The "Sharing" Economy: Issues Facing Platforms, Participants, and Regulators A Federal Trade Commission Workshop
Thank you for reviewing my comment, which relates to consumer protection in the sharing economy. The primary risk to consumers is not being unprotected, but being unaware they are not protected. In lieu of overly restrictive limits on activity undertaken with the noble goal of protecting consumers, an alternative may be requiring aggressive, proactive disclosures of what is and is not protected -- in a standardized and easy-to-access format -- so that consumers can evaluate risks and arrive at their own conclusions. We utilize such disclosures in a number of other consumer protective situations. Nutrition Facts labels, credit card fee and interest rate disclosures, and cigarette health warning labels are examples that come to mind. In each case, disclosures are made in simple language, standardized formats, and large typefaces so that consumers may easily understand the possible ramifications of their consumption choices. I urge the Commission to consider a "warning label" approach to consumer protection in the sharing economy. Allow breadth of innovation but require aggressive risk disclosure. A set of published reporting standards -- perhaps as simple as a menu of allowable disclosures or a standardized consumer checklist of risks and advisories (where some checked and some unchecked) -- could go a long way toward consumers to make informed, comparative analyses while still allowing businesses to experiment with new business models. Thank you for your time and consideration.