“Please don’t make me…I’ll do anything” (ten ways to make car-buying much easier)

  • Guest post by Nadine Ballard, esq.

After I recently purchased a new car, I found it odd that my friends responded by saying “Congratulations!  Good for you!” What exactly are they commending me for? Going into debt? Surviving the ordeal of negotiating with a car dealer?  We all know it is not a pleasant experience, so I suggest that the appropriate comment to a friend should be, “I’m sorry, I hope you survived the process without too much stress.” So let me tell you how I survived in the following ten (not so easy) steps:

First: Don’t be in a hurry. 

I waited until my 13 year old car had nearly 209,000 miles on the odometer, which necessitated finding and using a very reliable mechanic (I used cartalk.com which led me to the best mechanic ever!) This delay allowed me to save a good amount for a down payment, which truly helped me control the entire transaction. I wanted to purchase a late model used car, and would have used my reliable mechanic to do an inspection.  But when I got an offer on a new car that was a better price than a used model, I choose the new one even though I was extremely reluctant to step foot in a new car dealer showroom.  My daughter practically dragged me kicking and screaming to make that first test drive.  Without her this deal wouldn’t have happened. (Surviving the process means getting help from friends and family)

Second, compare different models; Go to three different dealers.

I downloaded the FREE app from Consumer Reports, which has a handy loan calculator that instantly tells you the MSRP and Invoice price* of any car.  This helps you figure out if they are offering a good deal. The Consumer Reports App also leads you to several other reliable websites that will help you determine the true value for your trade-in.  Since the free app doesn’t give you access to their Annual Car Buying guide, I went to my local library website and found free access to all Consumer Reports buying guides so that I could read about the cars I was considering. I was pleasantly surprised to find out that their test drive showed even better gas mileage than what was reported on the window sticker.  More importantly, Consumer Reports pointed out some issues that I needed to look for in my test drive and in my conversation with the dealer. 

* Don’t assume that getting a car at invoice price is a good deal – they can still negotiate thousands less than invoice price based on incentives from the manufacturer, kickbacks from financing companies, and other profit sources.

Third: Wait for the fall. 

I waited to the end of August, when dealers offer deals to get rid of their current inventory before the next year model arrives. When I saw one dealer offering $5500 off the MSRP on all 2015’s in inventory, I called another dealer to ask if they would beat that.  Of course they said yes! They gave me numbers over the phone which made the 2015 cheaper than the price of a one year old 2014 that I had just test-driven. So I took the bait and made an appointment with the Manager of the dealership. 

Warning: Inventory information on the Dealership’s website is unreliable.  It’s not updated timely and the features available on specific cars were not always accurate. If part of your research is looking on the dealer’s website, make sure to call them to verify what you find. Their website is designed to get you to “come on down!” – not to give you reliable information.

Fourth: Take the salesman along for the test-drive.

Although I was allowed to take a test drive without the salesman, I asked him to come along.  This gave us the opportunity to talk freely away from the showroom floor.  He taught me how “turbocharge” works and was honest about some extra maintenance costs for a diesel that would be required at 40,000 miles. At the other dealer I went to, the salesman spent time on his phone while I did a test drive, and showed no real interest in me or the car. It was such a drastic difference and showed me that dealers can make the experience almost pleasant with just a bit of friendliness.

Fifth: Look at the numbers. 

Once the test drive was done, I began to take control of the show by asking to talk numbers and carefully going over the contract terms.  Remember to go over both the numbers AND the words. Right away I saw the $250 “documentation fee.” I assertively stated that fee is optional (because it’s not legally required) and I insisted that it be removed. I compromised with a reduction in the purchase price because the manager claimed he couldn’t remove the fee from their preprinted contract.

Next, I told them it was a deal-breaker if they were going to ask me to sign a mandatory arbitration agreement.  It was not in the “Default” provision of the contract, where it usually is. On this particular form contract, on the front page, near the signature line there was an area called “Other Material Understandings and Integrated Documents” with three boxes that could be checked.  One of those would allow the dealer to insert a mandatory arbitration agreement. The manager agreed that we did not have to check the box! 

Right under that box was a statement that read:

JURY WAIVER: The purchaser and dealer waive and renounce the right under federal and state law to a trial by jury for any claim.

I quickly and firmly responded that I would NOT waive my constitutional rights just to buy a car! 

Editor’s quick class on Constitutional Law: Both the United States Constitution and the Ohio Constitution guarantee us all the right to have a jury trial in any civil matters. (which usually means “legal fights over money”)  Ohio uses the word “inviolate.”  So, the next time that someone tells you that if you are against Mandatory Arbitration you are “un-American,” ask them “What’s more American than a Jury Trial?”

I assured the manager that if he could negotiate the numbers on this contract, he also had the authority to change the words. It took a call to the owner of the dealership, but they finally agreed to let me cross it off.

Sixth: Talk about money.

It was time to talk financing. By this time, the manager had figured out I was calling the shots, so after I told him that I intended to get a loan through my own credit union, he acknowledged that if I had a good relationship with them I should use them.  (Even though he admitted that the dealership gets a kickback from the financing company when they arrange financing) He explained that the advertised .09% financing was only available as a choice between that reduced rate OR a cash rebate, and the cash rebate was a much better deal. 

Here’s where it’s good to get out your phone, use your calculator or the Consumer Reports App to start verifying numbers. Ask to see the current offer in writing, read the fine print and do the math to see if a higher rate of interest will cost more or less over the life of your loan than the total of the cash rebate.  Just showing the dealer that you are verifying his numbers helps set the tone that you are in control of the transaction.  At this point, they asked, but knew it was pointless to try to sell me any extras and I quickly said no to the extended warranty, gap insurance, and whatever else (I quit listening, and just repeated NO, NO, NO!!).

Seventh: Figure out what you can afford. 

Although everything I have read about buying a car warns you NOT to make decisions based on what monthly payment you can afford, once you’ve locked down the price, the rebates, the discounts and the trade-in value, you should figure out your down payment and the length of your loan based on how much you want your monthly payments to be. When you are arranging your own financing after you have picked out the car, you will need to decide at the dealership how much you intend to pay upfront as a down-payment, so they can prepare a final contract for you to take to your credit union.  We simply looked up the current interest rate on my credit union’s website.  They were very helpful in running the numbers to help me figure out how much to put down in order to keep my monthly payments reasonable during a 3 year loan. I would have preferred a two year loan, but the payments were too steep – so I made a mental note to talk to my credit union about ways to pay off the loan early.

