rule in 2013 which takes effect  
            August 2014 requiring all automakers to post on their website  
            a database of recalls which can be searched using the [VIN].   
            There are significant doubts throughout the industry that  
            NHTSA will meet its anticipated start date.  Even if it does,  
            a website only addresses part of the issue: notice [of] a  
            recall.  Without access to diagnostic equipment and parts, an  
            independent dealer like CarMax is not able to make the repairs  
            even when given notice.  Rather, CarMax is completely reliant  
            on a franchise dealer to perform the repairs on its behalf."    
             

          Independent Automobile Dealers Association of California also  
            writes in opposition, "Auto dealers are being targeted by  
            consumer attorneys at an ever increasing rate.  With no means  
            to absolutely prove that a dealer has been diligent and has  
            checked for a safety recall, [this bill] provides consumer  
            attorneys an additional item which they can use to file suit  
            against a dealer.

          "Currently, a dealer searching a manufacturer's website to  
            identify the presence or absence of a safety recall cannot  
            prove that he has performed the search as required prior to  
            sale.  Manufacturer's websites are not designed to print a  
            report, leaving a print of the screen shot the only option.   
            Those sites do not display a date or time stamp, which would  








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            prove when a dealer performed the search.  [This bill] would  
            penalize a dealer for not checking for or having a safety  
            recall performed when necessary but fails to recognize that  
            the proper tools for compliance are not available at this  
            time.  A single, VIN searchable database for all vehicle  
            manufacturer safety recalls is a solution which would enable a  
            dealer to search and retain proof."

           11)Comments and questions for the Committee  .  
          In light of the large number of safety recalls occurring every  
            year, opponents of the bill contend that there should be a  
            distinction between "major" and "minor" safety recalls, and  
            that "minor" safety recalls for things such as improper  
            labeling or changes to the owner's manuals should not prohibit  
            the sale of a used car sale to a consumer.

          Supporters, on the other hand, contend that all safety recalls  
            are in fact safety recalls that are based on safety risk to  
            consumers, and that distinguishing or second-guessing NHTSA's  
            determinations for whether a vehicle meets federal safety  
            standards is not wise public policy and does not address the  
            problem.  According to the GAO, less than 20% of safety  
            recalls are "compliance" recalls, or recalls for not meeting a  
            federal motor vehicle safety standard, which may include  
            seatbelt designs or noncompliance stickers.  

          As such, the Committee may wish to inquire of those opposing the  
            bill how they would distinguish "major" and "minor" recalls,  
            and what percentage of total recalls they believe are "minor"  
            in nature.  The Committee may also wish to inquire of  
            supporters and opponents as to the average length of time it  
            takes to repair a recall, and what percentage of safety  
            recalls can be repaired immediately, for example, by replacing  
            an improper sticker, and what percentage require a longer  
            delay due to availability of parts.  

          The Committee may also wish to ask how a dealer or a consumer  
            might proceed under the bill when a used car that is pending  
            sale is subject to a safety recall.  According to opponents of  
            the bill, if a recall campaign had a delay in getting  
            replacement parts, dealers would either have to hold cars  
            while they wait for parts or would have to turn away sellers  
            of recalled cars or purchase those cars at a lower price based  
            on the recall.  However, according to the sponsors, cars under  
            recalls like GM's ignition switch recall will likely already  








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            depreciate in value because of the recall itself, and if there  
            was a delay in getting parts, recalled car owners could sell  
            those cars in private party transactions, dealers could sell  
            those cars in wholesale transactions or out of state, or  
            dealers could choose not to purchase a recalled car that has  
            not been repaired or budget in the estimated time to fix the  
            car as part of the cost of doing business.        

