The "Sharing" Economy: Issues Facing Platforms, Participants, and Regulators A Federal Trade Commission Workshop
Public Comment Related to #607: FTC to Examine Competition, Consumer Protection, and Economic Issues Raised by the Sharing Economy at June Workshop The responses below relate only to short-term rentals unless otherwise stated. They reflect the opinion of an inspected, licensed, and insured B&B and our experience with airbnb. In accordance with FTC Rule 4.9(c), 16 CFR 4.9(c), I explicitly request that all portions of my public comment be kept confidential and secure. They may be displayed in the public record as submitted by "Anonymous Innkeeper." Public Comment. There are advantages and disadvantages to both the airbnb model and existing B&Bs. However, none of comparisons matter if the consumer feels airbnb is a perfectly safe, quality way to travel. There was a comment made during the hearing that airbnbs are all mom-and-pops and therefore, should be exempt from inspections and taxes. Legit B&Bs are mom-and-pops too, and yet, we are subject to local and state regulations; inspections such those for food prep, laundry and bed bugs; and the burden of taxes and increased insurance coverage. With as large a business as airbnb has grown to be, it is obvious that our states are leaving income and public safety behind. Legit B&Bs are transparent with regard to contact information, why not airbnbs? All businesses including the mom-and-pops, should be required to be transparent with full name of lister/owner, address, email address, and phone number. Privacy does not come into play when you are selling a product. Rating systems and review policies vary based on the Online Travel Agents (OTAs) and the Community Market Place (CMP). Consistency across multiple sites creates trust in the property. In the sharing-economy, reviews are limited to the CMP where the property is listed. It is not apparent to the consumer that there are differences in methodologies between 5 stars on an OTA and 5 stars on a CMP. Why is it that one is hard pressed to find an airbnb listing rated at less than 4 stars? Unlike on CMPs, on OTAs such as TripAdvisor or BedandBreakfast.com, the ratings are the ratings. The scores from these site are not manipulated in anyway and are completely honest. One limitation of OTAs is that anyone, a guest or prospective guest, may review a property. On CMPs, the reservation requires confirmation before a review can be submitted-can the guest review the property before arriving and then cancel their reservation? If so, what happens to the review-is it removed? OTAs will only take a posting down if the guest or potential guest used a bad review as a threat. All OTA reviews are anonymous. Standardizing reputation management systems with transparency in ratings, the full name of the rater, and the methodologies used to calculate ratings is one way to remove prejudice from the systems. Take it one step further and offer businesses a site where owners could write guest reviews. In closing, Airbnb is in the process of destroying legitimate Bed & Breakfasts. In our industry we have already seen a marked decreased in bookings, more cancelations, more negotiating of rates by guests, and fewer B&Bs sold. In our state, B&Bs are one of the hallmarks of tourism. Our state B&B association currently has 121 members. In 2007 the year airbnb was established, we had about 350. The airbnb traveler is left exposed without the veil of consumer protection offered through B&Bs who are inspected, licensed and insured. The sharing economy should not be just about sharing rooms, it should also be about sharing information about the businesses, sharing consumer ratings honestly without manipulation, and paying the proper taxes and attaining the proper licenses so that our government infrastructure is maintained.