Eighth: OEM parts. 

Anxious to complete the transaction, I left the dealership to head to my credit union and to my insurance agent. (Here’s where I made a mistake.  But I’m willing to blame the dealer for letting me leave without giving me the opportunity to read the terms of the manufacturer’s warranty, or giving me a copy as he is required to do –  before the purchase – under Federal law). It’s essential to look at the warranty for one really important reason: what it says about OEM parts.

What is an “OEM part?”  If you don’t know you may inadvertently VOID your warranty – so pay attention!  OEM stands for Original Equipment Manufacturer and it refers to parts that are made by the company that built the car.  MOST new car warranties require you to use OEM parts or your warranty will be voided.  The problem is: MOST insurance policies only cover payment for a collision repair facility to use NON-OEM parts. 

“So what?” you say.  “A part’s a part.” That’s probably true. Even more so when you’re at the shop and the clerk says “We can give you a flux-capacitor that is made by Toyota for $580 or we can give you one made by a private supplier for $259.”  Most of us will think about how much we’re saving and not about whether the warranty on our car will be voided when it breaks because of a part that is merely connected to the flux-capacitor.

Ohio law requires the insurance company to tell you when they give you the estimate for collision repairs that the use of non-OEM parts might VOID your warranty.  But, you have insurance, why should you make this kind of choice?  You have to decide between letting them void your auto-warranty or pay extra for OEM parts. (Sometimes a lot extra)  What can you do? When you call your insurance agent to add the new car onto your policy you should ask to pay the extra cost to get a policy that does pay for the more expensive OEM parts.  My agent told me it only costs an extra $7 per year, which is incredibly reasonable. After my new car warranty expires I can just drop the extra charge, because it won’t matter to anybody whether I use OEM parts or non-OEM parts.

Author’s reminder that you’re not quite out of the woods: My sister drives a Lexus SUV, and was involved in a rear ender last year.  The repair shop had to push the insurance company to approve the estimate with OEM parts, even though her insurance policy allowed for OEM parts!  One of the parts that had to be replaced was a simple 4 or 5 inch wide film (sort of like scotch tape) that was placed over the bottom of the back hatch opening to prevent scratching. The NON-OEM part was $27.00, the Lexus version (with the name Lexus on the tape) was over $300.

Ninth: Get your money elsewhere. 

Going to my credit union was a breeze. I am in a friendly place, they know me, give me free coffee and are happy to chat about stuff like the evils of auto-title loans. There, I am in my comfort zone, and happy to complete the transaction free from stress or a closing agent who is more concerned with loading up my loan with unnecessary fees. They don’t have to run a credit report (which is often unreliable…don’t get me started).  They already have my financial history and of course instantly approved my loan. I also set up automatic loan payments to coincide with my directly deposited paycheck, in an amount a little higher than the minimum payment because there is no penalty for paying it off early. It couldn’t be easier!  

By the way, I was also interested to learn that my credit union offers an open enrollment (you can sign up anytime) extended warranty that would allow me to use my own mechanic.

Tenth: Ask your insurance agent for a little discount action.

I stopped by my insurance agent, thinking it will take 5 minutes to have them drop the old car and add the new. Luckily, I had the time to chat with my agent, who wanted to run a few numbers and see what they could do to reduce my premium, which under the same policy would have gone up about $400 a year to add on the new car. After spending more than an hour there, she was able to reduce my annual premium, so I will actually pay less for the new car than I was paying for the old one! (She is the one who asked about the coverage of OEM parts, which made me realize my earlier mistake) 

Even though all those TV ads keep telling us to jump to the cheapest insurance company, my agent explained that loyalty discounts for sticking with the same company are far more important than a one-time discounted rate. My advice: Build a trusting relationship with your insurance agent and they will get you the best policy at the best price. (While you are there, ask about identity theft insurance – instead of paying hundreds of dollars a year to someone like Lifelock.  You can get the same coverage for about $15.00 a year through your homeowner’s insurance)

I am going to stop counting because I promised this was ten easy steps.  But, if you stop reading now, you’ll realize that I don’t have my new car yet!    

Next: Picking up the new car and dropping off the old.

I had to ignore the sad and guilty feelings I was having for giving away my old car and trading her in for a new model. I felt like I was trading in my old dog for a new puppy!  All I can say is “Get over it,” and focus on all the stuff you have to learn about the new technology in cars – plan on more than an hour to have your salesman train you how to use the Bluetooth technology, the fancy radio, the keyless system, and of course the “nav” (or navigation system).  My salesman promised that my first oil change was free (twice!) but I never saw anything in writing. 

BEWARE: Ohio law no longer requires a dealer to put all his promises in writing, so it’s your job to ask for something in writing to back up any promise.

When I got home, I spent hours reading the manual, watching instructional videos, and it took forever to re-program my garage door opener, but when it finally worked, I used the Bluetooth technology, found the right song on my phone, and the whole neighborhood heard me singing along with Helen Reddy, “Oh yes, I am wise, But its wisdom born of pain, Yes, I’ve paid the price But look how much I gained, If I have to, I can do anything,  I am STRONG, I am INVINCIBLE, I AM WOMAN!!!”

In summary, here is my list of tips:

  1. Put this off as long as possible: Find a good mechanic and save for a big down payment.
  2. Use the Consumer Reports App, and your library website free access to the Consumer Reports Buying Guide.
  3. Wait for end of the model year discounts, compare prices and get dealers to beat others pricing.
  4. Choose to have the salesman go with you on your test drive.
  5. Negotiate NUMBERS and WORDS – preprinted fees do not make them legally required, and never waive your constitutional rights!
  6. Do some math. Compare cost savings, calculate payments and say NO to add-on charges like extended warranties.
  7. Figure out what you can afford
  8. Make sure your new insurance policy covers OEM parts.
  9. Get financing through your own credit union.
  10. Get all promises in writing.

Posted by: Nadine Ballard (who is admired so much by Consumer Courage that he now has “I am woman” on his work PC’s Google search history)

“This year I PROMISE to…” (oh, spare us) Resolutions we can all follow

Consumer Courage on the first day of EVERY semester in college:

“This semester’s gonna be different! I’m going to every class…I’ll hit the library every night for AT LEAST an hour….I’ll make a review sheet every weekend…and I’ll read every page of every book that they give me”

Consumer Courage on the day before the finals of EVERY semester in college:

“Why didn’t I study more?  Next semester’s gonna be different!”

