NHTSA Complaint #11714634 — 2020 FORD EDGE

Safety Defects and Mechanical Failures My 2020 Ford Edge (VIN: [XXX] ) is plagued by systemic safety defects that render it unroadworthy under Pennsylvania law (37 Pa. Code § 301.2).[1, 2] The 8F35 transmission suffers from a documented "shudder" and loss of motive power (TSB 21-2389), creating a high risk of collisions in traffic.[3, 4, 5] Additionally, the vehicle is subject to critical federal recalls: Recall 21S02 (21V-011) regarding sudden rear axle seizure [6, 7, 8] and Recall 20S49 (20V-550) regarding a lethal fire hazard from leaking transmission fluid.[9, 10, 11] The engine also exhibits a design flaw known as "coolant intrusion" (TSB 19-2346), which leads to catastrophic engine failure and hydro-lock.[12, 13, 14] ​Deceptive Trade Practices and Lender Liability CarMax sold this vehicle as "Quality Certified" without fulfilling the disclosure requirements mandated by the 2022 Multistate Attorney General Settlement.[15, 16] Specifically, CarMax failed to provide the required standalone, signed disclosure form for open safety recalls prior to the sale.[17, 18, 15] Because this transaction was financed through Santander Consumer USA, the lender is derivatively liable for CarMax’s deceptive acts under the FTC Holder Rule (16 C.F.R. § 433).[19, 2] This federal rule allows me to assert all legal claims and defenses against Santander that I have against CarMax, including breach of the implied warranty of merchantability, which overrides any "As-Is" disclaimer when a vehicle is sold in a non-roadworthy condition INFORMATION REDACTED PURSUANT TO THE FREEDOM OF INFORMATION ACT (FOIA), 5 U.S.C. 552(B)(6)