We bought a car at auction for resale specifically knowing it had frame damage and was disclosed on both the auction ticket and written on the windshield. Glass was coming out of the vents this thing had been smacked so hard and this was AFTER repairs were made. We pulled up a Carfax on it after disclosing the damage and it came up clean!
If you do use Carfax, be sure to register the vehicle you purchase immediately after the sale and Carfax will be stuck with it. What a scam.
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