Editor’s note of backtracking to his parents:  Don’t worry.  I went to class.  I’m just saying these things for effect. (shhhh)

Unfortunately, most New Year’s resolutions last until about the second week of January.  Once we go back to work many of us forget the I’m-gonna-take-this-year-by-the-horns feeling that we had just a few weeks ago. 

    • “I’m gonna work out every day!” is replaced by “I’ve gotta hang my clothes SOMEwhere. Maybe they’ll fit on the treadmill?”
    • “I’m going to take a different good friend to dinner every week” becomes “I’m SO exhausted from work and that’s such a great new TV program…” 
    • The old favorite “I’m going to make some serious me-time” turns into “I’ve GOT to start getting to bed before midnight…”

In the spirit of making some resolutions you can stick to, here are some suggestions from Consumer Courage for you to consider as we melt into another New Year’s Eve.  This year, the self-help we pledge will be of the consumer and financial well-being nature:

  1. Make a budget and save (SOMETHING!)  This is really two separate ideas. Even if you are one of the lucky folks who don’t have to worry about stretching your pennies at the end of every month, you should have an idea of how much you NEED to spend and compare that with how much you WANT to spend – and what percentage of your income goes to each pile.  Take a month and write down where your cash is disappearing to.  Once you see how much you are spending on clothes, snacks, lunches, etc. you’re sure to change your habits. 
  2. Don’t get or use a credit card based on any rewards program or on the 20% discount you’ll get on that armful of gifts at the register!  (click here for the 10 worst credit card mistakes or here to see how that 20% discount could cost you some serious cash). 
  3. Switch to your local credit union and develop a personal relationship with your banker.   What’s the difference? Dig this article that compares banks and credit unions .
  4. Quit buying gift cards – it’s an easy (some might say lazy?) way to buy a gift.  But, 40% of gift cards that are purchased go unused, charge high fees, or have expiration dates that are unrealistic.  Why do stores love gift cards?  Because $1 Billion in GC value goes unused every year .  Which means that consumers are using gift cards to donate a Billion dollars to the retailers of America.  This year, make that donation to yourself.    
  5. Get your free credit report AND any other specialty reports that gather personal information about you, then take action to correct any mistakes that you find.  And, download the new brochure from Consumer Action about specialty reports.
  6. Get your kids interested in money management and keeping safe in the cyber-age (the FTC has some fun interactive games), encourage their schools to create a Lifesmarts team and enter competitions (or volunteer to be the Lifesmarts coach). 
  7. Rewatch the 60 minutes report on Data brokers selling our personal information then download the Disconnect software that they recommend. 
  8. While you’re at it, re-watch the 60 minutes report on Identity Tax Refund Fraud.  The story shows how con artists steal people’s personal information; file bogus tax returns under the victims’ names and get a big refund check.   They file as early as they can using all fake info (except for the stolen name and social security number) and trick the IRS into sending them a check for the giant refund.  When the victim files his return the IRS says “Gee that’s funny, we already gave you your refund.”  You’ll straighten it out for sure.  But, it will take months (at least) and cause you a bit of aggravation that you won’t soon forget.  File your tax return as soon as you possibly can!  This might just prevent some scammer from filing in your name and getting a bogus refund.    
  9. Read labels on food. Think twice before paying more for organic foods.  Ask yourself, why do I believe this label?  (many times, there’s no real difference between organic and non-organic) And terms like Natural, Local, Organic might not necessarily mean what you think.  
  10. Set up a system to pay all of your bills on time. Map out when your bills are due (each bill is usually due around the same time every month)  If you don’t already have a separate clean space in your house to put all of your bills when they arrive at your house – make one.  Whenever you sit down to pay the bills (once a week, until you get into a groove; once every two weeks once you have a system) look at your map of due-dates.  If the date arrives and you don’t see that particular bill in the pile – call the company, find out how much it is and pay it (just because you can’t find a bill doesn’t mean it’s not due).  While you’re at it, start something new with any credit card or bill that has a late fee OR an interest charge for past-due balances: Pay the minimum payment on the date those bills arrive.  After you pay the minimum put the bill into the “to be paid” pile so it goes into the rotation.  
  11. Plan for big expenses.  At some point in 2015, you will have an unexpected bill to pay that is hundreds of dollars (or more).  Is your dishwasher starting to leak?  Does the furnace sound like someone’s warming up a tank from World War II in the basement every time it kicks on?  Does your car eat oil?  These are all nature’s way of telling you that something’s wrong.  Start saving now juuuuuust in case one of those items decides to pass on during the next 12 months.  If you have money set aside, buying a new one will feel a lot less like a root canal, if you prepared even a little bit.  
  12. Take the financial power oath: (go ahead, raise your right-hand…..we don’t have all day) 

I [state your name]  will: 

    • NEVER take out a PAYDAY loan or an Auto-Title loan;
    • NEVER have my taxes done by any store that wants me to use my refund to buy something and NEVER pay anyone – other than a CPA – a dime to do my taxes (no matter how quickly I want my refund);  
    • NEVER pay someone to cash my paycheck;
    • NEVER pay money to anyone who calls me on the phone;
    • NEVER open any e-mail that promises to make me rich/make me money working from home/make me money as a secret shopper/help some foreign start-up “use” my bank account/or help the leader of an African Country move his fortune to the U.S.;
    • NEVER sign up for a credit card because they are offering me a free [anything] or so I can get a discount on whatever I’m about to buy;
    • NEVER give away my personal private information (even my email address) just to see if I have won a free coke or to register to vote for my favorite next singing star;
    • NEVER make any purchase over $250, until I research, compare prices and make an informed choice;
    • NEVER rely on customer reviews and remember that they can easily be faked or made by the place I’m buying from (or by one of their competitors);  And lastly, I will
    • ALWAYS – Pay attention to scam alerts. 

We’re sure that there are more things that you should do to be a safe consumer in 2015. Consider this a start.

Co-posted by: Nadine Ballard and Mark Wiseman (who always did his homework on time, went to class and was never worried during finals)

Is Yo Mama really ‘fiscally responsible’ by choosing Kmart layaway?

