Advocacy Filings

When government bodies and other organizations consider cases or policy decisions that affect consumers or competition, the FTC may offer insight and expertise to decision makers by filing an advocacy letter. To find a specific filing, use the filters on this page.

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FTC Staff Comment Supporting Michigan Senate Bill 268, And Recommending That the Michigan Legislature Consider Expanding the Bill To Permit Automobile Manufacturers To Sell New Motor Vehicles Directly To Consumers

Matter Number:

V150004

FTC staff submitted a comment, in response to a request from Michigan State Senator Darwin L. Booher, on the possible competitive effects of a legislation that would permit manufacturers of a category of vehicles, “autocycles,” to choose whether to sell directly to consumers, through dealers, or...

FTC Staff Comment Before the Federal Communications Commission On Public Notice DA 14-1700, Regarding the Issues Relating To Carrier Implementation of Call-Blocking Technology

Matter Number:

P034412

Docket Number:

CG Docket No. 02-278

WC Docket No. 07-135

FTC staff submitted a comment to the Federal Communications Commission (FCC) in response to a public notice seeking input on call-blocking. Staff stressed that consumers continue to be barraged by unwanted telemarketing calls, and that a large part of the solution is “call-blocking technology – i...

FTC Staff Comment Before the Department of Defense (DoD) on Proposed Amendments to DoD’s Regulations Implementing the Military Lending Act

Docket Number:

DOD-2013-OS-0133

The Federal Trade Commission filed a comment on the Department of Defense’s proposed amendments to its regulation implementing the Military Lending Act (“MLA”). FTC staff supports DoD’s efforts to implement strong consumer protections for service members, and gave their support for a number of the...

FTC Staff Comment Before the Commission on Dental Accreditation Concerning Proposed Accreditation Standards for Dental Therapy Education Programs

Matter Number:

V150000

FTC staff submitted a comment to CODA, in response to CODA’s request for public comments on the 2014 version of its proposed accreditation standards for dental therapy education programs. The comment urged CODA to finalize and adopt accreditation standards, which likely will benefit consumers....

Comment Filed by Jessica Rich, Discussing Voluntary Code of Conduct for Utilities and Third Parties Providing Consumer Energy Use Services

BCP Director Jessica Rich wrote a letter to the Federal Smart Grid Task Force, of the U.S. Department of Energy regarding their draft Voluntary Code of Conduct (VCC) for protecting consumer energy use data. She suggested three changes to the draft VCC. First, she suggested adding a requirement for...

Federal Trade Commission Staff Reply Comment to the New York State Public Service Commission on “Reforming the Energy Vision” Project

Matter Number:

V140012

The FTC staff submitted a reply comment in response to certain comments filed with the New York State Public Service Commission (NY PSC) regarding the proposal to authorize the establishment of entities known as Distributed System Platform (DSP) operators, which would be responsible for balancing...

Federal Trade Commission Comment Before the National Highway Traffic Safety Administration Regarding the NHTSA Proposed Rule Entitled “Federal Motor Vehicle Safety Standards: Vehicle-to-Vehicle (V2V) Communications,” and the Accompanying Report

The FTC filed a comment on the National Highway Traffic Safety Administration’s (NHTSA) advance notice of proposed rulemaking related to vehicle-to-vehicle communications. As the lead federal agency charged with protecting consumer privacy, the FTC in its comment expresses support for NHTSA’s...

FTC Staff Comment on Financial Crimes Enforcement Network’s Proposed Customer Due Diligence Rule for Financial Institutions

Matter Number:

P124402

FTC staff filed a comment on a Notice of Proposed Rulemaking published by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury, supporting the proposed Customer Due Diligence Rule. Among other requirements, the proposed rule would require financial institutions to...

FTC Staff Comment Before the Consumer Financial Protection Bureau Regarding the Use of Mobile Financial Services By Consumers and Its Potential For Improving the Financial Lives of Economically Vulnerable Consumers

FTC staff filed a comment before the CFPB in response to its request for information on the use of mobile financial systems by consumers and their potential benefits for the financial lives of underserved consumers. The staff comment highlighted consumer protection issues posed by mobile financial...

FTC Staff Comment Before the ERISA Advisory Council of the U.S. Department of Labor Regarding Pharmacy Benefit Manager Compensation and Fee Disclosure

Matter Number:

V140001

Staff submitted a comment containing information that may be useful to the Advisory Council on Employee Welfare and Pension Benefit Plans, regarding issues relating to PBM compensation and fee disclosure. The comment discussed prior FTC analyses relating to the Council’s general inquiry, and...

FTC Staff Comment Before the New Jersey General Assembly Regarding Assembly Bills 2986, 3096, 3041, and 3216, Which Would Create Limited Exceptions to New Jersey’s Prohibition on Direct-to-Consumer Sales by Manufacturers of Automobiles

Matter Number:

V140008

FTC staff submitted a comment, in response to a request from New Jersey Assemblyman Paul D. Moriarty, regarding four bills that each would permit, to varying degrees, some manufacturers to sell cars directly to consumers under limited circumstances. The comment concluded that the bills likely...

FTC Staff Comment Before the Missouri House of Representatives Regarding House Bill 1124, Which Would Expand the Current Prohibition on Direct-to-Consumer Sales by Manufacturers of Automobiles

Matter Number:

V140010

FTC staff submitted a comment, in response to a request from Missouri State Representative Michael J. Colona, regarding Missouri House Bill 1124. The bill would amend the Missouri Motor Vehicle Franchise Act, which prohibited franchisors of new motor vehicles from owning or operating a new motor...

FTC Staff Comment Before the Missouri House of Representatives Regarding Missouri House Bills 1481 and 1491

Matter Number:

V140009

Staff submitted a comment, in response to a request by Representative Jeanne Kirkton of the Missouri House of Representatives, regarding Missouri House Bills 1481 and 1491. HB 1491 would allow APRNs to assess and diagnose patients and order diagnostic and therapeutic tests and procedures, without...

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