In Wales v. Arizona RV Centers, LLC, 2015 WL 137260 (E.D.La. 2015), Judge Lamelle explained the scope of the FTC Holder Rule’s “Claims and Defenses” language in connection with the sale of a defective RV.

As the foregoing reveals, Defendant’s contentions as to the ability of buyers to assert affirmative claims against lenders under the FTC Holder Rule are contradicted by the plain language and history of the Rule itself. Accordingly, Defendant’s claims in this respect are without merit. The Court is further unpersuaded with regard to Defendant’s contentions that the language of the Louisiana Civil Code articles governing the implied warranty against redhibition limit application as between buyers, sellers, and manufacturers. While the Code articles might apply directly only as between such parties, the Holder Rule expressly makes applicable claims “the debtor could assert against the seller of goods.” Thus, the articles’ reference to buyers and sellers merely serves to emphasize that this type of claim falls under the express coverage of the Holder Rule. The FTC’s statements above pertaining to breaches of warranty and “sale-related claims” underscore this point. Defendant’s arguments to the contrary are without support in law and find no basis in inferential reasoning. While the Court concludes that the Holder Rule limits affirmative recovery to circumstances where the seller’s breach is so substantial as to warrant rescission, this is precisely the sort of claim brought by Plaintiffs in reliance on Louisiana’s law of redhibition in the instant case. As such, there remains no issue as to Plaintiffs’ ability to assert this form of claim against Defendants.