Kmart is running a new ad campaign, touting what they are calling ‘free’ layaway.  The commercial (which is hilarious) shows a group of elementary school kids trash talking about each others’ Mamas and how great they are, because they managed to buy cool items at Kmart. “Did your mama get that hoodie at Kmart?….Well your mama must have calories because that hoodie is sweet!” and the other kids all respond with “Whoa!”  The ad’s best line probably earned somebody a bonus. “Yo mama is so fiscally responsible she got all that on free layaway”……“Nooo!” It’s funny and has charm. It’s also not true. 

As we will see, Kmart’s layaway can be described in many terms.  But, ‘fiscally responsible’ and ‘free’ are not two of them.      

Maybe ‘Disclaimer’ is a better word to use

First of all, the offer is not open to everybody.  You have to join the ‘Shop Your Way’ program to qualify.  (Click here for the story of someone who tried ‘Shop Your Way,’ only to be given the old slippety-slip, when he tried to cash in his points.)  In fact, there are so many disclaimers connected to Kmart’s ‘Free layaway,’ that the press release announcing the start of the campaign actually came with footnotes! (SIX separate ones!)

The disclaimer that they actually put into the commercial flashes on the screen after 44 seconds.  It says:

Cancellation fees and exclusions apply. Valid on Layaway purchases ….. [until] 8/20. Requires down & biweekly payments. Service fee waived. All fees nonrefundable.  Not available in all stores. See store for details.

If you want to learn more about the terms for their layaway, you have to visit a website that is linked to the youtube video, where you will find details. 

Once there, you will find out that when you’re at Kmart, the word ‘FREE’ doesn’t mean what you think it means: 

    • It only applies if you enter into the layaway contract, between certain dates (in this case, only until August 20); 
    • You have to be a member of the ‘Shop Your Way’ club;
    • The FREE part only applies to the ‘service fee.’  It does NOT apply to the ‘cancellation fee,’ or other fees that Kmart is allowed to charge for regular layaway plans;
    • The offer is good except where it’s ‘prohibited by law;’

Consumer Courage is bothered by this commercial because – although they announce several times that the Layaway plan is FREE – it is more aptly described by the legal phrase: “NOT free.” (And, Consumer Courage wonders whether you should be allowed to call a 12 week layaway plan for a back-to-school item ‘responsible’, when school starts in about 5 weeks)

Layaway in a nutshell

Most people know that a ‘Layaway’ is when you agree to buy an item from a retailer, but let them hold onto it, while you make payments. When you finish paying, the item is yours…Simple, right? But what happens if you don’t pay the entire amount, will they refund your money? Here’s where myth and reality collide, as there are some quirky aspects to Ohio law which applies to Layaway plans that most people don’t know.

Is Layaway really a good idea?

Layaway sounds like a great idea.  If you can’t afford that Moss-covered-three-handled-family-gredunza  you’ve had your eyes on, you can still have it!  Just make partial payments to the seller, until you’ve paid the entire purchase price.  You’ll be saving the money, while the seller will pull that Gredunza from the shelves and agree not to sell it to anyone else, while you are paying.  The big question is: What are the risks that you’ll lose the money, if you aren’t able to pay the entire price?

In Ohio, there are two kinds of layaway contracts, depending on whether the item you are trying to buy costs more than or less than $500.  If it’s less than $500, there’s not much of a risk.  If you stop paying, you get a 10-day window to make up the missed payments.  If you can’t pay what you owe, you have the right to get back (almost) everything that you paid. The only money that the seller is allowed to keep for a small-ticket item is 10% of the value of the item or $25 – whichever is LESS. 

If the item costs more than $500 (a so-called ‘big ticket’ item), and you put it on Layaway, you’re risking a lot more than just twenty-five bucks. 

The good news?

When you layaway one of the big-ticket items, you have the right to get a written contract that must contain:

    • A schedule of payments;
    • The fact that you can cancel within 5 days of the start of the contract for a full refund;
    • A guarantee that if you stop paying, you can receive a due-bill for the amount you paid towards the purchase price of something else;
    • If you don’t get a written contract (or if the contract you get doesn’t follow Ohio law), the more friendly rules for a ‘less than $500 item’ apply 

The bad news?  The seller can:

    • Fee you to death on a layaway plan (as long as they put it in the contract). Ohio law allows any ‘reasonable’ charges, which means that they can charge you pretty much anything and get away with it, as long as they name the charge;
    • Really zing you, if you want cash back. If you can’t pay the whole amount and you want cash, instead of a due-bill, Ohio’s layaway law lets them rail you. If you insist on getting cash back, they can charge up to 50% of what you’ve paid to them, as long as they call them ‘fees’!

“Yo mama just broke Ohio’s Exclusions Rule!  Boom!”

Back to our Kmart commercial.  The biggest legal problems with this ad are found somewhere else in Ohio’s Consumer laws.  It appears to Consumer Courage that the ad violates two Consumer Protection rules. 

The first is referred to as the ‘Use of the word FREE’ rule.  Simply put, if a retailer has an ad that says something is FREE, it needs to actually be FREE.  If there are conditions that have to be satisfied for you to get that item for free, they need to say that in the ad.

The second rule is the ‘Exclusions Rule,’  which is supposed to keep us safe from retailers who make outlandish offers, while they have their fingers crossed behind their backs.  Imagine you see an ad that says “120 inch Plasma TV…..only $8.00!” and there’s a sentence that says “offer only good on Tuesdays in July, between 7:59 and 8:00 p.m., when the temperature is less than 45 degrees.” That last sentence has to be at least as big as the print in the rest of the ad. If not, the seller has violated Ohio’s Exclusions Rule.  Footnoted exclusions are not allowed either. If the ad is on TV or Radio, they have to state any exclusions, conditions or limitations right before, or right after the offer. Not at the end (like in our ad) and not in teeny print, close to the end (also in our ad).

Here are the fees that Kmart will stick you with, if you choose to lay something away:

    • Service Fee is $5 for all new layaway contracts.*
    • Cancellation Fee is $10 for all new layaway contracts.*
    • Down Payment is $15 or 10% (whichever is greater) and is collected when merchandise is put on layaway.*
      • * Except where prohibited by law, in which case the down payment would be less than that amount. See stores for state specific fee limitations. Down payment includes a $5 service fee for an 8-week contract. No partial cancellations are permitted. Cancellations can be made only in the store where you opened your contract.

The last two exclusions denoted by the star are interesting, because they both misstate your rights under Ohio law.  While they don’t define what a ‘partial cancellation’ is, Ohio law DOES give you the right to cancel your layaway contract at any time.  In addition, Ohio law does NOT require you to go to the store, where the contract was opened. That’s a retailer’s trick to make it harder on you to cancel.

