The plaintiffs here advance two theories for recovery under G. L. c. 93A, § 9. First, they argue tha

MARSHALL, C.J. We consider in this case whether two consumers who rented worldpoker tour motor vehicles from the defendants, Enterprise Rent-A-Car Company of Boston, Inc., and Enterprise worldpoker tour Rent-A-Car Company worldpoker tour (collectively Enterprise), have stated a claim under G. L. c. 93A, § 9 (1), which permits an action by any person who has been injured worldpoker tour by another s unfair or deceptive act or practice. The rental customers contend that the collision damage waiver provision (CDW) in Enterprise s form rental contract violated G. L. c. 93A, because its terms failed to comply
with the requirements of G. L. c. 90, § 32E 1/2 , which regulates collision damage waivers in private passenger automobile rental agreements. [FN3] In the alternative, the plaintiffs argue that the CDW was sufficiently worldpoker tour unfair or deceptive as to violate Chapter 93A, irrespective of § 32E 1/2.
We conclude that, because the CDW did not cause the plaintiffs to suffer any loss, they have failed to satisfy the causation requirement of the injury provision of G. L. c. 93A, § 9 (1); proving a causal worldpoker tour connection between a deceptive act and a loss to the consumer is an essential predicate for recovery under our consumer protection statute. worldpoker tour We affirm the order of a judge in the Superior Court granting worldpoker tour summary judgment for the defendants, albeit worldpoker tour for different worldpoker tour reasons. [FN4]
1. Facts. The essential facts are not disputed. Enterprise is a national consumer automobile worldpoker tour rental company. On February worldpoker tour 3, 2001, Barry Hershenow entered into a contract for a one-day rental of a motor vehicle at Enterprise s West Newton branch. *792 The rental charge was $14.99. [FN5] Hershenow purchased optional collision damage waiver protection for an additional $14.99. In general terms, when a customer worldpoker tour purchases CDW, the rental company agrees to waive claims against the customer for any damage to the car during the rental period. Hershenow admits that his rental automobile was not involved in a collision nor otherwise damaged during the rental period.
On July 13, 2001, Dana Beaumier rented an automobile for three days at Enterprise s Somerville branch. The rental charge was $80. Beaumier too opted for CDW protection, at an additional cost to her of $47.97. Beaumier also admits that the automobile she rented was not damaged during worldpoker tour the rental period.
@ If Owner offers and Renter agrees to pay an additional fee for DAMAGE WAIVER, renter is relieved of any deductible on renter s policy, and an additional amount, the total of renter s deductible and the additional amount worldpoker tour will not exceed $1,000.00 . . . . Damage Waiver does not apply if the car is stolen, or if renter or driver fails to or refuses worldpoker tour to make a report of damages worldpoker tour to police or other lawful authorities, or to cover tire chain damages. A violation worldpoker tour of any provision of this agreement invalidates Damage Waiver (emphasis added).
worldpoker tour Pursuant to this last sentence, a violation of any provision of the Enterprise rental contract would purportedly cancel the CDW. This provision is contrary to the requirements worldpoker tour of G. L. c. 90, § 32E 1/2 , which permits rental companies to cancel worldpoker tour *793 CDW only as specifically listed in the statute. See § 32E 1/2 (C) (5). [FN7] Additionally, as applied to the CDW, many restrictions that Enterprise imposed on the use of its vehicles were inconsistent with other provisions of § 32E 1/2 . For example, § 32E 1/2 (C) (5) (e), permits CDW exclusion for damage incurred while an authorized driver is driving outside the United States or Canada, unless expressly authorized in the rental agreement, but Enterprise s form contract provided for exclusion if the vehicle was driven outside Massachusetts without Enterprise s written consent. See note 6, supra, (subsection [f]). [FN8] Enterprise characterizes its contract provisions that are contrary worldpoker tour to the Massachusetts statute as a mistake.
On November 21, 2001, the plaintiffs wrote to Enterprise pursuant to G. L. c. 93A, § 9, on their own behalf and on behalf of a class of other Massachusetts renters whom they sought to represent. [FN9] The letter demanded that Enterprise cease including the illegal CDW exclusions in future rental contracts, cease relying on those exclusions to deny CDW protection, and refund all CDW payments to each purported class member, with interest. worldpoker tour Enterprise responded that the contracts complied with G. L. c. 90, § 32E 1/2 . It nonetheless agreed to modify its rental agreements and remove the challenged language that a violation of any provision of this agreement invalidates Damage Waiver. They noted that the automobiles at issue had sustained no damage. Thus, asserted Enterprise, even if its CDW provision contained impermissible exclusions, the only customers who could have been injured would have been those who damaged *794 the rented cars and against whom Enterprise refused to waive its claims based on a reason not allowed [under Massachusetts law].
