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.
CG Docket No. 02-278
WC Docket No. 07-135
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 proposed amendments, including the new framework for creditors to ensure that consumers entitled to the MLA’s protections are accurately identified, as well as efforts to stop creditors that evade MLA coverage while offering a substantially similar product to those products currently covered by the existing rule. FTC staff was concerned, however, about the proposal to give certain types of creditors, such as insured credit unions, limited or complete exemptions from the regulations. Staff was also opposed to the elimination of the requirement that information be disclosed “clearly and conspicuously.”
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. In a previous comment to CODA in December 2013, FTC staff commended CODA’s then-proposed standards as an important first step in encouraging the development of a nationwide dental therapy profession, and recommended revisions to portions of the standards that may have limited competition for dental services. Now that many of those concerns had been addressed, the FTC staff comment urged CODA “to finalize and adopt proposed standards without unnecessary delay, so that the development of this emerging service model can proceed, and consumers can reap the likely benefits of increased competition.”
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 addressed some recent questions directed to FTC staff by the Council.
FTC staff submitted a comment, in response to a request from Alderman Brendan Reilly of the Chicago City Council, regarding a proposed ordinance that would provide for the licensing and operation of transportation network providers (TNPs), particularly software applications that enable consumers to arrange for transportation services via personal vehicles. The comment stated that, if regulation of TNP services are warranted, regulation should focus primarily on ensuring the safety of customers and drivers and other consumer protection issues. The comment noted that some provisions may unnecessarily impede competition, and recommended that the City Council carefully consider the justification for and effects of such provisions. The comment also recommended that the city should more clearly allow for flexibility and experimentation in pricing.