An even bigger concern is that you have to go onto what Consumer Courage calls the ‘hyperlink merry-go-round’, in order to locate the contract and the various fees that go with it.  This is yet ANOTHER violation of the Exclusions Rule. (The retailer is required to give the consumer ‘obvious terms or instructions’ needed to locate the exclusions online and are supposed to make it easy to go ‘directly to the disclosed information’. )

Maybe we should all try a new kind of layaway.  I call it ‘Mattress Layaway.’  Put the money you want to save, in order to buy that awesome thing-a-ma-jig under your mattress.  Once you have enough, walk down to Kmart (or wherever you want to go) and pay them cash.  That way, you can back out any time you want and still keep all of your money.  The fees are much lower and when you’re strutting around in that new outfit you won’t have to hear:  

“Your mama can only afford to buy all of your clothes two sizes too small, because she spent so much on hidden Layaway fees at Kmart”……. “Boom!”

Posted by: Nadine Ballard and Mark Wiseman (who still gets just a teeny bit worried when he hears somebody utter the phrase ‘back-to-school shopping’)

2012, A Year in Review and what to watch for in 2013:

The Ohio Attorney General’s Annual Report for the Consumer Protection Section has been released, which leads us to question; Has 2012 been a good year for Consumer Protection in Ohio? Let’s take a look at the good and bad, and see what comes out on top! 


1) Ohio Supreme Court, in a 7-0 decision, sided with consumers to hold banks to minimum standards of due process, basically declaring that, in a foreclosure case, the banks must actually be able to prove that the promissory note had been assigned to them before they filed the foreclosure lawsuit.    

2) Neighborhood Housing Services of Greater Cleveland expanded its mission to include the “NHS Consumer Law Center”  – a welcome relief that somebody still cares about consumer protection in Ohio.

3) The Debt Settlement Bill did NOT get passed by the Ohio legislature.  Ohio already has a ‘Debt-Adjuster’s Act’  that protects consumers from outrageous fees and gives the Attorney General watch-dog powers over Debt-Adjusters. (‘Debt Adjusters’ are companies that help people who have too many bills that they can’t pay negotiate with their creditors).  This bill was an attempt to let certain companies operate outside of that act – which would have been very bad for consumers.  Good riddance to bad rubbish – Let’s hope it does not get resuscitated in the next legislative session.

4) The FTC (Federal Trade Commission) has a separate Bureau of Consumer Protection that has the mission of protecting consumers from fraud, deception and unfair business practices on a nationwide basis.   Since the beginning of the Obama administration, they have been more active than anyone at Consumer Courage can remember.  Click here for a (not entirely complete) list of a few of the major actions by the FTC’s Bureau of Consumer Protection, during 2012.    Having a Federal watchdog actually do its job, is certainly good for consumers.  Keep up the good work!

(Editor’s note: The increased efforts by the local regional FTC office to provide assistance to the advocate community and consumers of the region has been more obvious than ever before – especially with the pending arrival of National Consumer Protection Week starting March 4, 2013 – and is a welcome change from administrations past)

5) The Cleveland Plain Dealer still features a full time consumer reporter, Sheryl Harris,  who helps consumers resolve problems, highlights important developments in consumer protection legislation, litigation and industry self-regulation, and represents a much needed loud voice for consumer advocacy in Ohio.  I was particularly pleased to see some of her articles picked up by other newspapers in Ohio, and am proud of the PD for recognizing that consumer issues affect every member of our communities!

6) Social media and the internet are supporting some great blogs (including this one) to improve consumer education, which is often the only weapon we have to battle consumer fraud.  There are even a few “apps” designed to help consumers buy a new car,   finance a car, deal intelligently with car mechanics or fix it yourself,  and to find peer reviews and price comparisons.   

7) There are some great consumer protection lawyers in Ohio who continue to fight battles for their individual clients on a daily basis.  Most times, these advocates have to put their client’s victories ahead of their need for publicity, by agreeing to settlements that are confidential.  (Unfortunately, this means that we don’t usually hear about the results).  Anyone who spends a lifetime pursuing their dream of social justice knows that we are making an impact and changing the world when we help one person at a time.  I am confident more battles will be fought and victories won by the courageous few who embrace the “private attorney general” concept and use litigation to effectively fight fraud. 


1) Ohio’s Consumer Protection statute – The Consumer Sales Practices Act (CSPA) – was amended (some say diluted), as of July 3, 2012, to add a “cure offer” provision that takes away the consumer’s right to get enhanced damages and money for his own attorney fees under certain circumstances. What happened:  Because of this law the CSPA is now described by the NCLC as ‘one of the weakest consumer protection statutes in the Country.’  From now on, if consumers don’t accept the settlement offer made by the supplier right after they file their lawsuits, they might have to pay the fees the that the corporation’s lawyer charges to defend the suit.

• If the ‘cure’ offer is too low?; or
• If the offer to pay the consumer’s attorney fees (the new law contains a range) is too low?; or
• If the consumer suffers damages for inconvenience, embarrassment or anything that doesn’t involve lost cash?; or
• If the consumers want their lawsuits to stop the business from ripping somebody else off? …………………………..too bad! 

(Editor’s note: Curiously enough, the point at which the business has to offer the consumer a ‘cure’ is AFTER the consumer files his lawsuit, not before.  By lining it up this way, the legislature guarantees that the consumer will be inconvenienced as much as possible. If the ‘cure offer’ was to be made, BEFORE the lawsuit was filed, the consumer could skip the need to find an attorney and spend their valuable time preparing for a lawsuit, in the first place.)

So far, anecdotal evidence tells us that not too many corporate attorneys are using this new law (maybe because it makes no sense to settle the Ohio-based Consumer claims, when multiple claims based on other statutes and common law will remain pending).  But, the law has only been in effect for 6 months, so it may be too early to tell. 
What’s the Lesson:  If the legislature really wants to reform the law that is designed to protect consumers, it needs to listen and learn from consumer advocates who understand that litigation can and should be used to combat fraud in our state.

