Federal Trade
Commission
Congressional Budget Juscaon
Fiscal Year 2025
Fiscal Year 2025 Congressional Budget Justication
Table of Contents
Budget Request
Budget Request Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8
Needed Resources for FY 2025 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
Overview Statement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
Annual Performance Report For Fiscal Year 2023 and Annual Performance Plan For Fiscal Years 2024-2025
About This Report. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47
Strategic Goal 1: Protect the Public From Unfair or Decepve Acts or Pracces in the Marketplace . . . 49
Strategic Goal 2: Protect the Public from Unfair Methods of Compeon in the Marketplace
and Promote Fair Compeon. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 71
Strategic Goal 3: Advance the FTC’s Eecveness and Performance . . . . . . . . . . . . . . . . . . . . . 88
Descripons
Protecng Consumers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 111
Promong Compeon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 123
Support . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 129
Appendix
Proposed Appropriaons Language . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 143
Program and Financing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 144
Object Classicaon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 146
Personnel Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 147
Inspector General’s Request . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 148
Fiscal Year 2025 Congressional Budget Justication
UNITED STATES OF AMERICA
Federal Trade Commission
WASHINGTON, D.C. 20580
Office of the Chair
March 11, 2024
The Honorable Steve Womack
Chairman
Subcommittee on Financial Services and General Government
U.S. House of Representatives
Washington, DC 20515
The Honorable Chris Van Hollen
Chairman
Subcommittee on Financial Services and General Government
United States Senate
Washington, DC 20510
Dear Chairmen Womack and Van Hollen:
This letter transmits the budget justification for the Federal Trade Commission (FTC) in
support of the President’s fiscal year (FY) 2025 budget request.
The FTC’s FY 2025 budget requests a program level of $535,000,000 and 1,443 full-time
equivalent (FTE) positions. This is an increase of $105,000,000 from the FY 2023 enacted
appropriations level. As the justification materials describe, this budget will permit the FTC to
continue to meet the ongoing challenges of its mission to protect consumers and promote
competition.
By direction of the Commission.
Lina M. Khan
Chair, Federal Trade Commission
Budget Request
Fiscal Year 2025 Congressional Budget Justication - Budget Request8
Budget Request Summary
($ in thousands)
Fiscal Year 2024 Fiscal Year 2025 Change
Budget by Goal: FTE Dollars FTE Dollars FTE Dollars
Protecng Consumers 681 $216,663 699 $261,584 18 $44,921
Promong Compeon 707 213,337 744 273,416 37 60,079
Total 1,388 $430,000 1,443 $535,000 55 $105,000
Budget by Funding Source:
Oseng Collecons
HSR Filing Fees $304,000 $341,900 $37,900
Do Not Call Fees 13,000 13,000 ---
Subtotal Oseng Collecons $317,000 $354,900 $37,900
Subtotal Oseng Collecons
General Fund 113,000 180,100 67,100
Total $430,000 $535,000 $105,000
Fiscal Year 2025 Congressional Budget Justication - Budget Request
9
Needed Resources for FY 2025
The FTC is an independent agency that works to promote fair and open markets and protect the enre
American public from unfair or decepve business pracces. While primarily a law enforcement agency, the
FTC uses a variety of other tools to fulll its mission, including rulemaking, research, studies on marketplace
trends and legal developments, public outreach and engagement, and consumer and business educaon. To
maintain its high level of performance in FY 2025, the FTC is requesng $535,000,000 and 1,443 FTE. This is
an overall increase of $105,000,000 and an esmated 55 FTE above the FTC’s FY 2023 enacted appropriaon.
More specically this request consists of the following:
• Increase of $30,404,000 for mandatory expenses needed to support the agency’s exisng FTE levels at FY
2025 costs, such as costs to support the 5.2 percent pay raise in FY 2024 and an ancipated 2 percent pay
raise in FY 2025, costs for upward grade classicaons pursuant to C.F.R. 531.401 et seq., and correspond-
ing benet increases for each of these pay adjustments.
• Increase of $12,980,000 for 55 addional FTE:
• 20 FTE in the Bureau of Compeon to support:
◦ invesgang, challenging, and ligang ancompeve mergers and conduct,
◦ increasing the FTC’s enforcement capacity to challenge ancompeve pracces across markets
when warranted,
◦ processing and reviewing increasingly complex HSR merger lings and associated transacons,
◦ implemenng updates to the HSR pre-merger nocaon program, ,
◦ enhancing the FTC’s ability to understand quickly evolving technological issues implicated by its
casework and keep pace with ligaon demands.
• 10 FTE in the Bureau of Consumer Protecon to support:
◦ idenfying, challenging, and ligang unfair or decepve acts or pracces,
◦ increasingly complex consumer protecon invesgaons, including privacy and data security issues,
◦ addressing the role of emerging technology (e.g., Arcial Intelligence) in adversing and markeng
pracces,
◦ supporng rulemaking on a wide range of issues including junk fees, fake reviews, compliance
surveillance, and negave opons; and
◦ ensuring eecve monitoring of compliance with Orders and with Noces of Penalty Oenses.
• 3 FTE in the Bureau of Economics (BE) to provide increased support and economic analysis that guides
the Commission’s consumer protecon and compeon policies and enforcement.
• 9 FTE in the Oce of Technology (OT) to make a signicant investment in increased technical experse
and capacity to support the agency’s core mission and law enforcement invesgaons and acons
across consumer protecon and compeon in a rapidly digizing economy.
• 3 FTE in the Oce of Policy Planning (OPP) to provide more aorneys to support the agency’s 6(b) and
rulemaking authority and to support BC and BCP maers.
• 3 FTE in the Oce of General Counsel (OGC) to advise the Commission, Bureaus, and Oces on legal
maers such as jurisdicon, statutory authority, administrave procedures, and amicus briefs.
Fiscal Year 2025 Congressional Budget Justication - Budget Request10
• 6 FTE in the Oce of the Execuve Director (OED) to serve a variety of funcons, including hiring,
onboarding, and supporng a growing workforce, providing essenal services to support heightened
levels of enforcement work, and engaging in other crical operaonal iniaves such as implemenng
Informaon Resource Management (IRM) Strategic Plan iniaves, ensuring compliance with govern-
ment-wide IT mandates, opmizing the agency work environment, and improving data governance and
data-driven decision making.
• 1 FTE in the Oce of the Inspector General (OIG) to address increases in invesgave acvity under the
Inspector General’s jurisdicon.
• Increase of $61,616,000 for crical non-compensaon related investments:
• $32,000,000 for new oce construcon costs related to the FTC’s move from Constuon Center.
• $15,200,000 for expert witness contracts needed to support ongoing invesgaon and ligaon work,
changes and updates to the current security requirements and system infrastructure in the Consumer
Sennel Network, tech lab upgrades, and removing language barriers between the FTC and the public.
The increase also covers other non-comp costs such as travel, inaonary costs associated with the BCP
print program, and other inaonary cost adjustments.
• $11,000,000 for informaon technology costs related to increased cybersecurity, digital transformaon,
and operaons and maintenance costs.
• $3,416,000 for other non-comp costs aributable to the addional FTE requested, such as rent, uli-
es, security, IT equipment, soware/licenses, travel, training, and other inaonary adjustments.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
11
Juscaon for Programmac Increases
Bureau of Compeon
This budget reects an ongoing eort to right-size the Bureau of Compeon and the three regional oces
that perform compeon enforcement work, to accommodate marked increases in workload. The primary
drivers of the Commission’s increased resource needs are the high levels of market concentraon in major
economic sectors including healthcare, signicant merger acvity economy-wide, increased complexity of
proposed transacons, and the agency’s commitment to taking acon to protect the American public from
harmful acquisions and other ancompeve business conduct. Substanal merger acvity and signs of
market concentraon and related compeon concerns have dramacally increased the pressure on stang
resources in recent years.
Building upon recent stang increases, BC’s FTE request reects connued growth in the agency’s invesgave
and ligaon capacity to meet the increasing, broad-based ancompeve challenges in healthcare and tech-
nology markets, and beyond. This request also further expands the Bureau of Compeon’s regional presence,
ensuring that the three regional oces with compeon experse have sucient capacity to independently
conduct mulple signicant invesgaons and to support federal court or administraon ligaons without
reinforcements from other divisions. The Commission recently established the Bureau of Compeon’s
Ancompeve Pracces II Division along with the Western Region Compeon Group, a collaboraon
between the San Francisco and Seale regional oces, to enhance the Bureau’s capacity to invesgate and
challenge ancompeve business pracces in a broad array of industries. While pursuing this work, FTC sta
are severely outmatched by the resources that dominant rms can deploy, such that the number of aorneys
and experts working for defendants can outmatch FTC by ten to one.
In addion, the FTE request accounts for commensurate increases in specialized ligaon personnel, including
experienced ligators and ligaon support personnel, addional program support personnel to accommodate
expanded operaons, addional support for document producons and ligaon technology, and addional
sta for BC’s Premerger Nocaon Oce, which administers the HSR program on behalf of the FTC and the
U.S. Department of Jusce (DOJ).
While sta resources represent the bulk of the Bureau’s request, BC’s substanal workload generates various
other operaonal expenses. BC retains expert witnesses in support of invesgaons and ligaons. Expert
witnesses are a crical element of all antrust ligaons, where explaining complex market dynamics is essen-
al. These witnesses typically are highly skilled economists, business specialists, and other experienced indus-
try praconers who work hand-in-hand with FTC sta aorneys and economists to develop the analycal
support necessary to successfully challenge an antrust case and to rebut analyses conducted by defendants’
experts. It is commonplace for defendants in FTC ligaons to outspend the Commission by a signicant
amount on expert support, which oen results in FTC experts having to conduct more extensive—and thus
more costly—rebual analyses. This budget connues the agency’s eorts to more closely align the resources
available for expert witness support with actual ancipated expenditures for these crical services. This budget
also provides addional resources for travel, stenographic services, and sta development (the laer of which
will be crical as the Bureau connues to onboard a substanal number of new sta).
Bureau of Consumer Protecon
This budget would add sta to BCP’s division and regional oces for three main purposes. First, addional sta
would increase the FTC’s ability to not only combat perennial priority issues, but also invesgate and ligate
more and increasingly complex maers, such as those involving health privacy and children’s privacy; unfair
or decepve pracces by digital plaorms; frauds using new technologies in the areas of online and mobile
transacons; and harmful pracces in mullevel markeng and the gig economy.
Fiscal Year 2025 Congressional Budget Justication - Budget Request12
Second, BCP’s ligang divisions are currently engaged in rulemaking work, which would benet from addi-
onal personnel. For example, the Division of Adversing Pracces is developing potenal rules regarding the
harms caused by junk fees in the economy and combang fake reviews and other decepve endorsements.
The Division of Markeng Pracces is working on an Earnings Claim rule and exploring changes to the Business
Opportunity Rule. The Division of Privacy and Identy Protecon is exploring whether new rules are needed to
address potenal harms stemming from commercial surveillance and lax data security pracces. The Division
of Enforcement is engaged in click-to-cancel (negave opon) rulemaking and is updang the Energy Labeling
Rule, which would reduce energy costs for consumers and require manufacturers to provide consumers with
repair instrucons.
Finally, addional stang would help monitoring of compliance with orders, including iniaon of enforce-
ment invesgaons and law enforcement, as needed. Addional stang would help monitor compliance
with Noces of Penalty Oenses on issues such as misuse of consumer data by tax preparaon rms, false
money-making opportunity claims, fake review misrepresentaons by for-prot educaon instuons, and
unsubstanated health product claims.
Addional non-compensaon funding will be applied to crical BCP investments in the Sennel Network
Services (SNS) contract with Leidos, which covers the operaon of the Consumer Response Center (CRC), the
Consumer Sennel Network (CSN), and the Naonal Do Not Call (DNC) Registry. SNS supports the FTC’s con-
sumer protecon mission by assisng BCP with collecng millions of consumer reports annually from mulple
sources, including several public-facing websites, a consumer contact center, and more than 45 external
agencies and enes. These consumer reports cover a wide range of issues including identy the, crypto
scams, and telemarkeng fraud. The addional funding is needed to cover costs associated with changes and
updates to the current security requirements and system infrastructure in the Consumer Sennel Network, as
outlined in the Execuve Order 14028. The Execuve Order requires government agencies to adopt zero trust
cybersecurity principles and to adjust their infrastructures accordingly. SNS is one of several major systems
in the Agency and requires mulple enhancements to its security plaorm and infrastructure in order to be
compliant with the Execuve Order.
Addional non-compensaon funding is also required to cover rising expert witness contract costs as BCP
ligaons larger and more complex cases.
Addional non-compensaon funding will enable BCP to connue building out its language access to educa-
on and communicate with communies that speak languages other than English. The addional funding will
support the ongoing costs associated with a recent modernizaon project that will enable the CSN and the CRC
to take reports from and communicate with consumers in other languages, among other updates.
