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I am very surprise that a car could be certified after a crash, but it may not have been...If I buy a CPO car from a dealer,and then let's say get involve in a crash and a year later trade it back in for an other car, my original car can still be sold as a CPO since the CPO warranty is transferable from one owner to an other. I have got to say though, one should always check the car history before buying, any dealer will give you a print-out upon request....
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