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Grind all the paint off with 80 grit. I would then cut a flap that fully exposes the rusted area. Grind the rust away and prep it properly and then use the 2-part urethane rubber bumper repair stuff as a glue to hold the flap back down and clamp it in place.
I have done the same with Cuda rubber bumpers. They all had a habit of breaking off the sealed-in bumper bolts and you had to do similar surgery to replace the bolts.
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I have a couple of these and have never felt comfortable giving any of them to JUST anyone to fix.
With what you have offered, is this the best repair solution?
I have just never knew what was correct to fix these and it's processes to fix them.
Any other info that can be brought to light regarding this fix???