2) CSPA was amended (effective 9/28/12),  to remove certain Home Construction Repairs from the list of Consumer Transactions that were protected.  Now, there is a separate section of the Ohio Revised Code that will let contractors: get away with requiring more money up front; have a reduced risk of liability; and gain the ability to set their own standards.  Mark Twain once said ‘Those that respect the law and love sausage should watch neither being made.’  This new law looks more like sausage than any in a long time. 
Since there are still consumer protections for home-improvement contracts that cost LESS than $25,000, contractors actually have an incentive to make your repairs cost more.  Strangely, there is an exception for contracts of any price, where the contract is a so-called ‘Cost-plus’ contract.  Since home-repair contracts are almost never ‘cost-plus contracts’ (cost-plus contracts are most common in large defense contracts, such as when the government needs fighter-planes, battleships and tanks), it’s hard to understand why this provision is in the law in the first place.  But, if your home-improvement contract is a ‘cost plus contract’ you’d better watch out!  
Here are some troubling questions that are left open even after this bill became law:

• Will builders now have an incentive to add costs to the contracts to make the total over the $25,000 threshold?
• Will builders now try to make ANY home-improvement contract a ‘cost-plus’ contract to trigger the exemption and remove any consumer protections?
• Will the provision in the new law that allows contractors to adopt their own building standards make it harder for a consumer to show that the work was shoddy?

Lesson:  Now you need to get a lawyer to help you negotiate a contract for any home improvement, or you will discover that the builder can take most of the money up front and basically build whatever he wants.  Unfortunately, this law might just have taken away your rights as a consumer.

3) The ‘Puppy Mill bill’  was passed.  But, it contained unbelievably low standards for dog breeders.  Even worse – at the last second ALL consumer protection provisions in the bill were cut out.  (go to section 956.20  in this version that did NOT get passed, to see the Consumer protections that were removed by the House)
What happened: nearly every version of this bill included language that protected the consumers who purchased the animals, in case the animal contracted problems that were associated with being bred in a puppy mill. (Outrageous vet bills in the first year; buying an animal that looked to be OK, but was not, etc.)  The version that was adopted by the legislature and presented to the Governor, however, deleted any of the consumer-protection language, with no explanation why.
Lesson:  The legislature cares more about dogs than the people who own them.  Don’t take our word for it, though.  There are even some animal rescue operations that have a problem with the new law. 

(Editor’s Note: this sleight-of-hand is not uncommon with legislation when both houses and the Governor are from the same party.  When every version contains consumer protections, the advocates stop lobbying to keep consumer protections inside the bill.  Then, when the bill goes to the legislative committee for touch-ups, they remove all consumer protection language, and consumers are left out in the cold)

4) HB 322 passed (effective 9/4/12) to allow all banking institutions based in Ohio to increase the interest rates on revolving credit accounts to the highest rate allowed by any other state.  All we can say is: WOW! 
What happened: The limit on credit card interest rates for banks that have their headquarters in Ohio, which used to be 25% (which, itself is impossible to repay) was abolished.  Now, Ohio banks can charge an interest rate that is as high as the interest rate that is allowable in ANY State, which can be off-the-charts high. (such as this credit card that comes with a 79% interest rate!

Lesson: Consumers are even more on their own than ever before.  You’d better be careful what kind of interest rate your credit card has (either the initial interest rate or the nasty default interest rate)  And, making the minimum payment – ON TIME – to keep the default rate from kicking in is now more important than ever before.

5) The Ohio Dept of Commerce, and other watch-dog agencies continues to allow short term lenders to make payday loans, by taking advantage of a loophole in the laws that govern the short-term lending industry.  That they haven’t stepped in is even more shocking, when you consider that almost 64% of Ohio’s voters agreed to outlaw high interest rate PayDay loans in 2006; and at least two Courts have recently determined that PayDay loans are still illegal in Ohio.  Instead of being able to charge only 28% on a loan, these lenders continue to charge 400% interest.

6) In a recent development that is somewhat shocking (especially since the FTC has been very consumer-friendly, during the Obama administration. See: ‘Good for Consumers,’ above) the FTC proposed changes to the Used Car Rule  that do not keep pace with technology or the latest issues in car buying.  Those changes have been labeled as ‘…worse than the old one, blatantly false…misleading’ by a consortium of Consumer Groups.  

(Editor’s note: the FTC recently extended the public comment period for the new rule to March 13, 2013.  While such an extension doesn’t always signal an about face, it is entirely possible that the FTC is rethinking its position on this new rule, given the pushback that they have received from the Advocate Community.  Consumer Courage is holding out hope that more informed, consumer-friendly heads will prevail)

Any changes to the FTC’s used-car rule are very important to Ohio, because we don’t have any rules that regulate used car sales.  (or any law, for that matter, that is directed to the latest crazy lending scheme: car title loans). 

Other key actions to watch in 2013:

1) The Ohio Supreme Court will be deciding Sonya Anderson v. Barclays Capital Real Estate, Inc dba HomeQ Servicing, Case No. 2011-0908, (click here for a brief background on the case)  to determine if Mortgage Servicing is covered by the Consumer Sales Practices Act. Oral Arguments are set for 2/28/13 so watch for a decision in March or April.

2) Motions are pending in the Ohio Supreme Court asking them to review two key Court of Appeals opinions; one on time barred debt and Ohio’s borrowing statute, Jarvis v. First Resolution Mgt. Corp., Case No. 2013-0118,  and the other finding that payday lenders can’t use loopholes to charge exorbitant rates in Ohio Neighborhood Finance v. Rodney Scott, Case No. 13-0103.   It is interesting to note that the former Director of the Ohio Dept. of Commerce has already filed a memorandum in support of the industry, so don’t expect the State to stand up for consumers on that one!   Watch this blog for updates!
(Editor’s Note: Although the brief in support of the PayDay lending industry was filed by the former Director of the Ohio Department of Commerce, and not the current one, the skeptic in us thinks that having the former Director file a brief on behalf of an industry that charges shameful interest rates would be a great way to help that industry, without actually doing it yourself.  It is interesting to note that the current DoC administration has remained silent in this case.  We’re just sayin’….)

3) We need to watch how the lower courts are going to apply the victory in Schwartzwald. Take a look at recent court decisions in U.S. Bank, N.A. v. McGinn, 2013-Ohio-8,  where the court suggests a way around the new ruling!

Posted by: Nadine Ballard

Voting to give up your privacy – Interactive Ad campaigns for the Super Bowl

Is a free coke really worth the price of giving away your privacy?

