How to best engage with BCP and BE on economic analysis in BCP investigations
The FTC’s Bureau of Consumer Protection (BCP) is committed to providing legal clarity to legitimate businesses that wish to deal honestly with their customers and comply with the law. Last year, I shared how to work most effectively with BCP staff if your business receives a Civil Investigative Demand (CID), and the consequences that can result if businesses fail to cooperate. Now I’d like to address another integral part of responding to a BCP CID and engaging with BCP during an investigation: early and substantive engagement with BCP staff and, in cases in which the FTC is seeking monetary relief, the FTC’s Bureau of Economics (BE).