Finally, the addional non-compensaon funding is needed to cover cost increases associated with adding
FedRAMP cercaon to some of its requirements, to cover addional travel costs, and to cover cost increases
to BCP’s print program as the costs of paper, prinng, storage, and shipping have been steadily increasing. The
FTC’s print program works to help all audiences know how to spot, avoid, and report scams, with a parcular
focus on communies with limited access to the internet or that prefer to get their informaon on paper (for
example, older adults, veterans, and people with limited English prociency).
Bureau of Economics
Economic analysis supports the law enforcement and rulemaking acvies that the FTC undertakes to advance
its compeon and consumer protecon missions. Addional BE FTEs will be used to employ a larger number
of antrust economists to support the growth in BC acvies, including support for FTC merger and nonmerger
enforcement invesgaons and ligaon; compeon rulemakings; and mission-relevant research—including
merger retrospecve studies—to help the FTC focus antrust enforcement to maximize the agency’s ability to
Fiscal Year 2025 Congressional Budget Justication - Budget Request
13
maintain compeve input and output markets. Addional FTEs would also be used to increase the number of
stascians, nancial analysts, and research analysts, who work alongside the agency’s antrust economists to
support invesgaons, ligaon, rulemakings, and research.
The addional FTEs also will allow growth in BE’s ability to support the FTC’s consumer protecon mission.
Addional consumer protecon economists will help the agency assess the costs and benets of alternave
policy approaches; provide day-to-day guidance on rulemakings and invesgaons; enhance ligaon support;
and to ensure all consumer protecon acons taken by the Commission are consistent with, and informed
by, sound economic principles. Addional FTEs would also be used to increase the number of stascians,
nancial analysts, and research analysts, who work alongside the agency’s consumer protecon economists to
support invesgaons, ligaon, rulemakings, and research.
Oce of Technology
This budget connues to invest in the FTC’s in-house technological experse to ensure that the agency’s en-
forcement, policy, and research agenda keeps pace with a rapidly digizing economy. Especially with the evolu-
on of arcial intelligence, the FTC’s examinaon of complex market structures and of business pracces that
aect consumers, businesses and workers require a range of technical experse. Addional FTE in the Oce
of Technology (OT) will allow the agency to incorporate a greater range of technical experse and skillsets
into the agency’s law enforcement invesgaons and acons. Bringing on soware engineers, UX designers,
product managers, tech researchers, and subject maer experts who are deeply familiar with the mechanics
of evolving markets and business pracces will ensure that the FTC is beer posioned to understand market
realies more fully. In addion, the signicant increase to OT is a strategic investment in the agency’s ability to
ancipate technology-related market problems and address them swily. Addional resources will allow the
agency to engage in mely intervenon as it will have had the resources to be aenve to evolving business
pracces and emerging technologies. OT will act as a central resource to both BC and BCP and promote a more
holisc, interdisciplinary approach. Having this experse in-house will reduce reliance on external experts and
will build instuonal knowledge by having FTC employees work on these projects connuously.
Oce of Policy Planning
Addional FTE in OPP will allow the agency to incorporate a greater knowledge base and range of skillsets
into the agency’s work. OPP has a primary role within the FTC of supporng the FTC’s 6(b) authority. Under
the 6(b) authority, OPP researches specic industries or topics to bring a fuller understanding of that industry
or topic to the FTC. 6(b) studies demand signicant FTE resources to implement, carry forward, and dra.
These studies are one of the primary ways OPP can assist the Commission in developing and implemenng
long-range compeon and consumer protecon enforcement and policy iniaves and advise sta on cases
raising new or complex policy and legal issues. OPP connues to provide a crucial role in preparing advocacies
for the Commission and subming lings supporng compeon and consumer protecon principles to state
legislatures, regulatory boards, ocials, state and federal courts, other federal agencies, and professional
organizaons. Addional FTE will support this key pracce within OPP. Addional FTE will also support OPP in
reinvigorang the agency’s amicus pracce, which similarly helps the agency advocate posions that support
compeon and consumer protecon. OPP also needs addional FTE aorneys to support the principal role
OPP plays in developing ideas for public workshops as well as an expanded role in planning public hearings and
listening sessions. For both workshops and listening sessions, OPP can follow up by draing reports for either
the Commission or sta to issue. These reports provide forward thinking informaon for the public and can
contribute to signicant naonal and internaonal policy debates.
Fiscal Year 2025 Congressional Budget Justication - Budget Request14
Oce of General Counsel
OGC requests addional FTE to provide legal advice to the agency on a number of issues such as jurisdicon,
statutory authority, administrave procedure, condenality, congressional requests for informaon, rulemak-
ing proceeding, and ethics and employment law. The addional FTE will allow OGC to provide beer and more
mely advice and assistance on these legal issues, which will in turn allow the agency to beer carry out its
important missions.
Oce of the Execuve Director
The Oce of the Execuve Director (OED) requests addional funding to support the connued implemen-
taon of the FTC’s Informaon Resource Management (IRM) Strategic Plan, with a focus on cybersecurity,
digital transformaon, and operaons and maintenance of mission essenal IT systems and services. Specic
investments include the implementaon of a Zero Trust network architecture in accordance with OMB
Memorandum M-22-09, digital transformaon of FTC maer and informaon management processes, and
ancipated growth in FTC data processing and storage related to electronic discovery and merger review. OED
also requests funding for construcon costs related to the move from Constuon Center. Lastly, funding will
be needed to accommodate the proposed increase in FTE across the agency and the reliable infrastructure to
support the growing workforce to include network access and services, security, HR support and HC systems,
acquision support, and other essenal services.
Oce of the Inspector General
The Oce of the Inspector General (OIG) requests an addional FTE to provide the support required to co-
ordinate and discharge complex invesgave responsibilies and conduct legal and invesgave research for
established paerns and detecve trends in administrave misconduct or criminal acvies, thereby enhanc-
ing OIG’s ability to safeguard the FTC’s interests.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
15
Appropriaons Language Provisions
Federal Deposit Insurance Corporaon Improvement Act: The Federal Deposit Insurance Corporaon
Improvement Act of 1991 (FDICIA) amended the Federal Deposit Insurance Act. As originally enacted, the
FDICIA imposed various statutory responsibilies on the FTC that the agency did not have the resources or
experse to perform eecvely. Accordingly, since 1992, Congress, with Administraon support, has prohibited
the FTC from spending funds on some or all of the responsibilies assigned to it under secon 151 of the Act.
The requested appropriaons language for FY 2025 connues the spending restricon, reecng legislaon
enacted in October 2006, which maintains an appropriately narrow role for the FTC under secon 151. This
role enables the FTC to connue to enforce the provisions requiring non-federally insured depository instu-
ons to disclose that they do not have federal insurance and that the federal government does not guarantee
the depositor will get back his or her money, and retains the implementaon ban with respect to “look-alike”
provisions.
Other Provisions: The requested appropriaons language connues in eect provisions in prior- year appro-
priaon acts that: (1) allow for the purchase of uniforms and hire of motor vehicles; (2) allow for services as
authorized by 5 U.S.C. 3109; (3) limit to $300,000 the amount available for contracts for collecon services in
accordance with 31 U.S.C. 3718; (4) allow up to $2,000 for ocial recepon and representaon expenses; (5)
allow for the collecon of oseng fees; (6) allow for the gross sum appropriated to be reduced as oseng
fees are collected; and (7) allow all funding to be available unl expended.
Oseng Fee Collecons
This submission assumes that total oseng collecons from HSR ling fees and DNC fees will provide the FTC
with $354,900,000 in FY 2025. The FTC assumes the $180,100,000 dierence between oseng collecons
and the $535,000,000 request will be funded through a direct appropriaon.
HSR Premerger Filing Fees. This submission assumes oseng HSR fee collecons will provide the FTC with
$341,900,000. The HSR fee collecons are based on the ling fee structure implemented through the Merger
Fees Filing Act of 2022. These fees are authorized by secon 605 of Public Law 101-162, as amended eecve
February 1, 2001, in the FY 2001 Commerce-Jusce-State Appropriaons Act (Secon 630, Public Law 106-
553). The HSR Act requires that fees be split 50-50 between the FTC and the Antrust Division of the U.S.
Department of Jusce.
Do Not Call Fees. This submission assumes oseng collecons of $13,000,000 from DNC fees. These fees,
rst collected in FY 2003, will be used to maintain and enforce a naonal database of telephone numbers
of consumers who choose not to receive telephone solicitaons from telemarketers and to carry out other
Telemarkeng Sales Rule acvies.
Fiscal Year 2025 Congressional Budget Justication - Budget Request16
Overview Statement
Consumer Protecon: Highlights of FY 2023 Accomplishments
This scal year, the FTC connued to enforce the law against a wide variety of unfair and decepve pracces,
pursue policy iniaves to help safeguard Americans’ privacy and nancial security, and help educate consum-
ers and businesses throughout the country about how to protect themselves against scams and fraud.
Among other outcomes, the FTC’s eorts helped to protect privacy and data security for children, consumers,
and businesses; hold scammers and fraudsters accountable, parcularly as new generave AI tools help to
facilitate more sophiscated means of decepon; and protect consumers’ ability to know whether the prod-
ucts they purchase were made in the USA or abroad and to repair their purchases themselves or through an
independent repair service.
In FY 2023, the FTC led 43 complaints in federal district court and obtained 39 permanent injuncons and
orders requiring defendants to pay more than $193.8 million in consumer redress or disgorgement of ill-goen
gains. Defendants were also required to pay over $7.3 million under two civil contempt orders. In addion, cas-
es seeking civil penales, including cases referred to the Department of Jusce (DOJ), resulted in 22 court judg-
ments imposing more than $327.8 million in civil penales. The FTC issued 11 new administrave complaints
and entered 19 nal administrave orders requiring defendants to pay over $325 million. The agency also
reviewed compliance in over 370 maers, including nearly 2,000 defendants, issued 11 reports on consumer
protecon, and released more than 250 new and revised consumer and business educaon publicaons.
The FTC is commied to using the full extent of its authority to return money to Americans harmed by nancial
scams and fraud. In AMG Capital Mgmt., LLC v. FTC, the Supreme Court ruled that Secon 13(b) of the FTC
Act does not authorize monetary remedies, eliminang the agency’s long-standing and primary tool for ob-
taining court orders requiring wrongdoers to provide refunds to harmed consumers. In the wake of AMG, the
FTC has focused on other remedial powers—such as Secon 19 of the FTC Act and the FTC’s Penalty Oense
authority—to parally compensate for the loss of Secon 13(b) monetary relief authority. The FTC has also
undertaken rulemakings—including cracking down on decepve or unfair junk fees and combang decepve
or unfair review and endorsement pracces—that, if nalized, will serve as the basis for future enforcement
acons that can provide monetary relief to harmed consumers under Secon 19. While not a replacement
for the FTC’s ability to provide relief to consumers under Secon 13(b), these eorts allow the Commission to
connue obtaining court orders requiring violators to pay refunds to consumers harmed by wrongful conduct.
The FTC also has aggressively enforced its orders against repeat oenders, referring cases to criminal authori-
es as appropriate.
Consumer Protecon Law Enforcement and Policy Iniaves
The FTC Protects Americans from False and Decepve Adversing, Markeng, and Fees
• Operaon Stop Scam Calls: The FTC and more than 100 federal and state law enforcement partners, in-
cluding the aorneys general from all 50 states and the District of Columbia, announced a new crackdown
on illegal telemarkeng calls involving more than 180 acons targeng operaons responsible for billions
of calls to U.S. consumers. The joint federal and state iniave, “Operaon Stop Scam Calls,” is part of
the Commission’s ongoing eorts to combat the scourge of illegal telemarkeng, including robocalls. The
iniave not only targets telemarketers and the companies that hire them but also takes acon against
lead generators who decepvely collect and provide consumers’ telephone numbers to robocallers and
others, falsely represenng that these consumers have consented to receive calls. The eort also targets
Voice over Internet Protocol (VoIP) service providers who facilitate illegal robocalls every year, which oen
originate overseas.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
17
Operaon Stop Scam Calls includes ve new cases from the FTC against companies and individuals respon-
sible for distribung or assisng the distribuon of illegal telemarkeng calls to consumers naonwide.
• In a complaint led by DOJ, the FTC alleges Fluent, LLC and several related corporate defendants tricked
consumers into consenng to receive markeng solicitaons including telemarkeng calls in violaon
of the FTC Act, Telemarkeng Sales Rule (TSR), and the CAN-SPAM Act, which sets rules for commercial
email. Under a proposed order, Fluent will be required to pay a $2.5 million civil penalty and be banned
from engaging in, assisng, or facilitang robocalls.
