16 CFR Parts 2 and 4: Proposed Revisions to Part 2 and Rule 4.1 of the Commission's Rules of Practice, FTC File No. P112103
I completely concur with Commissioner J. Thomas Rosch's reasons for voting against the proposed revisions to the Part 2 Rules and Rule 4.1(e) as outlined in his Dissenting Statement dated January 13, 2012. The omission of the two reforms noted in his Statement, "mandatory compulsory process in all full-phase investigations and regular reports on the status of pending investigations to all Commissioners," could seriously hamper meaningful follow-through with investigations by the FTC. Furthermore, such reforms would strengthen transparency in all investigations by placing important process updates into the record.