I am the current president of the Northern Virginia Music Teachers Association (NVMTA), a local affiliate of the Music Teachers National Association (MTNA. NVMTA is a group of over 400 independent music teachers, the largest MTNA affiliate in the Commonwealth of Virginia, and one of the largest in the United States. I therefore feel compelled and obligated to respond to the proposed Settlement Orders associated with the FTC’s complaint against MTNA. The alleged violation related to the code of ethics provision states “the teacher shall respect the integrity of other teacher’s studios and shall not actively recruit students from another studio.” The proposed order settling the FTC’s charges requires the MTNA to stop restricting or declaring it unethical for members to solicit teaching work from other music teachers. However the purpose of this provision of the MTNA code of ethics was designed not to prevent competition among teachers, nor to keep prices artificially high. It was designed to protect the student. Music instruction in the private studio setting is similar to an apprenticeship. A student benefits most from several years of study with one teacher. Moving from one teacher to another every few months is not to the benefit of the student. However, during the various festivals and competitive events sponsored by NVMTA, students are often disappointed with their performances (as they are in other activities at this age). As professional teachers, we try to respect the children’s feelings and therefore we do not find it appropriate to actively recruit students when they may be vulnerable. This is not about restricting competition, but rather respecting students. In fact, NVMTA maintains an active website and referral service to assist parents and students in finding music teachers. This is open to new as well as existing students. And in fact, students often do change teachers. NVMTA does not have any restrictions on this occurring. We do not keep any records of changes, and the “gaining” teacher does not have to report or pay anything to the “losing” teacher. Students do change teachers for a number of reasons.• It is not uncommon that as a student ages and progresses musically, for them to change teachers, as no one teacher is right for all students. And some teachers, due to experience or size of studio or teaching style may be more suited for the changing student skills.• Likewise, as a student matures it is not uncommon for them to desire a different type of teacher, whether this is for personality or teaching style.• With this being Northern Virginia, transportation and logistics is always an issue and often parents/students will desire a change of teacher whose location or teaching schedule is more conducive to their changing lifestyles. In all cases, NVMTA resources are available to help students find the teacher that best suits their needs. Contrary to the FTC statement there is nothing in the NVMTA code or in practice that results in an “unreasonable restraint of trade.”The FTC appears to have engaged in an effort that both inappropriately interprets statute and potentially impairs the education of our students. This is because the FTC appears not to understand the mission of NVMTA and its emphasis on teaching students. In NVMTA no member, officer or chairperson, receives any compensation for their efforts to administer the organization and provide these opportunities for the students we serve. In my 24 years of experience with this association I am not aware of a single complaint being raised by any teacher regarding restriction of trade or competition, nor has any action ever been taken by the NVMTA against a teacher for “soliciting” students from other teachers. This FTC investigation has done nothing to facilitate competition among teachers. It has simply diverted the time and attention of the volunteer members of NVMTA from their true mission: helping children develop and grow through music.