• The FTC alleges that California-based Viceroy Media Soluons, LLC, which does business as quick-jobs.
com, and Voltron Interacve, and their sole owners Sunil Kanda and Quynh Tran, violated the FTC Act
and the TSR by assisng and facilitang millions of illegal robocalls while doing business as a telemar-
keng lead generator. Viceroy Media Soluons, LLC agreed to an order that bans them from helping
companies place robocalls and imposes a $913,636 civil penalty, which will be parally suspended
based on their inability to pay.
• The FTC led a complaint against telemarking company Yodel Technologies, LLC and its owner
Robert Pulsipher alleges they violated the TSR by calling millions of consumers whose numbers are
on the Do-Not-Call Registry and did not consent to be called. Under the proposed order seling the
complaint, Yodel and Pulsipher will be banned from parcipang in telemarkeng, either directly or
through an intermediary. It also imposes a $1 million civil penalty against them, which will be parally
suspended aer they pay $400,000.
• The FTC led a complaint alleging that New Jersey-based Vision Solar LLC; Solar Xchange LLC, which
also did business as Energy Exchange; and its owner, Mark Ges, violated the FTC Act, the TSR, and
Arizona’s Consumer Fraud Act and Telephone Solicitaon Act by making unlawful telemarkeng calls
on behalf of Vision Solar, a company that sells solar panels. Under the order seling the charges, Solar
Xchange and Ges will be prohibited from: misrepresenng that they are aliated with any ulity or
government agency; making unsubstanated claims regarding the cost of installing solar panels; and
engaging in abusive telemarkeng pracces. It also imposes a parally suspended civil penalty of $13.8
million.
• On behalf of the FTC, DOJ led a complaint against Miami, Florida-based Hello Hello Miami (HHM) and
Luis E. Leon Amaris, alleging that the defendants assisted and facilitated the transmission of approxi-
mately 37.8 million illegal robocalls by providing VoIP services to more than 11 foreign telemarketers.
In its complaint, the FTC is seeking to permanently bar HHM and Amaris from assisng and facilitang
illegal telemarkeng robocallers and obtain monetary relief for defrauded consumers, as well as civil
penales.
• Telemarkeng Robocalls Enforcement: The FTC implemented Project Point of No Entry (PoNE) to disrupt
foreign-based scammers and imposters responsible for blasng U.S. consumers with annoying and un-
wanted calls. Through Project PoNE, the Commission: 1) idenes point of entry VoIP service providers
that are roung or transming illegal call trac, 2) demands they stop doing so and warns their conduct
may violate the Telemarkeng Sales Rule, and then 3) monitors them to pursue recalcitrant providers, in-
cluding by opening law enforcement invesgaons and ling lawsuits when appropriate. The FTC can seek
civil penales and court injuncons to stop TSR violaons. It can also seek money to refund to consumers
who were defrauded via illegal telemarkeng calls. The FTC coordinates directly with the agency’s federal
and state partners, which support the program and pursue their own acons to ght illegal telemarkeng
robocalls.
On behalf of the FTC, DOJ led a complaint in federal court against Stracs Networks Inc. and its inter-
connected web of operaons responsible for delivering tens of millions of unwanted Voice Over Internet
Fiscal Year 2025 Congressional Budget Justication - Budget Request18
Protocol (VoIP) and ringless voicemail (RVM) phony debt service robocalls to consumers naonwide. One
set of lead generaon defendants agreed to sele the complaint in this case. The court order prohibits
debt relief lead generator KASM, also doing business as Kasm, Inc., and the company’s owner from making
the misrepresentaons alleged in the complaint and from violang the Telemarkeng Sales Rule (TSR). It
also requires the defendants to review the methods used by their exisng lead generators, determine if
leads were sold or oered to them illegally, and stop buying leads from any lead generator found to have
sold them such leads. Finally, the consent order imposed a $3.38 million judgment against the defendants,
which will be parally suspended based on their inability to pay.
The FTC sued to stop a VoIP provider, Xcast Labs, Inc., that connued to funnel hundreds of millions of ille-
gal robocalls through its network, even aer receiving mulple warnings. DOJ led the complaint in federal
court on the FTC’s behalf. According to the complaint, in January 2020, the FTC sent leers to a number
of VoIP providers, including Xcast Labs, warning them that assisng and facilitang illegal telemarkeng or
robocalling was against the law. The complaint also alleges that Xcast Labs received dozens of “traceback”
inquiries from US Telecom’s Industry Traceback Group regarding suspected illegal calls that originated on
Xcast Labs’ network, as well as inquiries from law enforcement agencies about transmission of suspected
illegal trac on the Xcast Labs network. Even aer receiving these direct warnings, the FTC alleges that
Xcast Labs transmied illegal robocalls to consumers.
• Illegal Telemarkeng Orders: As a result of an FTC lawsuit, American Vehicle Protecon Corp., the oper-
ators of a telemarkeng scam that called hundreds of thousands of consumers naonwide to pitch them
expensive “extended automobile warranes,” face a lifeme ban from the extended automobile warranty
industry and from all outbound telemarkeng. There are two separate court orders with the defendants.
In addion to the lifeme ban, the rst order includes a monetary judgment of $6.6 million, which is large-
ly suspended based on their inability to pay. The second order with Kole Consulng Group and its owner
includes a lifeme ban and a monetary judgment of $6.5 million, which is parally suspended once Daniel
Kole pays $500,000.
• Unsolicited Emails Selement: Experian Consumer Services (ECS) agreed to pay a $650,000 civil penalty to
sele charges it sent consumers unsolicited email without oering them a way to opt out of such messag-
es, as required under the CAN-SPAM Act. The order also prohibits ECS from sending markeng emails that
fail to oer a mechanism to opt out of such messages. The complaint was led by DOJ on behalf of the
FTC.
• Junk Fees Rule: The FTC launched an advance noce of proposed rulemaking to crack down on junk fees
proliferang throughout the economy. Junk fees are unnecessary, unavoidable, or surprise charges that
inate costs while adding lile to no value. Consumers can get hit with junk fees at any stage of the pur-
chase or payment process. Companies oen harvest junk fees by imposing them on capve consumers
or by deploying digital “dark paerns” and other tricks to hide or mask them. If nalized, a rule in this
area would allow the Commission to seek penales against rst-me violators or the ability to obtain
redress readily for consumers in instances in which fees violate the FTC’s prohibion on unfair or decepve
pracces.
• Social Media Adversing 6(b) Orders: With fraud on social media surging, the FTC issued 6(b) orders to
eight social media and video streaming plaorms seeking informaon on how these companies scrunize
and restrict paid commercial adversing that is decepve or exposes consumers to fraudulent health-care
products, nancial scams, counterfeit and fake goods, or other fraud. The orders, which the companies are
required to comply with by law, were sent to: Meta Plaorms, Inc.; Instagram, LLC; YouTube, LLC; TikTok,
Inc.; Snap, Inc.; Twier, Inc.; Pinterest, Inc.; and Twitch Interacve, Inc.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
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• Opioid Addicon Recovery Fraud Prevenon Act Order: The FTC took acon under the FTC Act and
the Opioid Addicon Recovery Fraud Prevenon Act (OARFPA), suing Michael J. Connors and companies
he controls for decepvely markeng their Smoke Away products as able to eliminate consumers’ nicone
addicon and enable them to quit smoking quickly, easily, and permanently. The case is the FTC’s rst
smoking cessaon product challenge under OARFPA, and its rst alleging the decepve use of tesmonials
to sell a supposed addion-treatment product. The proposed spulated order seling the Commission’s
complaint permanently bans Connors—who seled a 2005 FTC complaint regarding Smoke Away—and his
companies from markeng or selling any substance use disorder treatment product or service, including
any smoking cessaon product or service. The order also prohibits the defendants from making health-re-
lated adversing claims for other products unless they are substanated by competent and reliable
scienc evidence, prohibits them from using decepve consumer tesmonials, and imposes both a $7.1
million monetary judgment and a $500,000 civil penalty.
In another OARFPA acon, the FTC sued Dr. Dalal A. Akoury and a set of companies she controls that op-
erate as AWAREmed Health & Wellness Resource Center, a medical clinic, for making a wide range of false
or unsupported claims for addicon treatment services, cancer treatment services, and the treatment of
other serious condions. DOJ led the case on the FTC’s behalf. The court order bars Dr. Akoury and her
AWAREmed clinic from making such unsupported claims and requires her to pay a $100,000 civil penalty.
In a third OARFPA acon, the FTC sued the makers of Sobrenix, which was marketed to reduce and even
eliminate alcohol cravings and consumpon. The FTC alleges the marketers, a company called Rejuvica
and its owners, Kyle Armstrong and Kyle Dilger, made numerous unsubstanated and false claims about
Sobrenix, a liquid ncture made with a blend of kudzu root and other herbs and vitamins, and used paid
endorsers in decepvely formaed adversing. The defendants also used bogus review sites, including one
toung Sobrenix, to deceive consumers about their products.
• Right to Repair Orders: The FTC approved nal orders against motorcycle manufacturer Harley-Davidson
Motor Company Group, LLC, grill maker Weber-Stephen Products, LLC, and the manufacturer of
Wesnghouse outdoor power equipment, MWE Investments, LLC for illegally restricng customers’ right
to repair their purchased products. The FTC orders require the companies to x warranes by removing
illegal terms and recognizing the right to repair, and ensure that dealers compete fairly with independent
third pares.
• Decepve Adversing Orders: In an inial decision, the FTC’s Administrave Law Judge (ALJ) ruled that
Intuit Inc. (Intuit), the maker of the popular TurboTax tax ling soware, “engaged in decepve adversing
in violaon of Secon 5 of the FTC Act.” Specically, the ALJ found Intuit widely distributed numerous
adversements for TurboTax that “expressly or impliedly represented that the consumer-viewer would be
able to le their taxes online for free using TurboTax, when, for a signicant proporon of these consum-
ers, this was simply untrue.” Under the terms of the ALJ’s order, which the Commission will review, Intuit is
“prohibited from engaging in decepve pracces in the future.” It also is barred from represenng that any
good or service is free, unless: 1) it is free for all consumers; or 2) all the terms, condions, and obligaons
upon which receipt and retenon of the “Free” good or service are conngent are set forth clearly and
conspicuously at the outset of the oer so as to leave no reasonable probability that the terms of the oer
might be misunderstood. Further, if the good or service is not free “to a majority of U.S. taxpayers,” this
also must be disclosed in a clear and conspicuous manner. The order also prohibits specic misrepresenta-
ons by Intuit regarding the tax preparaon and ling services it oers, requires that the order be distrib-
uted to relevant pares for the next 20 years, and include strict recordkeeping and reporng provisions to
ensure the company’s compliance.
The FTC nalized a consent order requiring Ohio-based LCA-Vision Inc., doing business as LasikPlus and
Joe MediCenter, to pay $1.25 million for using decepve bait-and-switch adversing to trick consumers
Fiscal Year 2025 Congressional Budget Justication - Budget Request20
into believing they could have their vision corrected for less than $300. In reality, only 6.5 percent of
consumers lured in for consultaons were eligible for the adversed promoonal price for both eyes.
According to the FTC, despite the adversing claims, for consumers with less than near-normal vision
(good enough to drive without glasses), the company typically quoted a price between $1,800 and $2,295
per eye.
• Use of Consumer Reviews and Tesmonials Rule: The FTC proposed a new rule to prevent marketers from
using illicit review and endorsement pracces. Such pracces may include using fake reviews, suppressing
honest negave reviews, and paying for posive reviews, which deceive consumers seeking honest feed-
back on a product or service and undercut honest businesses. In its noce of proposed rulemaking, the
Commission cited examples of clearly decepve pracces involving consumer reviews and tesmonials
from past cases and also noted the widespread emergence of generave AI, which is likely to make it
easier for bad actors to generate fake reviews.
• Fake Reviews Order: Roomster Corp. and its owners, John Shriber and Roman Zaks, agreed to a selement
with the FTC and six state partners. The court-approved order permanently bans the defendants from
buying or incenvizing consumer reviews as part of a selement over charges that they bought fake re-
views to ence consumers to pay for access to living arrangement lisngs that they claimed were veried,
authenc, and available but oen turned out to be fake. In addion, the order includes a monetary judg-
ment of $36.2 million and civil penales totaling $10.9 million payable to the states. These amounts will
be suspended aer Roomster and its owners pay $1.6 million to the six states based upon the defendants’
inability to pay the full amount.
• Negave Reviews Order: Online shoe retailer Hey Dude, Inc. agreed to pay $1.95 million to sele FTC
charges that the company misled consumers by suppressing negave reviews, including more than 80
percent of reviews that failed to provide four or more stars out of a possible ve. In its Complaint, the FTC
also alleged that the company violated the Commission’s Mail, Internet, or Telephone Order Merchandise
Rule in several ways between 2020 and 2022. The proposed order would bar Hey Dude from future viola-
ons of the Mail Order Rule and prohibit the company from making misrepresentaons about consumer
reviews by requiring it to publish all reviews it receives, including reviews previously withheld from publi-
caon, with limited excepons related to moderaon of inappropriate content.