          Opponents also argue that it is fundamentally unfair for the  
            bill to impose broad prohibitions on the sale of vehicle  
            dealers when rental car companies are permitted to continue  
            renting and leasing used vehicles without a similar  
            requirement to check for recall notices.  The author's office  
            asserts that rental car companies should be exempt for now  
            because they operate in a different and more complicated legal  
            framework (interstate commerce) than in-state sales, that  
            federal rental car legislation is currently pending and has  
            the active support of the rental car industry, and that the  
            rental car companies have in the meantime taken a pledge to  
            ground recalled cars.  Opponents also contend that this bill  
            is premature because the GROW AMERICA Act, which would address  
            both sale and rental of all vehicles subject to recall until  
            repaired, is pending, and that any action on this bill would  
            be preempted by this proposal.  
           
          The Committee may wish to inquire of the author and opponents as  
            to the likelihood of success of these federal efforts, and  
            whether or not it would be prudent to impose the prohibition  
            as it is in the bill's current form, or impose it on dealers  
            and rental companies alike, perhaps with an amendment  
            explicitly acknowledging the precedence any federal  
            legislation would enjoy related to recall requirements.   
           
           12)Double-referral  .  This bill is double-referred to the  
            Assembly Judiciary Committee, where it will be referred if  
            approved by this Committee.

           13)Related legislation  . AB 964 (Bonta) of 2013 would have  
            prohibited a vehicle from being advertised or sold if the  
            dealer knows or should have known that the vehicle is subject  
            to a manufacturer's safety recall, and would have required  
            written disclosure of specified problems with the vehicle. AB  
            964 is currently on the inactive file on the Assembly Floor.

           14)Previous legislation  .  SB 990 (Vargas) of 2012 would have  








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            allowed a car dealer selling a used car to obtain data from a  
            commercial entity, rather than the federal government, to  
            provide required information to consumers on the vehicle's  
            title history.  SB 990 was held in the Senate Transportation  
            and Housing Committee.

          AB 753 (Monning) of 2011 would have expressly prohibited a  
            rental car company from renting a vehicle that is subject to a  
            recall notice unless the vehicle has been repaired as  
            specified in the notice.  AB 753 failed passage in the Senate  
            Appropriations Committee.

          AB 1215 (Blumenfield), Chapter 329, Statutes of 2011, requires  
            new car dealers to participate in a program to electronically  
            title and register vehicles that they sell and to post  
            specified warning notices on some used cars.

          AB 68 (Monta�ez), Chapter 128, Statutes of 2005, enacts the Car  
            Buyer's Bill of Rights, which provided that a car dealer may  
            not advertise of sell as "certified" a used or pre-owned motor  
            vehicle unless specified conditions are satisfied, and further  
            provided that vehicles sold as "certified" may not be sold "as  
            is," or if the dealer has disclaimed any warranties.

          SB 114 (Bowen) of 2005 would have enhanced the process by which  
            attempts are made to notify an owner of a motor vehicle of a  
            required safety-related vehicle recall. SB 114 was held on the  
            Suspense File in the Assembly Appropriations Committee.

           REGISTERED SUPPORT / OPPOSITION  :

           Support 
           
            Consumers for Auto Reliability and Safety (sponsor)  
          Advocates for Highway and Auto Safety
          Avis Budget Group
            California Nurses Association  
          California Public Interest Research Group (CALPIRG)  
          Center for Public Interest Law/Children's Advocacy Institute 
          California Rural Legal Assistance Foundation 
          Consumer Action  
          Consumer Attorneys of California  
          Consumer Federation of California  
          Consumer Watchdog 
          Consumers Union 








                                                                  SB 686
                                                                  Page  16

          Enterprise Holdings 
          Hertz
            International Association of Machinists and Aerospace Workers
          National Consumers League
          SafetyBeltSafe U.S.A. 
          State Farm  
          Trauma Foundation 
           
            Opposition 
           
          California New Car Dealers Association  
          CarMax Auto Superstores, Inc.  
          Independent Automobile Dealers Association  

           Analysis Prepared by  :    Eunie Linden / B.,P. & C.P. / (916)  
          319-3301