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Comments on Proposed Rulemaking Regarding Unfair Market Trade Practices

Homeownership and Consumer

Comments on Proposed Rulemaking Regarding Unfair Market Trade Practices

Date Posted: 

This week, Community Legal Services submitted comments to proposed rules issued by Pennsylvania’s Office of Attorney General.  The rules seek to clarify Pennsylvania’s Unfair Trade Practices and Consumer Protection Law (CPL).  Fifty years ago, the General Assembly enacted the CPL to “even the bargaining power between consumers and sellers in commercial transactions, and to promote that objective, it aims to protect the consumers of the Commonwealth against fraud and unfair or deceptive business practices.”  Commonwealth by Shapiro v. Golden Gate Nat'l Senior Care LLC, 194 A.3d 1010, 1023 (Pa. 2018). 

CLS represents many low-income Philadelphians each year who are the victims of consumer scams and other deceptive practices.

The comments were submitted on behalf of CLS’s clients, along with several state and national organizations, including Community Justice Project, Consumer Federation of America, Consumer Reports, National Consumer Law Center, National Association of Consumer Advocates, Pennsylvania Chapter, Neighborhood Legal Services Association, Pennsylvania Legal Aid Network, PennPIRG, and Philadelphia Legal Assistance.

We strongly and enthusiastically support this rulemaking as it will help resolve perceived ambiguity in the statutory language of the CPL, provide greater clarity and certainty in the marketplace, and carry out the CPL’s defined statutory purposes to protect consumers from unfair methods of competition and unfair or deceptive acts or practices. 

The rule will also enable companies to conform more easily to lawful standards and practices as it more clearly articulates the marketplace rules that apply to all competitors, and will thwart bad actors that seek to reap greater profits by pursuing dishonorable tactics that may have previously been unclear as to their treatment under the statute.

The rulemaking can be found here:

Download our comments below.

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PDF icon comments on CPL rule.pdf1.2 MB