• Review Hijacking Order: The FTC acted against a marketer of vitamins and other supplements called The
Bounful Company (Bounful) for abusing a feature of Amazon.com to deceive consumers into thinking
that its newly introduced supplements had more product rangs and reviews, higher average rangs,
and “#1 Best Seller” and “Amazon’s Choice” badges. The case against Bounful marks the FTC’s rst law
enforcement challenging “review hijacking,” in which a marketer steals or repurposes reviews of another
product. The FTC alleged that Bounful carried out this decepve tacc by merging its new products on
Amazon with dierent well-established products that had more rangs, reviews, and badges. The order
requires Bounful to pay $600,000 as monetary relief for consumers, prohibits Bounful from making
similar types of misrepresentaons, and bars the company from using decepve review taccs that distort
what consumers think about its products or services.
• Endorsement Guides: The FTC nalized an updated version of its Guides Concerning the Use of
Endorsements and Tesmonials in Adversing (Endorsement Guides), which provide agency guidance to
businesses and others to ensure that adversing using reviews or endorsements is truthful. The revised
FTC Endorsement Guides strengthen and clarify guidance for adversers and address emerging market
trends. The FTC also issued an updated version of a guidance document that answers frequently asked
quesons about the Endorsement Guides.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
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• Decepve Endorsements Orders: The FTC nalized consent orders against Google LLC and iHeartMedia,
Inc. seling allegaons that they produced and aired nearly 29,000 decepve rst-person endorsements
by radio personalies promong the personalies’ use of and experience with Google’s Pixel 4 phone in
2019 and 2020. The nal orders approved by the Commission sele the allegaons and bar Google and
iHeartMedia from similar misrepresentaons. Separate state judgments also require them to pay a total of
$9.4 million in penales.
• “Click to Cancel” Rule: The FTC proposed a “click to cancel” provision requiring sellers to make it as easy
for consumers to cancel their enrollment as it was to sign up. The noce of proposed rulemaking is part
of the FTC’s ongoing review of its 1973 Negave Opon Rule, which the agency uses to combat unfair or
decepve pracces related to subscripons, memberships, and other recurring-payment programs.
• Dark Paerns Orders and Ligaon: Vonage Holdings Corp., an internet phone service provider, agreed to
pay $100 million in refunds to consumers harmed by the company’s acons, make its cancellaon process
simple and transparent, and stop charging consumers without their consent. The FTC alleged that the
company used dark paerns to make it dicult for consumers to cancel and oen connued to illegally
charge them even aer they spoke to an agent directly and requested cancellaon.
In an acon against Amazon.com, Inc., the FTC led a Complaint charging the company with engaging in a
years-long eort to enroll consumers into its Prime program without their consent while knowingly making
it dicult for consumers to cancel their subscripons to Prime. The FTC alleges that Amazon has knowingly
duped millions of consumers into unknowingly enrolling in Amazon Prime. Specically, Amazon used
manipulave, coercive, or decepve user-interface designs known as “dark paerns” to trick consumers
into enrolling in automacally-renewing Prime subscripons. The FTC also alleges that consumers who
aempted to cancel Prime were forced to navigate mulple steps to accomplish the task of canceling.
As a result of an FTC lawsuit, Publishers Clearing House, LLC (PCH) agreed to a proposed court order
that will require it to pay $18.5 million to consumers who spent money and wasted their me and make
substanal changes to how it conducts business online. The FTC charged that PCH used dark paerns to
mislead consumers about how to enter the company’s well-known sweepstakes drawings and made them
believe that a purchase is necessary to win or would increase their chances of winning, and that their
sweepstakes entries were incomplete even when they were not. The FTC also charged that the company
has added surprise shipping and handling fees to the costs of products, misrepresented that ordering is
“risk free,” used decepve emails as part of its markeng campaign, and misrepresented its policies on
selling users’ personal data to third pares prior to January 2019. Many consumers aected by these
pracces are older and lower-income.
• Business Opportunity Rule: The FTC launched an advance noce of proposed rulemaking seeking com-
ment from the public on a number of quesons related to the rule, including the need for the rule, its
benets and costs to consumers and to industry, the level of compliance with the rule, and any changes
that should be made to the rule, including any pracces or types of business opportunies that it should
cover. The noce also sought comment on whether the rule be expanded to include coaching or mento-
ring programs, e-commerce opportunies, investment opportunies, or other types of business or mon-
ey-making opportunies.
• Business Opportunity Enforcement: At the request of the FTC, a federal court temporarily shut down a
business opportunity scheme that lured consumers to invest $22 million in online stores, using unfounded
claims about income and prots. The operators of Automators also claimed to use arcial intelligence
to ensure success and protability for consumers who agreed to invest with Automators. The FTC alleges
that the vast majority of Automators’ clients did not make the promised earnings or even recoup their
investment.
Fiscal Year 2025 Congressional Budget Justication - Budget Request22
• Decepve Earnings Claims Orders: The FTC took acon against DK Automaon LLC, related companies,
and their principals for using unfounded claims of big returns to ence consumers into moneymaking
schemes involving Amazon business packages, business coaching, and cryptocurrency. The defendants
agreed to a court order requiring them to turn over $2.6 million to be used to refund consumers harmed
by their decepon, as well as requiring them to stop their decepve earnings pitches and follow the law.
The FTC alleged that the defendants promised consumers that they could “generate passive income on
autopilot” when in reality, few consumers ever made money from these schemes.
Kyle Dennis, a supposed stock trading “guru” for RagingBull.com, agreed to an order that permanently
enjoins him from making further false earnings claims or other false or misleading markeng claims. In
its complaint, the FTC alleged that Dennis pitched bogus stock ps that cost consumers more than $40
million. The FTC’s complaint further alleged that Dennis pocketed more than $13.6 million personally from
the scheme. Due to the Supreme Court’s ruling in AMG Capital Management v. FTC, however, the FTC
was unable to seek money that Dennis earned from the scheme to provide refunds to the consumers he
harmed.
The FTC took acon to stop Lurn, a Maryland-based online business coaching seller, from making unfound-
ed claims that consumers can make signicant income by starng an array of online businesses. In October
2021, the company received Noce of Penalty Oenses from the FTC about earnings claims that listed
specic acts and pracces that violate the FTC Act, but even aer receiving that Noce, Lurn connued
decepvely selling its programs. According to the complaint, thousands of consumers purchased tens of
millions of dollars in programs from Lurn. The company, its CEO, and two spokespeople agreed to court
orders that will require them to stop their unlawful pracces and require Lurn and its CEO to turn over
$2.5 million to the FTC to be used to refund money to consumers they harmed.
• Real Estate Scam Order: The FTC nalized a consent order against Opendoor Labs, Inc. designed to pre-
vent the online real estate business from deceiving consumers about how much money they could save by
selling their home to Opendoor, as opposed selling on the open market. The order requires Opendoor to
pay $62 million, which is expected to be used for consumer redress; prohibits it from making the decep-
ve, false, and unsubstanated claims to consumers about how much money they will receive or the costs
they will have to pay to use its service; and requires it to have competent and reliable evidence to support
any representaons made about the costs, savings, or nancial benets associated with using its service,
and any claims about the costs associated with tradional home sales.
• Pyramid Schemes Order: A federal court sided with the FTC, ruling that James D. Noland, Jr. illegally
owned and operated two pyramid schemes, Success By Health (SBH) and VOZ Travel, in violaon of the
FTC Act and that Noland violated a previous federal court order barring him from pyramid schemes and
from misrepresenng mullevel markeng parcipants’ income potenal. The court’s ruling permanently
bans Noland, his wife Lina Noland, Sco Harris, and Thomas Sacca from any parcipaon in mul-level
markeng. The ruling also imposes a $7.3 million judgment on Noland, Harris, and Sacca, the full amount
sought by the FTC. Any amount recovered by the FTC will be used to redress consumers.
• Health Products Compliance Guidance: The FTC issued “Health Products Compliance Guidance,” the
agency’s rst revision of its business guidance in this area in nearly 24 years. The revised business guide
represents a substanal update to the sta’s 1998 guide, “Dietary Supplements: An Adversing Guide
for Industry.” Since that guide was issued, the FTC has brought more than 200 cases challenging false or
misleading adversing claims for dietary supplements, foods, over-the-counter drugs, and other health-re-
lated products. The revised guide draws on those cases with 23 new examples. One major revision is to
extend the guidance covering dietary supplements to all health-related products. Among other things,
the new guide includes a much more detailed discussion of the amount and type of evidence needed to
Fiscal Year 2025 Congressional Budget Justication - Budget Request
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substanate health-related claims, with more emphasis on the fact that the FTC, as a general rule, expects
high quality randomized, controlled human clinical trials.
• False or Decepve Health Claims Order: ZyCal Bioceucals Healthcare Company, Inc. and its principals
agreed to an order barring them from making claims that their products grow bone and carlage and
relieve joint pain unless supported by randomized controlled clinical trials. The order also bars them from
providing anyone else with the means to make false or misleading claims. The FTC previously seled with
another corporate defendant, Excellent Markeng Results, Inc., and its principals.
• False or Decepve COVID-19 Related Claims Enforcement: The FTC took acon against California-based
Precision Paent Outcomes, Inc. and the company’s CEO for markeng an over-the-counter dietary sup-
plement containing nothing more than vitamins, zinc, and a avonoid as an eecve treatment to migate
the eects of COVID-19. In its complaint, the FTC is seeking to permanently stop the company and its CEO
from using decepve treatment or prevenon claims with no supporng scienc evidence to sell their
dietary supplement.
At the request of the FTC, a federal court issued an order permanently banning defendant Frank Romero
from oering for sale or selling any protecve goods or services, aer granng the FTC’s moon for
summary judgment. The order also includes two monetary judgments against Romero, who has done
business under the names Trend Deploy and Uvenux. The rst judgment is for $989,483.69, to be returned
to consumers harmed by Romero’s violaons of the FTC Act and the Commission’s Mail Order Rule. The
court also entered a second civil penalty judgment of $2,562.21 for Romero’s violaons of the FTC Act with
regards to the COVID-19 Consumer Protecon Act. The FTC alleged that Romero preyed upon consumers’
fear of COVID-19 by adversing the availability and quick delivery of PPE, including N95 facemasks, even
though he had no basis to make those promises.
The FTC brought lawsuits against Eliza Johnson Bacot, Lauren Busch, and Dr. Tina Wong, three current and
former high-level distributors—so-called “Wellness Advocates”—of the Utah-based mul-level markeng
company doTERRA Internaonal, LLC. The FTC alleges the distributors, all current or former healthcare
praconers, made false claims that the company’s essenal oils and dietary supplements could treat,
prevent, or cure COVID-19 in a series of webinars in early 2022 and touted their medical experse in rec-
ommending the products. Each of the defendants agreed to court orders requiring them to pay a $15,000
civil penalty, to stop making unfounded COVID claims, and to back-up any health claims.
The operators of an alleged grant scam called Grant Bae that targeted minority-owned businesses will
face a permanent ban from grant-wring and business consulng services as a result of a lawsuit brought
against them by the FTC and the State of Florida. The order against Treashonna P. Graham and C Lee
Enterprises includes a monetary judgment of more than $2 million, which is parally suspended due to
an inability to pay. An addional selement with one relief defendant contains a monetary selement of
$115,000, which is fully suspended due to an inability to pay.
In Blessings in No Time (BINT), the operators of a “blessing loom” investment program that targeted
African Americans and people struggling nancially during the COVID-19 pandemic agreed to a selement
banning them from the business of mul-level markeng as a result of enforcement acons taken by the
FTC and the State of Arkansas alleging they operated an illegal pyramid scheme. In addion to the perma-
nent ban, the defendants are also prohibited from operang any chain referral scheme, including “blessing
loom” schemes like BINT, and are banned from making decepve or unsubstanated income claims or
misrepresentaons. Moreover, the defendants will pay at least $450,000 into a fund administered by the
state of Texas that will be used to provide refunds to aected consumers.
• Health-Related Adversing Claims Pung Children At Risk: As part of its ongoing monitoring of health-re-
lated adversing claims, the FTC sent cease and desist leers—jointly with the U.S. Food and Drug
Fiscal Year 2025 Congressional Budget Justication - Budget Request24
Administraon (FDA)—to six companies currently markeng edible products containing Delta-8 tetrahy-
drocannabinol (THC) in packaging that is almost idencal to many snacks and candy children eat, including
Doritos torlla chips, Cheetos cheese-avored snacks, and Nerds candy. According to the leers, aer
reviewing online markeng for Delta-8 THC products sold by the six companies, the FTC has determined
that their adversing may violate Secon 5 of the FTC Act, which prohibits unfair or decepve acts in or
aecng commerce, including pracces that present unwarranted health or safety risks. The leers stress
that prevenng pracces that present such risks, parcularly to children, is one of the Commission’s high-
est priories, and that imitang non-THC-containing food products that children consume is misleading.