On November 21, 2001, the plaintiffs also filed this action in the Superior Court. Before the issue of class certification was addressed, Enterprise moved for judgment on the pleadings and for summary judgment. Mass. R. Civ. P. 12 (c), 365 Mass. 754 (1974). Mass. R. Civ. P. 56, 365 Mass. 824 (1974). The plaintiffs worldpoker tour also moved for summary judgment. A judge in the Superior Court ruled in favor of Enterprise on both motions, and judgment entered on August worldpoker tour 6, 2003. [FN10] The judge concluded that no private right of action worldpoker tour exists under G. L. c. 90, § 32E 1/2 , and that there is no right to bring a separate action for any violation of that statute under G. L. c. 93A. He entered judgment on the pleadings for the defendants. The judge also entered summary judgment for the defendants because there is no claim for private right of action under [G. L. c. 90, § 32E 1/2 ] or under [G. L. c. 93A], noting that he was not ruling on the merits of the motion. The plaintiffs appealed. We transferred the case here on our own motion.
2. Discussion. As noted, the Superior Court judge did not rule on the merits of Enterprise s motion for summary judgment. The judge did not, however, exclude any of the evidence submitted by Enterprise in support of the motion that was beyond the pleadings, and the amended judgment states that the judge considered the pleadings, depositions, answers to interrogatories, admissions, worldpoker tour and affidavits. We therefore consider the entire record on appeal. Mass. R. Civ. P. 12 (c). We will sustain the judge s ruling entering judgment for Enterprise if it is sound on any ground established in the record. Aetna Cas. Sur. Co. v. Continental Cas. Co., 413 Mass. 730, 734-735 (1992).
The plaintiffs here advance two theories for recovery under G. L. c. 93A, § 9. First, worldpoker tour they argue that Enterprise s violation of G. L. c. 90, § 32E 1/2 , constituted a per se violation of G. L. c. 93A, § 9. In support of this argument, they point to 940 *795 Code Mass. Regs. § 3.16 (3) (1993), worldpoker tour which provides that an act or practice worldpoker tour is a violation of § 2 of G. L. c. 93A, if it fails to comply with consumer protection statutes, rules, regulations, worldpoker tour or laws. [FN11] Second, they contend that Enterprise s CDW was unfair and deceptive within worldpoker tour the meaning of G. L. c. 93A, independent of any noncompliance with G. L. c. 90, § 32E 1/2 . [FN12]
Before we turn to the plaintiffs arguments, we address the defendants predicate argument that a violation of G. L. c. 90, § 32E 1/2 , may not be enforced in a private action under G. L. c. 93A. [FN13] The defendants maintain that, because G. L. c. 90, § 32E 1/2 (E), provides worldpoker tour for civil fines and a public enforcement action brought worldpoker tour by the Commonwealth, private relief for violations of that statute is not available. The plaintiffs counter that the absence of a private
We do not perceive a conflict between the two statutory schemes, nor do we perceive any clearly expressed legislative intent that G. L. c. 90, § 32E 1/2 , displace entirely any existing private remedies for deceptive practices concerning collision damage waivers in private passenger automobile rental agreements. Section 32E 1/2 was enacted in 1990, one year after a report by the National Association of Attorneys General (NAAG) detailed worldpoker tour nationwide abuses in the car rental industry, including the industry s use of high pressure sales tactics to *796 persuade consumers to purchase collision damage waivers. See Final Report and Recommendations of the National Association of Attorneys General worldpoker tour Task Force on the Car Rental Industry Advertising and Practices, 56 Antitrust Trade Reg. Rep. S-1, S-3, S-5, S-15 (Special Supp. Mar. 16, 1989). NAAG reported that some rental companies had sold damage waivers that were so unreasonably restricted as to be worthless, and that [c]ar rental contracts [were] not a useful source of information on either the extent of the consumer s liability or CDW. Id. at S-14. NAAG recommended that State Legislatures enact statutes to address these abuses. The Massachusetts Legislature promptly did so. [FN14] These events lead us to conclude that the Legislature s intent was to supplement, not curtail, existing consumer protections.
We infer that the absence of a private right of action in the 1990 legislation stemmed from the Legislature s knowledge that such a consumer right of action already existed pursuant to [G. L.] c. 93A, § 9, rather than from a desire to bar such actions. Dodd v. Commercial Union Ins. Co., 373 Mass. 72, 77 (1977) (G. L. c. 176D, which prohibits unfair or deceptive acts in the insurance industry, did not exclude application of G. L. c. 93A). See Ciardi v. F. Hoffmann-La Roche, Ltd., 436 Mass. 53 (2002) (Antitrust Act, G. L. c. 93, §§ 1-14A, did not infringe on scope of G. L. c. 93A). Contrast Cabot Corp. v. Baddour, 394 Mass. 720, 722-723, 725 (1985) (Uniform Securities Act intended to provide comprehensive regulation of securities field, and distinguishing Dodd v. Commercial Union Ins. Co., supra, where absence of private actions established that insurance field not comprehensively regulated); Reiter Oldsmobile, Inc. v. General *797