The big advertisers (willing to pay close to $3.8 million for a 30 second spot during the Super Bowl)   are all raising the stakes this year by offering online contests during the game to get consumers to watch on TWO separate screens – (the second screen being your IPAD or other tablet device). They expect ¾ of the viewers to be viewing on “two screens”.   This year Coca-Cola wants consumers to engage in their advertising in an interactive way.  As a hook, they are offering a prize to the first 50,000 consumers who log in and create an account,   so they can pick their favorite team to win the “Coke Chase”; which is a fictional race by a group of cowboys; a group of show-girls on a tour bus and a group of bikers – who have evidently stolen the lost wardrobes from the Mad-Max film series – called ‘Badlanders’. They are racing through the desert in search of a certain carbonated cola. (We’re not joking)

So, what’s the harm in signing up for an on-line account anyway?

We’ve all done it.  Just before you buy that new gadget or sign up for a new promotion, you put most of your contact information into an application.  Then (before you can proceed) you are flashed to a screen with tons of tiny print and a box at the bottom that asks you to ‘Agree to the terms.’  Without thinking, you click ‘Agree’ and proceed.  What people don’t realize is that when they create an on-line account, they are giving the host-company permission to sell that information to anybody who asks.

Unfortunately, for the unsuspecting consumer, there is no law that prohibits the host company from sharing or selling your information to ANYbody for ANY purpose. In fact, to add insult to injury, the FTC’s telemarketing sales rule (which is the law that create the National Do-Not-Call Registry) considers the fact that you logged on to the advertiser’s website an “inquiry,” which means that for the next 90 days, you have waived your rights under the Federal DO NOT CALL law. Once you have ‘created your new ID,’ you have given the host company (Coca-cola, if you sign up for the ‘Coke Chase’) – and all of the companies that they sell your information to – permission to call, text, or send spam messages to you.

So what’s the prize that will entice you to give away your private information and waive your legal rights? [Drum roll please………] A free coke!!! Seriously? Is giving away your privacy really worth less than a $1.59 soft drink?

What other gimmicks are being used this winter to lure you in and cause you to make a formal ‘inquiry’ to these businesses that will allow them to sell your contact information?

 Budweiser wants you to name the new Clydesdale pony! (LOOK UP THE PRIZE FOR SIGNING UP)

 Doritos wants you to vote on one of five commercials in its “Crash the Super Bowl” contest – which allowed viewers to create their own commercial. o At least Doritos is giving away $1 million to the winner of its   But, of course only one person will win the Doritos contest.  (Everyone else will merely lose their privacy)

 Papa Johns is skipping the TV commercials this year, with a plan to concentrate solely on the second screen viewers by giving away a free pizza every 45 seconds, and a “chance” to win a $45 gift card. Hoping to sell a million pizzas on Super Bowl Sunday, if the game goes into overtime, everyone who has “registered” with them online will be eligible for a free pizza.

But, these contests beg the question: Is a free pizza or coke worth giving away your privacy?

Before you are lured into these gimmicks, watch this FTC video on Privacy Sharing, and read these tips from the Privacy Rights Clearinghouse   

Posted by: Nadine Ballard

You agreed to this (whether you know it or not)….Mandatory Arbitration Agreements

In trying to find some empathy for some of my friends who are so shocked at the recent election results, I can still conjure up my shock when I first read the US Supreme Court decision in AT&T v. Concepcion  in April, 2011, which essentially wiped out our constitutional rights to have any legal dispute heard by a jury of our peers. (Editor’s Note: In the Concepcion case, the U.S. Supreme Court gave its blessing to any company that wants to hide language in any consumer contract that says “I, the consumer, agree that the only way to have my dispute with the company heard is by a private arbitration company and not in a Court of law”)

Sure, Concepcion was about stopping class actions filed by large groups of consumers who all have small monetary claims (the suit was about charging $30 for a free phone), but when the highest court in our nation upheld a forced mandatory arbitration clause in a cell phone contract it sent a message to every business in America that they too could easily eliminate the risk of being sued. A year later, the National Association of Consumer Advocates released a study  revealing that, no surprise, arbitration agreements are everywhere,  “from health club contracts to cable television services to nursing home contracts;” and they are, effectively, suppressing consumer claims and denying us our day in court. Let’s compare this study, with the recent news releases from stopfraud.gov‘ (which is a governmental task force made up of 20 federal agencies, 94 US Attorneys Offices and state and local partners to investigate and prosecute significant financial crimes).  StopFraud.gov issues weekly reports of fraudulent schemes that have affected millions, and lawsuits and settlements involving billions of dollars, covering criminals and big corporations alike.  One example is the lawsuit the DOJ just filed last month in NY against Bank of America seeking over a $1 billion for mortgage fraud.

In an age when half the country wants ‘less government’, one avenue to reduce government spending might be to look for ways to allow more (not fewer) private lawsuits to attack fraudulent practices against consumers. So what can we do? Since the chances of getting Congress to pass The Arbitration Fairness Act, S. 987 and H.R. 1873, is next to nil, all we can do is take the matter into our own hands, and do one of the following:

1) Refuse to do business with any company that forces you to waive your rights (next to impossible as nearly every nationwide company does this); 

2) Read the contract and physically cross out the mandatory arbitration provision before you sign (there may not be a quicker way to have the salesman say ‘I’m sorry, we can’t do business with you’);

3) Timely exercise your right to opt out of a mandatory arbitration program (easy!- if you read the fine print and act quickly!)

Option #3 seems to be the new trend now – offering consumers the right to decide (for a very limited time frame) that they don’t want to be forced into mandatory arbitration (this is called an ‘opt out’ clause).  By offering this ‘opt out’ clause, companies seem to be in a stronger position, when they need to prove in Court that their mandatory arbitration provision was not really ‘forced’ or ‘mandatory.’ The catch is the small window of time given to consumers to exercise that right. In the Time Warner contract,  for example, you must exercise your ‘opt out’ rights within 30 days of the FIRST time you become a Time Warner customer. The ‘opt out’ ship for Time Warner contracts sailed a long time ago for me, but it’s not too late to opt out of a mandatory arbitration program recently announced by PayPal. Nearly everybody uses paypal for online shopping, so anybody who has ever used it should jump on this chance to protect themselves. One of my favorite consumer blogs, Consumerist has made it super easy to ‘opt out’ of the PayPal mandatory arbitration agreement by giving us a downloadable form.  All you need to do is download it, sign it, and get it in the mail and postmarked no later than Dec. 1, to:

Litigation Dept.
2211 North First St.
San Jose, CA      95131

It’s always a good idea to keep a copy of any letter you send, and to be extra careful, you might want to send the letter by ‘certified mail return receipt requested’ – so you have proof that they received it. New customers will have 30 days from the date you first accept the user agreement to send the opt out letter, so if you start using it this holiday season, add it to your list of New Year’s resolutions to follow up with that opt-out letter . Ebay recently adopted a mandatory arbitration program and also gave customers a 30 day window to opt out, but that deadline passed earlier this week.  Don’t let this deadline pass, ACT NOW!!