• Penalty Oense Authority: The Commission connued its iniave to use its Penalty Oense Authority
to deter unfair and decepve pracces on a market-wide basis and to protect consumers from scams that
prey on economic precarity. The FTC sent Noce of Penalty Oenses to approximately 670 companies
involved in the markeng of OTC drugs, homeopathic products, dietary supplements, or funconal foods
to place them on noce they could incur signicant civil penales if they fail to adequately substanate
their product claims in ways that run counter to the ligated decisions of prior FTC administrave cases.
Noces of penalty oenses allow the agency to seek civil penales of up to $50,120 per violaon against a
company that engages in conduct that it knows has been found unlawful in a previous FTC administrave
order, other than a consent order.
• Franchise Rule: The FTC issued a request for informaon seeking public comment on franchise agreements
and franchisor business pracces, including how franchisors may exert control over franchisees and their
workers. The FTC is interested in how franchisors disclose certain aspects and contractual terms of the
franchise relaonship, as well as the scope, applicaon, and eect of those aspects and contractual terms.
• Energy Labeling Rule: The FTC updated its Energy Labeling Rule to allow consumers to more accurately
compare the esmated annual energy consumpon of appliances before they buy them.
• Green Guides: The FTC announced that it is seeking public comment on potenal updates and changes to
the Green Guides for the Use of Environmental Claims. The Commission’s Green Guides help marketers
avoid making environmental markeng claims that are unfair or decepve under Secon 5 of the FTC Act.
The Commission seeks to update the guides based on increasing consumer interest in buying environmen-
tally friendly products. As part of the Green Guides review, the FTC also held a workshop, “Talking Trash at
the FTC: Recyclable Claims and Green Guides,” to examine “recyclable” adversing claims. The workshop
included three panel discussions featuring a range of stakeholders focusing on the current state of the
recycling market and claims, the consumer percepon of recycling claims, and the future of the Green
Guides.
• Decepve Energy-Eciency Claims Order: In response to legal acon by the FTC, a federal court ordered
Superior Products Internaonal II, Inc. and its CEO to permanently halt the decepve energy-eciency
claims they had been making about coang products sold for houses and other buildings. The court issued
a permanent injuncon prohibing Superior Products and Pritche from misrepresenng the coangs’
insulang or energy-saving capabilies and imposed a monetary judgment of $14,182.95 against them.
• Eyeglass Rule: The FTC issued a noce of proposed rulemaking to update its Ophthalmic Pracces Rules,
known as the Eyeglass Rule, to ensure ophthalmologists and optometrists provide paents with a copy of
their prescripon immediately aer the compleon of a refracve eye exam, get a signed statement from
the paent conrming that they have received their prescripon, and keep a record of that conrmaon
for at least three years. The FTC hosted a workshop, “A Clear Look at the Eyeglass Rule,” to examine pro-
posed changes to its Eyeglass Rule.
• Contact Lens Rule: The FTC sent 61 cease and desist leers to eye care prescribers aer receiving com-
plaints claiming that the prescribers failed to comply with the Contact Lens Rule. Some leers also cited
Fiscal Year 2025 Congressional Budget Justication - Budget Request
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potenal violaons of the Ophthalmic Pracce Rules (known as the Eyeglass Rule). These rules ensure
consumers the right to comparison shop for prescripon lenses. The leers warn the prescribers that
violaons of the Contact Lens Rule or Eyeglass Rule may result in legal acon, including civil penales of up
to $50,120 per violaon.
• Funeral Rule: FTC acon against Funeral & Cremaon Group of North America, LLC, Legacy Cremaon
Services, LLC, and their owner led to a court order requiring the defendants to pay $275,000 in civil pen-
ales and abide by strict requirements on how they communicate with customers. On behalf of the FTC,
DOJ alleged the defendants misrepresented their locaon, leading consumers to believe they were a local
provider, adversed decepvely low prices, made illegal threats, failed to return cremated remains to
bereaved consumers, and failed to provide disclosures required by the Funeral Rule.
The FTC is exploring possible steps to strengthen and modernize the Funeral Rule, which requires fu-
neral providers to give in-person visitors price informaon to make informed decisions. The sta report
“Shopping for Funeral Services Online: An FTC Review of Funeral Provider Websites” found that fewer
than 40 percent of the funeral provider websites the agency reviewed provide any prices online. The FTC
launched an advance noce of proposed rulemaking concerning potenal amendments to the rule, includ-
ing whether and how funeral providers should be required to display or distribute their price informaon
online and through electronic means. The FTC also hosted a public workshop in September 2023 seeking
input on proposed changes to the Funeral Rule. The workshop explored many of the issues raised in the
advance noce of proposed rulemaking, including whether and how funeral providers should be required
to display or distribute their price informaon online or through electronic means.
The FTC Protects Americans from Fraud and Decepon in Consumer Finance Markets
• Decepve Pre-Approved Claims Order: The FTC nalized a consent order seling charges that credit
services company Credit Karma, LLC deployed dark paerns to misrepresent that consumers were “pre-ap-
proved” for credit card oers. The consent order requires the company to pay $3 million that will be sent
to consumers who wasted me applying for these credit cards and to stop making these types of decep-
ve claims.
• Money-Making Opportunies Order: As a result of a lawsuit led by the FTC and the Utah Division of
Consumer Protecon (DCP), the principals of a Utah-based real estate investment training company,
Response Markeng Group, LLC, will pay $15 million and be banned from selling money-making opportu-
nies. The selement includes two of Response Markeng’s aliates, Nudge, LLC and BuyPD, LLC, along
with the four individuals who the complaint alleges were the actual owners of Response Markeng and
Response Markeng’s President. In addion, two of the primary real estate celebries, Sco Yancey and
Dean R. Graziosi, who endorsed the training, have agreed to separate selements that require them to
pay $1.7 million. The selements with Graziosi and Yancey are the FTC’s rst monetary selements with
celebrity endorsers.
As the result of an FTC lawsuit, investment advice company WealthPress Holdings LLC has agreed to a pro-
posed court order that would require it to refund more than $1.2 million to consumers and pay a $500,000
civil penalty for deceiving consumers with outlandish and false claims about their services. The case marks
the rst me that the FTC has collected civil penales against a company that received the Noce of
Penalty Oenses regarding money-making opportunies sent in October 2021, and the rst civil penales
for violaons of the Restore Online Shoppers’ Condence Act (ROSCA).
• Payment Processors Order: The FTC acted to stop Nexway SASU, a mulnaonal payment processing
company, along with several of its subsidiaries, an associated company known as Asknet Soluons AG,
its CEO, and its chief strategy ocer, from serving as a facilitator for the tech support scammers through
Fiscal Year 2025 Congressional Budget Justication - Budget Request26
credit card laundering. The defendants in the case have agreed to court orders that prohibit them from
any further payment laundering and require them to closely monitor other high-risk clients for illegal
acvity. The court orders also contain a total monetary judgment of $16.5 million, which will be parally
suspended once Nexway and its subsidiaries pay $350,000, Asknet and its subsidiaries pay $150,000, its
CEO pays $100,000, and the chief strategy ocer pays $50,000. The complaint and orders were led by
the DOJ on behalf of the FTC.
• Credit Repair Scheme Order: As the result of an FTC lawsuit, the operators of “The Credit Game,” a credit
repair scheme that cost consumers millions of dollars, face a lifeme ban from the credit repair industry.
The orders contain a total monetary judgment of over $18.8 million, which is parally suspended. The
defendants are required to turn over a wide array of property that would be liquidated and used to
provide refunds to consumers harmed by the scam. The FTC alleged that the company illegally charged
consumers hundreds and even thousands of dollars for credit repair services of lile to no value and told
consumers to “invest” their COVID-19 governmental benets in a business opportunity that amounted
to starng their own bogus credit repair scheme. In some cases, the company’s “services” also allegedly
included ling false identy the reports with the FTC and encouraging consumers to take acons that
were unlawful.
• Credit Card Disputes Ligaon: The FTC and State of Florida led suit against Chargebacks911 for unfairly
thwarng consumers who were trying to dispute credit card charges through the chargeback process. The
FTC and Florida allege that since at least 2016, the “chargeback migaon” company and its owners have
used mulple unfair techniques to prevent consumers from successfully winning chargeback disputes.
• Decepve Cryptocurrency Claims Order: The FTC reached a selement with bankrupt cryptocurrency plat-
form Celsius Network. The order charged three former execuves with tricking consumers into transferring
cryptocurrency onto the plaorm by falsely promising that deposits would be safe and always available
and will permanently ban them from handling consumers’ assets. The selement permanently bans
Celsius and its aliates from oering, markeng, or promong any product or service that could be used
to deposit, exchange, invest, or withdraw any assets. The aliate companies also agreed to a judgment
of $4.7 billion, which will be suspended to permit Celsius to return its remaining assets to consumers in
bankruptcy proceedings. The FTC’s case against the three former execuves will proceed in federal court.
• Decepve Financing Provider Order: The FTC and State of California took acon against home improve-
ment nancing provider Ygrene Energy Fund Inc. for deceiving consumers about the potenal nancial
impact of its nancing, and for unfairly recording liens on consumers’ homes without their consent. Ygrene
agreed to pay $3 million to provide relief to certain consumers whose homes are subject to the company’s
liens and to stop its decepve pracces and meaningfully oversee the contractors who have served as its
salesforce.
• Student Loan Debt Relief: The FTC stopped SL Finance LLC and BCO Consulng Services Inc., a pair of
student loan debt relief schemes that it alleges bilked students out of approximately $12 million by using
decepve claims about repayment programs and loan forgiveness that did not exist. The agency also al-
leges the companies falsely claimed to be or be aliated with the Department of Educaon and told
students that the illegal payments the companies collected would count towards their loans.
The FTC took acon to stop scammers who the agency alleges facilitated an operaon to prey on students
seeking debt relief. The agency alleges that the Apex Processing Center pretended to be aliated with
the U.S. Department of Educaon, used decepve loan forgiveness promises, and falsely claimed they
were oering relief under the “Biden Loan Forgiveness” plan to lure students and collect millions in illegal
upfront fees.
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• Credit Card Debt Relief: As the result of an FTC lawsuit, ACRO Services LLC, the operators of an alleged
credit card debt relief scheme based in Tennessee, have agreed to court orders that would permanently
ban them from telemarkeng and selling debt relief products or services. The orders contain a total mon-
etary judgment of $17.5 million, which is parally suspended. The FTC alleged the defendants took tens
of millions of dollars from people by falsely promising to eliminate or substanally reduce their credit card
debt.
The FTC Safeguards Americans’ Privacy and Data Security
• Meta Consent Order: The FTC proposed changes to the agency’s 2020 privacy order with Facebook, Inc.
aer alleging that the company has failed to fully comply with the order, misled parents about their ability
to control with whom their children communicated through its Messenger Kids app, and misrepresented
the access it provided some app developers to private user data. As part of the proposed changes, Meta,
which changed its name from Facebook in October 2021, would be prohibited from prong from data
it collects, including through its virtual reality products, from users under the age of 18. It would also be
subject to other expanded limitaons, including its use of facial recognion technology, and required to
provide addional protecons for users.
• Children’s Online Privacy Protecon Act Orders: The FTC secured agreements requiring Epic Games, Inc.,
creator of the popular video game Fortnite, to pay a total of $520 million in relief over allegaons the
company violated the Children’s Online Privacy Protecon Act (COPPA) and deployed design tricks, known
as dark paerns, to dupe millions of players into making unintenonal purchases. The FTC’s acon against
Epic involves two separate record-breaking selements. As part of a proposed federal court order led
by DOJ on behalf of the FTC, Epic will pay a $275 million monetary penalty for violang the COPPA Rule,
which is the largest penalty ever obtained for violang an FTC rule. Addionally, in a rst-of-its-kind pro-
vision, Epic will be required to adopt strong privacy default sengs for children and teens, ensuring that
voice and text communicaons are turned o by default. Under a separate administrave order, Epic will
pay $245 million to refund consumers for its dark paerns and billing pracces, which is the FTC’s largest
refund amount in a gaming case.
To sele charges that it violated the COPPA Rule and deceived parents and users of the Alexa voice as-
sistant service about its data deleon pracces, Amazon.com, Inc. has agreed to pay a $25 million civil
penalty, overhaul its deleon pracces, and implement stringent privacy safeguards. According to the
complaint led by the DOJ on behalf of the FTC, Amazon prevented parents from exercising their deleon
rights under the COPPA Rule, kept sensive voice and geolocaon data for years, and used it for its own
purposes, while pung data at risk of harm from unnecessary access.
