RVDA: Notices Required for FEMA Trailer Sales
RV dealerships have recently been investigated for failing to pass along a required federal disclosure certificate when they resell FEMA units, according to the latest issue of RV Executive Today.
The Recreation Vehicle Dealers Association (RVDA) reminded members that they are legally required to pass along the “Useable Travel Trailer Certificate” notice informing buyers that these FEMA units aren’t intended to be permanent housing.
The RV trailers that FEMA bought after Hurricane Katrina and auctioned off by the General Services Administration (GSA) require this special disclosure at the time of that sale and must be passed to all subsequent buyers.
Dealers should be particularly cautious of trailer trade-ins from 2005 and 2006 and the need to confirm the vehicles’ histories. A customer may “forget” to pass along the required disclosure to the RV dealer when trading in the vehicle for a new RV. RVDA said that the best way to research vehicle history is to run the VIN against the GSA’s database of Katrina trailers or ask the trailer manufacturer for a vehicle’s history.
Not all of the affected FEMA units are white boxy models – some were purchased directly from RV dealer inventory. RVDA said that relying on the vehicle’s title may not be reliable, since Katrina trailers weren’t titled until after their first sale at auction.
A similar issue is developing with oversized park model trailers that FEMA bought more recently and are now being auctioned through the GSA. Park models over 400 square feet must comply with HUD code, and as RVDA understands it, these oversized park models are not built to HUD codes. Customers may be unable to title these vehicles in their state, and they may run afoul of local building codes. Specifically, they may be unable to place these units in a zoned park model RV park.
All oversized compliant and non-compliant park models sold at GSA auctions come with a “Usable Park Model Trailer Certification” that the buyer must sign and pass along to all subsequent purchasers. The certificate disclaims government liability for any future issues arising from these vehicles. Dealers face liability if they fail to pass along the certificate.