Posted by: Nadine Ballard

For the lawyers: OPIF searches, Consumer claims in B’cy cases, Sample Complaints

 I am teaching two seminars this fall on Consumer Law issues, which I hope will increase an interest in bankruptcy lawyers to pursue consumer law claims, and will encourage judicial officers to apply the law and award consumers appropriate statutory damages.  Friday, Oct. 26, I taught a program for the Ohio Judicial College entitled, CSPA Damages and the New Right to Cure. 

(EDITOR’S NOTE: The so-called Right to Cure (RTC) became law in July of 2012. Simply put, the RTC allows a business that violates the Consumer Sales Practices Act to do so on a daily basis without much worry.  They can ignore consumer-victims who have a complaint and force them to file a lawsuit.  Then, all they have to do is merely offer to pay the consumers out-of-pocket damages and ‘up to $2,500.00’ for their attorney.  If the consumer turns the offer down and gets less at trial, they lose the right to get reimbursed for Court costs, any subsequent attorney’s fees and treble damages.  The RTC also curtails the consumer’s right to obtain injunctive relief and/or rescind the contract.  These are all consequence that were put into the statute to prevent business from becoming repeat abusers.  In short, it changed Ohio’s Consumer Protection Statute from being one of the strongest in the County, to one of the weakest)

Part of the materials is a research tool I developed called the Top Twelve OPIF searches, which hyperlinks cases in the AG’s public inspection file for fast and easy retrieval. As we all know, the search function of OPIF is not great, and with the recent changes to the AG website, it’s not even easy to find OPIF on their website. If anyone wants a copy of the ‘Top Twelve OPIF Searches’ just shoot me an email and I will pass it along.

My second CLE program this fall is Nov. 20 for the American Bankruptcy Law Forum in Dayton. I am focusing on ten different topic areas that target debtors such as debt collection, debt management plans, predatory small loans (payday and title loans), foreclosure rescue scams, mortgage servicing abuse, job scams, credit repair scams and credit reporting issues.  I am including in the materials sample complaints of recently filed cases in each of these topic areas. In response to a public records request to the AG, I received copies of about 400 privately filed complaints filed in the past two years in Ohio (which I suspect is nowhere near the total number of cases being filed on behalf of consumers throughout the entire state).  The good news is that the most commonly litigated claim is against the companies that tout those crazy debt management plans that falsely promise to get you out of debt, fast, without filing bankruptcy! All of these plans violate Ohio’s Debt Adjuster Act, and many constitute the unauthorized practice of law, which should be prosecuted as a crime!  A recent court of appeals opinion out of the Fifth District, Bumpus v. Ward in favor of the consumer against a Debt Management plan, led me to a conversation with Plaintiff’s counsel, Jeremiah Heck, who verified that he has filed many of these cases and is successfully getting money back for consumers who fell victim to this scam.  If anyone wants a copy of his complaint, let me know and I will pass it along too!  

Please e-mail requests for materials from Nadine to: [email protected]

Posted by Nadine Ballard

Don’t click on that Spam!

Question for the day: Would you know when NOT to open an e-mail and click on the link inside? 

Would you respond to an email that listed the sender as “loanManager;;;” and a subject line that said:  “personal l0ans up to $1000///” ?

I must have clicked on the wrong link and I am suddenly inundated with spam email, offering me everything from medications from Canada, new windows, and an online dating service that will lead me to the man of my dreams.  I resent the time it takes to send them to my spam folder, but I wonder and worry “who responds to these emails?”  How desperate does a person have to be to click on an email that offers a quick $1000 loan, with misspelled words and misplaced characters, isn’t that a RED FLAG to stay away?

The real question is this:   Where does someone who needs money find a reasonable alternative to the ‘Loan Sharks’ that are operating legally in Ohio – payday loans, title loans, and internet based small loans from foreign states or even foreign countries with interest rates as high as 900%!  Take a look at the page on this website that helps you decipher the legal interest rate limit on different types of small loans and learn to ask for and read the fine print to make sure the interest rate is reasonable.

Because PayDay (and Quick Cash) lending is so harmful, Consumers must learn to: 

• Develop a banking relationship with a local credit union or a neighborhood community bank;
• Become familiar with and use the personal financial management tools that are necessary to create and live within a budget, and
• When they need to borrow money, seek financing from the local neighborhood banker who cares about their success. 

We have some great Credit Unions in the Dayton area (including Wright Patt Credit Union  which is doing some great work to help educate and protect our neighbors from abusive lending).  But we need to teach these skills to our children and get them on the right path at a much earlier age. 

 In 2007, the Ohio legislature passed the Predatory Lending Law Homeowner’s Equity Protection Act. (the Department of Commerce has a synopsis of the Act HERE.  For readers interested in an even shorter version, The Coalition on Homelessness and Housing in Ohio has one HERE)  

The Homeowner’s Equity Protection Act contained a little-known provision that created a 12-person board that was supposed to design a financial literacy program to be used in the Counties with the five worst mortgage rates.  The Board was also supposed to review various state agencies to make sure that they have policies and practices that: 

[A]ddress financial literacy, access by state residents to financial information, education, and resources, prevention of foreclosures and bankruptcies, and prepurchase and postpurchase counseling and education for homebuyers; Sec. 1349.72. (A) (1)

In fact, a certain percentage of fees for licensed lenders was to be set aside for funding these programs….At this point in the blog, I was going to tell you to call the Department of Commerce and ask them what this Board was doing to ‘promote financial literacy’ throughout the State –  When it meets; What programs it adopted; Which schools had financial literacy on their syllabus; How they were using the money that was being collected.  But, you can’t.  Because, in June of 2011, the legislature repealed the two sections  that created this Board in the first place.  Perhaps the better question is: Who thought that it was a good idea to stop educating the citizens in the five Counties with the worst foreclosure rates about financial literacy?

Posted by: Nadine Ballard