Microso Corporaon will pay $20 million to sele FTC charges that it violated COPPA collecng personal
informaon from children who signed up to its Xbox gaming system without nofying their parents or
obtaining their parents’ consent, and by illegally retaining children’s personal informaon. As part of
a proposed order led by the DOJ on behalf of the FTC, Microso will be required to take several steps to
bolster privacy protecons for child users of its Xbox system. For example, the order will extend COPPA
protecons to third-party gaming publishers with whom Microso shares children’s data. In addion, the
order makes clear that avatars generated from a child’s image, and biometric and health informaon, are
covered by the COPPA Rule when collected with other personal data.
The FTC obtained an order against educaon technology provider Edmodo, Inc. for collecng personal data
from children without obtaining their parent’s consent and using that data for adversing, in violaon of
the COPPA Rule, and for unlawfully outsourcing its COPPA compliance responsibilies to schools. Under
the order, Edmodo is, among other things, prohibited from requiring students to hand over more personal
Fiscal Year 2025 Congressional Budget Justication - Budget Request28
data than is necessary to parcipate in an online educaonal acvity, which is a rst for an FTC order. The
proposed order also includes a suspended civil penalty of $6 million.
• Health Breach Nocaon Rule Orders: The FTC took enforcement acon for the rst me under its
Health Breach Nocaon Rule against the telehealth and prescripon drug discount provider GoodRx
Holdings Inc., for failing to nofy consumers and others of its unauthorized disclosures of consumers’ per-
sonal health informaon to Facebook, Google, and other companies. In a rst-of-its-kind proposed order,
led by DOJ on behalf of the FTC, GoodRx is prohibited from sharing user health data with applicable third
pares for adversing purposes, and has agreed to pay a $1.5 million civil penalty for violang the rule.
The FTC charged that the developer of the ferlity app Premom deceived users by sharing their sensive
personal informaon with third pares, including two China-based rms, disclosed users’ sensive health
data to AppsFlyer and Google, and failed to nofy consumers of these unauthorized disclosures in vio-
laon of the Health Breach Nocaon Rule. The order, which was entered on June 22, 2023, prohibits
the app developer, Easy Care Healthcare Corporaon, from sharing users’ personal health data with third
pares for adversing, requires the app to obtain users’ consent before sharing health data for any other
purpose, and to tell consumers how their personal data will be used.
The FTC is seeking comment on proposed changes to the Health Breach Nocaon Rule that include
clarifying the rule’s applicability to health apps and other similar technologies. Since the rule’s issuance,
health apps and other direct-to-consumer health technologies, such as tness trackers, have become com-
monplace. The proposed changes to the rule come as business pracces and technological developments
increase both the amount of health data collected from consumers, and the incenve for companies to
use or disclose that sensive data for markeng and other purposes.
• Biometric Informaon Policy Statement: The FTC issued a policy statement warning that the increasing
use of consumers’ biometric informaon and related technologies, including those powered by machine
learning, raises signicant consumer privacy and data security concerns and the potenal for bias and dis-
criminaon. Biometric informaon refers to data that depict or describe physical, biological, or behavioral
traits, characteriscs, or measurements of or relang to an idened or idenable person’s body. The
policy statement warns that false or unsubstanated claims about the accuracy or ecacy of biometric
informaon technologies or about the collecon and use of biometric informaon may violate the FTC Act.
• Health Data Orders: The FTC nalized an order banning online counseling service BeerHelp, Inc. from
sharing consumers’ health data, including sensive informaon about mental health challenges, for ad-
versing. The order also requires the company to pay $7.8 million to consumers to sele charges that it
revealed consumers’ sensive data with third pares such as Facebook and Snapchat for adversing aer
promising to keep such data private.
The FTC charged that the genec tesng rm 1Health.io Inc., formerly known as Vitagene, le sensive
genec and health data unsecured, deceived consumers about their ability to get their data deleted, and
changed its privacy policy retroacvely without adequately nofying and obtaining consent from consum-
ers whose data the company had already collected. As part of the nal order with the FTC, 1Health agreed
to pay $75,000 and will strengthen protecons for genec informaon and instruct third-party contract
laboratories to destroy all consumer DNA samples that have been retained for more than 180 days.
• Health Privacy: The FTC and the U.S. Department of Health and Human Services’ Oce for Civil Rights
(OCR) cauoned hospitals and telehealth providers about the privacy and security risks related to the use
of online tracking technologies integrated into their websites or mobile apps that may be impermissibly
disclosing consumers’ sensive personal health data to third pares. The two agencies sent a joint leer
to approximately 130 hospital systems and telehealth providers to alert them about the risks and concerns
regarding the use of technologies, such as the Meta/Facebook pixel and Google Analycs, that can track
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a user’s online acvies. These tracking technologies gather idenable informaon about users, usually
without their knowledge and in ways that are hard for users to avoid, as users interact with a website or
mobile app.
• Illegal Surveillance Order: The FTC charged home security camera company Ring, LLC with compromising
its customers’ privacy by allowing any employee or contractor to access consumers’ private videos and by
failing to implement basic privacy and security protecons, enabling hackers to take control of consum-
ers’ accounts, cameras, and videos. The court order requires Ring to pay $5.8 million and to delete data
products such as data, models, and algorithms derived from videos it unlawfully reviewed. The order also
requires Ring to implement a privacy and security program with novel safeguards on human review of
videos as well as other stringent security controls, such as mul-factor authencaon for both employee
and customer accounts.
• Data Security Orders: The FTC nalized an order with online alcohol marketplace Drizly, LLC and its CEO
over security failures by the company that the FTC said led to a data breach exposing the personal infor-
maon of about 2.5 million consumers. The FTC alleged that Drizly and its CEO were alerted to security
vulnerabilies two years prior to the 2020 breach yet failed to take steps to protect consumers’ data from
hackers despite publicly claiming to have appropriate security protecons in place. The FTC’s order, among
other things, requires Drizly to destroy any personal data it collected that is not necessary for it to provide
products or services to consumers and must refrain from collecng or storing personal informaon unless
it is necessary for specic purposes outlined in a retenon schedule.
The FTC nalized its order with educaon technology provider Chegg Inc. for its careless data security
pracces that exposed sensive informaon about millions of Chegg’s customers and employees, includ-
ing Social Security numbers, email addresses, and passwords. The FTC’s order requires Chegg to imple-
ment a comprehensive informaon security program, limit the data the company can collect and retain,
oer users mulfactor authencaon to secure their accounts, and allow users to request access to and
deleon of their data.
• Tax Prep Consumer Data: The FTC used its penalty oense authority to warn ve tax preparaon compa-
nies that they could face civil penales if they use or disclose condenal data, collected from consumers
for the purpose of preparing their taxes, for unrelated purposes such as adversing, without rst obtaining
consumers’ consent. By sending a Noce of Penalty Oenses, the agency is warning recipients they could
incur civil penales of up to $50,120 per violaon if they misuse personal data in ways that run counter to
the original purpose for which this informaon was collected.
• Fair Credit Reporng Act Violaons Orders: Background report providers TruthFinder and Instant
Checkmate agreed to a proposed order requiring them to pay $5.8 million to sele charges that they
deceived consumers about whether consumers had criminal records and that the companies violated the
Fair Credit Reporng Act (FCRA) by operang as consumer reporng agencies while, among other things,
failing to ensure the maximum possible accuracy of their consumer reports. The proposed order also
requires the companies to implement an FCRA monitoring program, among other provisions.
The FTC Works to Protect Every Community
• Scams Targeng Black and Lano Consumers: The FTC took acon against auto dealer Passport
Automove Group for deceiving consumers by tacking hundreds to thousands of dollars in illegal junk
fees onto car prices and for discriminang against Black and Lano consumers with higher nancing costs
and fees. Passport, its president, and its vice president will pay more than $3.3 million to sele the FTC’s
lawsuit, which will be used to refund consumers harmed by Passport’s conduct.
Fiscal Year 2025 Congressional Budget Justication - Budget Request30
In response to an acon led by the FTC, a federal court entered a temporary restraining order against the
operators of a Florida-based business opportunity and real estate investment training scheme known as
Ganadores Online and Ganadores Inversiones Bienes Raíces. The FTC charges that the companies behind
Ganadores, their owners, and key employees targeted Spanish-speaking consumers with brazen and false
money-making pitches for online businesses and real estate investments.
• Scams Targeng or Disproporonately Impacng Older Adults: The DOJ, on behalf of the FTC and the
Wisconsin Aorney General, led suit against Consumer Law Protecon, LLC and related companies,
along with their owners and operators, for scamming consumers, mostly older adults, out of more than
$90 million in a massive meshare exit scam. Since at least 2018, the defendants used direct mail and in
person “seminars” to pitch a dizzying array of decepve claims to pressure consumers into paying for their
services.
• Background Screening Issues: The FTC and the Consumer Financial Protecon Bureau (CFPB) requested
comment on background screening issues aecng individuals who seek rental housing in the United
States, including how the use of criminal and evicon records and algorithms aect tenant screening
decisions and may be driving discriminatory outcomes. The FTC and CFPB are working closely to idenfy
pracces that may unfairly prevent consumers from obtaining and retaining housing, and comments to the
Request for Informaon (RFI) will help inform enforcement and policy acons under each agency’s jurisdic-
on. The Fair Credit Reporng Act, which the FTC and CFPB both enforce, also imposes requirements on
many aspects of the tenant screening process.
The FTC Protects Small Businesses
• Made in the USA: The FTC nalized a consent order against Electrowarmth Products, LLC and its owner for
decepvely claiming the heated fabric maress pads they sell for truck bunks are made in the USA. The -
nal order prohibits Grindle and Electrowarmth from making any country-of-origin claim about a product or
service unless the claim is not misleading and they have a reasonable basis that substanates their claim.
It also requires the respondents to make certain disclosures about the country of origin of any product
subject to the Texle Fiber Products Idencaon Act, and to provide compliance reports. The order also
imposes a suspended $815,809 monetary judgment.
The FTC nalized its order against Instant Brands LLC, manufacturer of Pyrex-brand kitchen and home
products, for making false “Made in USA” claims. The order stops the company from making decepve
claims about products being “Made in USA” and requires it to pay a $129,416 judgment.
The FTC nalized its order against motocross and ATV parts maker Cycra, Inc. and its ocer for falsely
claiming that the company’s products were manufactured in the United States. The order stops Cycra and
its ocer from making decepve claims about products being “Made in USA” and require them to pay a
monetary judgment of $872,577, which is parally suspended once the defendants pay $221,385.66.
FTC took acon against Chaucer Accessories, Inc., Bates Accessories, Inc., and Bates Retail Group, Inc., a
group of Massachuses and New Hampshire based clothing accessories companies, and their owner for
falsely claiming that certain company products were manufactured in the United States. The nal order
stops the companies and their owner, Thomas Bates, from making decepve claims about products being
“Made in USA” and requires them to pay a monetary judgment of $191,481.
• Small Business Debt Collecon: As a result of acon by the FTC and Commonwealth of Pennsylvania,
debt collecon company Internaonal Credit Recovery, Inc. (ICR), an ocer, and a manager agreed to
a permanent ban from the debt collecon industry aer being charged with engaging in bogus debt
collecon eorts against businesses and non-prots. The FTC and Pennsylvania alleged that ICR was a key
part of a telemarkeng scheme run by American Future Systems, Inc., (AFS), which also does business as
Fiscal Year 2025 Congressional Budget Justication - Budget Request
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Progressive Business Publicaons and the Center for Educaon and Employment Law. ICR allegedly col-
lected on debts AFS claimed organizaons such as businesses, schools, re and police departments, and
non-prots owed for book and newsleer subscripons they did not order. The seling defendants are
also required to cooperate since the case will connue against the other defendants.
• Small Business Credit Reporng: The FTC launched an inquiry into the small business credit reporng
industry, ordering ve rms in that industry to provide the Commission with detailed informaon about
their products and processes. The orders were issued to Dun & Bradstreet, Experian Informaon Soluons,
Equifax, Ansonia Credit Data, and Creditsafe USA. The Commission’s inquiry will examine mulple aspects
of how informaon is collected and processed for business credit reports, how the reports are marketed,
and how and whether the credit reporng companies address factual errors in the reports. In addion to
informaon about these topics, the orders also require the companies to provide informaon on services
they provide to businesses to monitor or enhance their own credit reports.
• Workers and Small Businesses in the Gig Economy: The FTC nalized a consent order against Denver-
based HomeAdvisor, Inc., a company aliated with Angi, formerly known as “Angie’s List,” seling allega-
ons that it used a wide range of decepve and misleading taccs in selling home improvement project
leads to service providers, including small businesses operang in the “gig” economy. The nal order
requires that HomeAdvisor pay up to $7.2 million for redress and prohibits the company from making any
false or misleading claims regarding its leads, including that they concern individuals who are ready to hire
a service provider or who submied a request for home services directly to HomeAdvisor.
Consumer Protecon Law Enforcement Collaboraon and Advocacy
• Key Law Enforcement Tools: In FY 2023, more than 7.7 million fraud, identy the, nancial, and DNC
complaints were added to the FTC’s Consumer Sennel Network (CSN) database. Nearly 3,000 law en-
forcement users worldwide have access to CSN. In FY 2023, over 249 million telephone numbers were on
the Naonal Do-Not-Call Registry. In FY 2023, the Consumer Response Center handled more than 51,000
inquiries and complaints from consumers and businesses each week, for a total of 2.7 million complaints
and inquiries. The FTC also maintains the federal government’s central repository for identy the com-
plaints. The one-stop website is integrated with the FTC’s consumer complaint system, allowing consumers
who are vicms of identy the to rapidly le a complaint with the FTC and create the documents they
need to alert police, the naonwide consumer reporng agencies, and the Internal Revenue Service (IRS).
• Criminal Referrals: The FTC connues to refer law violators to criminal law enforcement agencies for pros-
ecuon. In Fiscal Year 2023, FTC sta acvely worked on 37 new formal requests for cooperaon from our
criminal law enforcement partners, including 29 federal, ve state, and three local requests. In Fiscal Year
2023, prosecutors relied on FTC informaon and support to charge 18 new defendants and obtain eight
new convicons. Nineteen defendants were sentenced during this period, and those sentences included
prison terms totaling 429 months. Of these defendants, Steven Short was sentenced to 78 months in
prison for his role in a credit-card laundering scheme. Another defendant, Jennifer Shah, was sentenced to
78 months in prison for her role in a naonwide telemarkeng fraud scheme that targeted elderly vicms.
Addionally, Sergio Rodriguez was sentenced to 48 months in prison for his parcipaon in a foreclosure
rescue scam that defrauded thousands of nancially distressed homeowners.
• Collaboraon with State Aorneys General: In addion to the FTC’s collaboraon with aorneys general
from all 50 states the District of Columbia to crack down on illegal telemarkeng calls, the FTC connues
to partner with state aorneys general to protect consumers from unfair and decepve pracces across
the marketplace. In FY 2023, the FTC and the Wisconsin Aorney General together led suit against a
meshare exit scam for defrauding older adults and other consumers out of more than $90 million; the
FTC worked with the Utah Aorney General to stop a real estate investment training from false promising
Fiscal Year 2025 Congressional Budget Justication - Budget Request32
wealth creaon opportunies; and the FTC, in collaboraon with the California Aorney General, took
acon against a home improvement nancing provider for deceiving property owners about the terms
aached to home improvement nancing.
The FTC also issued a request for public informaon (RFI) seeking public comments and suggesons
on ways it can work more eecvely with state aorneys general to help educate consumers about, and
protect them from, potenal fraud. The RFI comes at the direcon of the FTC Collaboraon Act of 2021.
The Collaboraon Act directs the FTC to “conduct a study on facilitang and rening exisng eorts with
State Aorneys General to prevent, publicize, and penalize frauds and scams being perpetrated on individ-
uals in the United States.” It further requires the Commission to consult directly with interested stakehold-
ers, as well as provide the opportunity for public comment and advice relevant to the producon of the
study.
• Advocacy in the Courts and Other Federal Agencies: The FTC led briefs and comments with federal and
state government bodies advocang for policies that promote the interests of consumers and highlighng
the role consumer and empirical research might play in their decision-making.
• The FTC joined the CFPB in ling a friend-of-the-court (amicus) brief with the U.S. Court of Appeals
for the Eleventh Circuit in the case of Louis v. Bluegreen Vacaons Unlimited, Inc. The brief asks the
appeals court to overturn a lower court decision that denied servicemembers the right to sue to in-
validate a contract that they allege violates the Military Lending Act. The district court erred, the brief
argues, and its ruling could undermine enforcement of the Military Lending Act, a law designed to
protect military families from predatory lending. Servicemembers are parcularly vulnerable to preda-
tory pracces, which can undermine military readiness and morale.
• The FTC led an amicus brief arguing that the Children’s Online Privacy Protecon Act (COPPA) does
not preempt state privacy laws that are consistent with COPPA. The brief was led in support of a
federal appeals court’s ruling in Jones v. Google, a case in which a group of children allege that Google
collected data and surrepously tracked their online acvity in violaon of state laws.
• The FTC led an amicus brief in the U.S. Court of Appeals for the Seventh Circuit challenging a district
court ruling that invalidated a key an-discriminaon rule in the Equal Credit Opportunity Act (ECOA).
The case, CFPB v. Townstone Financial and Barry Sturner, relates to a Chicago-based mortgage lender
and its owner, which the CFPB alleged violated Regulaon B, the rule that implements ECOA. The CFPB
alleged that the defendants took steps to discourage Black consumers from applying for loans, violang
Regulaon B’s an-discouragement rule. The district court ruled that the an-discouragement provision
was invalid and that ECOA protects only those consumers who have already applied for credit. In its
brief, the FTC argues that the district court’s ruling was incorrect. The Commission’s brief notes that the
an-discouragement rule—which has stood for nearly 50 years—is authorized by the plain language
of ECOA, which mandates that regulators further ECOA’s “purpose” and prevent its “evasion.” The FTC
also argues that the district court’s ruling would have “profoundly negave consequences” for consum-
ers, emboldening discriminatory lenders to openly discourage consumers from applying for loans.
• The FTC led a comment with the U.S. Department of Educaon regarding the U.S. Department of
Educaon’s proposed regulaons to protect postsecondary students in the educaon marketplace.
In the comment, FTC sta stresses its support of the Educaon Department’s proposed regulaons,
nong that prohibing misrepresentaons and decepve recruitment pracces would help curb the
very type of harm that the FTC has encountered in its cases. Sta’s comment also notes that, given the
importance and expense of educaon, the FTC has priorized protecng consumers from unfair and
decepve pracces in this space. The comment endorses the Educaon Department’s eort to protect
consumers from the harms caused by such pracces in the educaon marketplace.
Fiscal Year 2025 Congressional Budget Justication - Budget Request
33
• SAFE WEB: In 2023, the FTC gathered data and informaon and submied its SafeWeb Report to Congress,
detailing the agency’s eorts to combat cross-border fraud through the U.S. SAFE WEB Act and its and
work contribung to the ght against ransomware and other cyber aacks that originate outside the
United States.
• Internaonal Cooperaon on Fighng Fraud: In FY 2023, the FTC renewed its Memorandum of
Understanding (MOU) with the Unsolicited Communicaons Enforcement Network, which includes the
FCC as well as internaonal counterparts in Canada, Australia, New Zealand, South Korea, and the UK. In
addion, the FTC partnered with Lan American countries to ght fraud, entering into a mullateral MOU
with Chile, Colombia, Mexico, and Peru. In FY 2022 and 2023, the agency worked with internaonal part-
ners to ensure that vicms of the Next-Gen sweepstakes scam were eligible to receive refunds.
• Providing Experse Internaonally: The FTC provided input to internaonal policy organizaons such as
the OECD, UNCTAD, APEC, and the Global Privacy Assembly, dealing with such issues as dark commercial
paerns, arcial intelligence, sustainability, and internaonal data transfers. The FTC similarly parc-
ipated in regional networks, such as the Asia Pacic Privacy Authories Forum, the African Consumer
Protecon Dialogue, and the Iberoamerican network of consumer authories. The FTC and the European
Commission launched a consumer dialogue which included bilateral discussions and webinars for FTC, EC,
and member state ocials to exchange experse on dark paerns, online reviews, environmental claims,
repair restricons, and other topics of mutual interest. The FTC led the G7 data protecon authories’
work on enforcement cooperaon, and in June parcipated in a G7 roundtable of these authories, engag-
ing in dialogues on various cung edge privacy topics, including generave AI.
Consumer Protecon Research, Outreach, and Educaon
• Open Commission Meengs: During FY 2023, the FTC held eight Open Commission Meengs to provide
a forum for the public to directly engage with the work of the Commission. These meengs begin with an
opportunity for any member of the public to address the Commission and share their experiences in the
marketplace, followed by Commission discussion on key agency priories, including protecng children’s
privacy online, eliminang junk fees, and halng scams that target our naon’s veterans and service-
members. During FY 2023, nearly 150 members of the public—from small business and franchise owners
to advocates for children’s privacy to grocery store workers to the Majority Leader of the United States
Senate—had the opportunity to speak before the Commission, and these meengs opened the FTC’s
important work to protect consumers to thousands of viewers across the country.
• Outreach to Older Americans: The FTC’s Pass It On campaign (ftc.gov/PassItOn and ftc.gov/Pasalo in
Spanish), tailored to people aged 65 and older, shares informaon about fraud and encourages readers
to share it with a friend. The agency has expanded upon the successful campaign by adding topics and
refreshing its approach as part of its Stop Senior Scams Act acvies. As part of the 2023 rollout of the
refreshed materials, the FTC held public-facing webinars that brought in more than 2,600 aendees. the
agency connues to promote these resources through webinars and presentaons in collaboraon with
other federal agencies, such as the CFPB, local government oces on aging, legal services providers, and
non-prot organizaons including AARP and the Senior Medicare Patrol. Nearly 20 million pieces of Pass It
On educaonal material have been distributed since the campaign launched in July 2014.
• Protecng Older Consumers Report: In October 2022, the Commission issued “Protecting Older
Consumers 2021-2022: A Report of the Federal Trade Commission.” The report highlights key trends
based on fraud reports by older adults, and the FTC’s eorts to combat the pressing problems through
law enforcement acons, rulemaking, and outreach and educaon programs. New analysis in the report
idened dierences in the fraud types and payment methods reported by older adults most likely to be
Black, Lano, and Asian American and Pacic Islander compared to reports from all consumers.
Fiscal Year 2025 Congressional Budget Justication - Budget Request34
• Outreach to Military Service Members: The FTC has developed and manages the Military Consumer
campaign together with the U.S. Department of Defense’s (DoD’s) Oce of Financial Readiness and the
CFPB, with nearly 50 other military, federal, and state partners. The campaign addresses unique challenges
of military life that oen make military personnel and families targets for scammers. Service members
and their families, along with the DoD’s personal nancial managers who serve them, use the campaign
website (MilitaryConsumer.gov) as a tool for nancial readiness. Two highlights of the campaign (Military
Consumer Month in July and Veterans Day in November) feature extensive social media outreach and
virtual events with the network of military partners. Since the launch of the campaign in 2017, the
Commission has distributed more than 1.2 million Military Consumer bookmarks to the military communi-
ty, guiding servicemembers, veterans, and their families to MilitaryConsumer.gov.
• Outreach to Small Businesses: The FTC connues its focus on educang small business owners about
small business nancing, data security, and scams and decepve pracces targeng small businesses.
Providing informaon and guidance to small businesses in communies of color is a priority for the agen-
cy, which makes business educaon materials available in Spanish. Outreach eorts are ongoing to reach
minority-owned businesses, as well as women-owned businesses, veteran-owned businesses, and other
historically disadvantaged small businesses. Agency sta regularly engage chambers of commerce that
represent diverse business communies and provides advice to the Small Business Administraon’s (SBA)
District Oces on cybersecurity scams that target small business owners and their business networks.
The FTC connues to promote free resources for small business owners to help train their employees on
cybersecurity threats. The FTC parcipated in the SBA’s four-day 2023 Naonal Small Business Virtual
Summit and, among other eorts, connues expand the reach of its Spanish language campaign materials
on cybersecurity and the scams that target small businesses, in collaboraon with the SBA, the SBA’s
Small Business Development Corporaons (SBDCs), the Beer Business Bureau (BBB), and local Hispanic
Chambers of Commerce.
• Consumer Issues Aecng American Indian and Alaska Nave Communies Report: In 2022, the FTC
engaged in a naonal outreach and educaon eorts to gain a broader understanding of the parcular
consumer protecon challenges American Indian and Alaska Nave communies experience and how the
Agency may work to further support these communies. This eort included listening to and collaborang
with sources in American Indian and Alaska Nave communies as well as analyzing consumer complaints
to the FTC from individuals in these communies. The “Consumer Issues Aecng American Indian
and Alaska Nave Communies Report,” submied to Congress in March 2023, provides details on the
consumer issues idened through these eorts, including a summary of some of the law enforcement
acons and recent noces of proposed rulemaking relang to consumer abuses idened as impacng
American Indian/Alaska Nave communies, the Agency’s acons to beer reach and respond to their
needs, In addion, the Agency partnered with organizaons, including the Nave Learning Center and the
Naonal Indian Council on Aging, to provide informaon on consumer protecon issues.
• Outreach to Protect Americans from COVID-related Fraud: The FTC used paid radio, print, and digital
adversing campaigns to target millions of consumers in communies across the U.S. to warn Americans
about pandemic-related scams and to promote a new website aimed at helping people manage the
nancial impact of the pandemic: ftc.gov/MoneyMatters and ftc.gov/AsuntosDeDinero. In FY23, topics
from the site have been featured in six naonal and targeted radio tours, reaching millions of listeners
naonwide. Recognizing the impact of the pandemic on small businesses, the FTC connues to work with
the SBA, SBDCs, the BBB, and other groups that serve minority small business owners, all to help business
owners in all communies protect their businesses, livelihood, and employees from pandemic-related
scams and economic hardship. To date, the agency has held 33 Ethnic and Community Media Briengs,
bringing together journalists, state and local law enforcement, legal services, and community advocates to
discuss scams and bad business pracces aecng communies of color, immigrant communies, Tribal
Fiscal Year 2025 Congressional Budget Justication - Budget Request
35
communies, and English language learners. The agency also engaged in a paid adversing campaign for
radio, print, and digital media outlets that primarily reach Nave American communies focused on raising
awareness about gi card scams and reporng fraud.
• Outreach to Historically Underserved Audiences: The FTC connues its commitment to reaching histori-
cally underserved audiences to help them locate and use consumer educaon resources aimed at protect-
ing against scams. This has included oering core FTC resources in 12 languages, in addion to English and
Spanish. As of FY 2023, people who call the FTC Call Center are able to report fraud and identy the in
their nave language by following prompts to select a specic language. In addion, the Agency connues
to reach out to audiences which speak languages other than English through an ongoing ethnic media
strategy that includes a series of ethnic and community briengs and roundtables that have connected
ethnic and community media with FTC experts on how fraud impacts communies of color. Topics have
included scams and bad business pracces in auto buying; job and money-making scams that plague
historically underserved audiences; new phishing scam trends, including using text messages and AI; and
the ways scammers demand payment. Geographically based roundtables have connected the FTC with
local law enforcement, legal services, community advocates, and ethnic media. Audiences reached include
rural, immigrant, Black, and Lano communies in Louisville and Tampa; the Hmong, Lano, Black, and
immigrant communies in Minneapolis; and Chinese, Korean, South Asian, Pacic Islander, and other Pan-
Asian communies in San Francisco. The results have included numerous, in-language arcles and radio
spots in local and ethnic media, reaching not only those targeted communies via trusted sources, but
also carrying the messages into less-reached rural communies, sharing praccal and aconable advice,
and encouraging reporng to the FTC.
• INFORM Consumers Act: Congress passed the Integrity, Nocaon, and Fairness in Online Retail
Marketplaces for Consumers Act, or the INFORM Consumers Act, to add more transparency to online
transacons and to deter criminals from acquiring stolen, counterfeit, or unsafe items and selling them
through online marketplaces. The FTC sent leers to 50 online marketplaces naonwide nofying them
about their obligaons to comply with the new INFORM Consumers Act. The FTC also developed business
educaon materials that are available on the agency’s website to summarize how online marketplaces can
comply with the act, along with links to the act itself. Violaons of the act may be treated as a violaon of
an FTC rule, and thus noncompliant online marketplaces may face enforcement that could result in civil
penales of $50,120 per violaon.
• Stealth Social Media Adversing to Children: The FTC hosted a virtual event on “Protecng Kids from
Stealth Adversing in Digital Media,” Bringing together researchers, child development and legal experts,
consumer advocates, and industry professionals to examine the techniques being used to adverse to
children online and what measures should be implemented to protect children from manipulave adver-
sing. The FTC also issued a sta paper “Protecng Kids from Stealth Adversing in Digital Media.” The
paper recommends that businesses, social media inuencers and others who market or promote products
online to children should avoid blurring adversing by clearly separang adversing and entertainment,
educaonal, and other content to help limit potenal harms to children. It warns that for younger children
in parcular, disclosures are unlikely to be eecve.
• PrivacyCon: The FTC hosted its annual PrivacyCon event virtually, bringing together a diverse group of
stakeholders, including researchers, academics, industry representaves, consumer advocates, and gov-
ernment regulators, to discuss the latest research and trends related to consumer privacy and data securi-
ty. The seventh annual PrivacyCon featured presentaons on commercial surveillance, automated decision
making, and a range of other privacy and data security topics.
Fiscal Year 2025 Congressional Budget Justication - Budget Request36
Promong Fair Compeon: Highlights of FY 2023 Accomplishments
The FTC enforces America’s antrust laws to promote open, compeve markets, which benet American
consumers, workers, innovators, and honest businesses. The Commission’s enforcement eorts encompass
crically important markets, including healthcare, technology, energy, defense, consumer goods and services,
labor, and manufacturing.
In FY 2023, the agency brought 23 enforcement acons under the antrust laws, iniated federal court or
administrave ligaon in six maers, and issued consent orders to remedy prospecve or ongoing harm
to compeon in seven maers. In an addional ten maers, the pares abandoned or restructured their
proposed acquisions to address Commission concerns that the original transacon likely would have harmed
compeon. The FTC also connued to monitor and enforce compliance with exisng consent orders, includ-
ing prior approval provisions, as well as merger and acquision reporng obligaons under the Hart-Sco-
Rodino (HSR) Act.
Compeon Law Enforcement and Policy Iniaves
Providing Clarity to Market Parcipants
• Dra Merger Guidelines: In July, the FTC and the Department of Jusce proposed dra Merger Guidelines,
which lay out how U.S. enforcers will assess whether transacons may lessen compeon or tend to
create a monopoly. Informed by thousands of comments from consumers, workers, academics, aorneys,
enforcers, business owners, and many others from across the economy, the dra guidelines capture the
tangible eects that mergers have on people’s lives. The dra guidelines reect modern market realies,
advances in economics and law, and the experiences of a diverse array of market parcipants. The Merger
Guidelines were nalized and issued in December 2023.
• Dra Hart-Sco-Rodino Form: The FTC and the DOJ proposed changes to Hart-Sco-Rodino Form and
Instrucons, marking the rst me in 45 years that the agencies have undertaken a top-to-boom review
of the form. These proposed changes would enable the agencies to more eecvely and eciently screen
transacons for potenal compeon issues within the inial waing period, which is typically 30 days.
The proposed updates would require pares to provide details on relevant corporate relaonships, previ-
ous acquisions, the structure of enes involved, and labor pracces.
• Secon 5 Unfair Methods of Compeon Policy Statement: The Federal Trade Commission issued a state-
ment that restores the agency’s policy of rigorously enforcing the federal ban on unfair methods of compe-
on. The FTC’s previous policy restricted Secon 5’s oversight to a narrower set of circumstances, making
it harder for the agency to challenge the full array of ancompeve behavior in the market. The current
statement removes this restricon and declares the agency’s intent to exercise its full statutory authority
against companies that use unfair taccs to gain an advantage instead of compeng on the merits.
Promong Fair Compeon in the Healthcare and Pharmaceucal Industries
• Pharmaceucal Monopolizaon: In January 2023, the FTC asked a federal judge to hold “Pharma Bro”
Marn Shkreli in contempt for failing to provide the FTC with informaon needed to verify his compliance
with a 2022 ground-breaking federal order banning him from working in the pharmaceucal industry for
life. The order stems from the FTC’s federal court ligaon where the court held that Shkreli orchestrated
an illegal ancompeve scheme to perpetuate a monopoly for the drug Daraprim, a life-saving drug used
in the treatment of a rare, potenally fatal parasic infecon known as toxoplasmosis. Separate from the
FTC’s request in federal district court to hold Shkreli in contempt, the FTC also urged the United States
Court of Appeals for the Second Circuit to reject Shkreli’s arguments seeking to overturn his lifeme ban
Fiscal Year 2025 Congressional Budget Justication - Budget Request
37
from parcipang in the pharmaceucal industry. The FTC ulmately prevailed before the Second Circuit,
with that court arming the 2022 order and its lifeme ban.
• Health Care Informaon Technology An-Compeve Conduct: In July 2023, the FTC led a spulated
order to sele charges that health informaon technology company Surescripts engaged in exclusionary
conduct to maintain a monopoly in violaon of the antrust laws. The selement follows a favorable
federal court ruling that found that Surescripts possesses monopoly power in e-prescribing services with a
95 percent “supershare.” In adopng the Commission’s posion, the opinion made important claricaons
of the law, including on the establishment of monopoly power through market share and barriers to entry.
According to the FTC’s April 2019 complaint, Surescripts employed illegal vercal and horizontal restraints
in order to maintain its monopoly of the roung and eligibility e-prescribing markets. These markets
involve technology used by physicians to route electronic prescripons and health care providers to elec-
tronically determine paent eligibility and insurance coverage, respecvely. The order prohibits Surescripts
from imposing loyalty or exclusivity requirements on its roung and eligibility customers, including
through all-unit discounng, as well as barring the company from using non-compete agreements with
employees that would prevent them from working for a competor.
• Health Care Adversing Plaorm Merger: In July 2023, the FTC issued a complaint seeking to block the
world’s largest health care data provider, IQVIA Holdings, from acquiring Propel Media, Inc. According to
the complaint, the proposed acquision would give IQVIA a leading posion in the market for program-
mac adversing for health care products (namely prescripon drugs) to doctors and other health care
professions and would incenvize IQVIA to withhold key informaon to discourage entry into the market
by potenal rival companies. IQVIA and Propel are two of the top three providers of these services, known
as demand-side plaorms, which specically target health care professionals with adversing for pharma-
ceucal drugs and other products. The complaint alleges that the proposed deal would eliminate head-to-
head compeon between the two rms, driving up prices and reducing quality and choice—potenally
harming paents by inhibing knowledge of new products and aecng the prescribing behavior by health
care providers and increasing prices if inated markeng costs were passed-on to paents. Aer an evi-
denary hearing in late 2023, U.S. District Court Judge Edgardo Ramos issued an order granng the FTC’s
moon for preliminary injuncon on December 29, 2023.
• Private Equity Serial Acquisions of Anesthesia Providers: In September 2023, the Commission led a
complaint in federal court alleging that U.S. Anesthesia Partners, Inc. (USAP), the dominant provider of
anesthesia services in Texas, and private equity rm Welsh, Carson, Anderson & Stowe executed a mul-
year ancompeve scheme to consolidate anesthesiology pracces in Texas, driving up the prices of
anesthesia services for Texas paents to increase prots. According to the complaint, USAP and Welsh
Carson engaged in a three-part strategy to consolidate and monopolize the anesthesiology market. First,
they executed a roll-up scheme by systemacally buying up nearly every large anesthesia pracce in Texas
to create a single dominant provider with the power to demand higher prices. Second, the rms drove up
prices through price-seng agreements with the remaining independent pracces. And third, the rms
further reduced compeon by striking a deal to sideline a signicant competor by keeping it out of
USAP’s territory. This mulprong ancompeve strategy has cost Texans an esmated tens of millions of
dollars each year. This maer is pending in federal court.
• Pharmaceucal Merger: In May 2023, the Commission issued a complaint seeking to block Amgen Inc.’s
proposed acquision of Horizon Therapeucs plc. According to the complaint, the deal would allow Amgen
to leverage its porolio of blockbuster drugs to entrench the monopoly posion of Horizon drugs Tepezza
and Krystexxa, used in the treatment of thyroid eye disease and chronic refractory gout, respecvely. The
complaint alleges that Amgen has a history of using rebates on its high-volume drugs through cross-mar-
ket bundling which may make it impossible for smaller rivals developing compeng drugs to compete,
Fiscal Year 2025 Congressional Budget Justication - Budget Request38
discouraging market entry. In September 2023, the FTC reached a proposed consent order with Amgen to
address the potenal compeve harm from the proposed acquision. Among other things, the proposed
order prevents Amgen from bundling any of its products with either Tepezza or Krystexxa or from condi-
oning any product rebate or contract terms on the sale or posioning of either drug.
• Pharmacy Benet Managers Secon 6 Study: The FTC ordered the six largest pharmacy benet managers
(“PBMs”) to provide informaon and records regarding their business pracces. The study focuses on the
impact of vercally integrated PBMs on the access and aordability of prescripon drugs. In FY 2023, as
part of its ongoing inquiry into PBMs and the FTC issued compulsory orders to three group purchasing
organizaons (“GPOs”) that negoate drug rebates on behalf of other PBMs.
• Physician Group and Healthcare Facility Mergers Secon 6 Study: The FTC connues its 6(b) study based
on orders issued to six health insurance companies to provide data that will allow the agency to study the
eects of physician consolidaon and healthcare facility consolidaon that occurred from 2015 through
2020.
• Cercates of Public Advantage Secon 6 Study: The FTC connues its 6(b) study on the eects of cerf-
icates of public advantage (COPA) on prices, quality, access, and innovaon of healthcare services as well
as on the impact of hospital consolidaon on employee wages. Partly due to the FTC’s COPA policy paper,
which was released last scal year, the state of Maine repealed its COPA law in April. The FTC has also
submied advocacy leers to state legislatures challenging requests for COPAs, which has led to pares
abandoning proposed mergers.
Promong Fair Compeon in Digital Markets
• Meta Monopolizaon Case: The Commission’s landmark monopolizaon case against Facebook (now
Meta), which was led in December 2020, is pending in federal court. The complaint alleged the company
has engaged in a systemac strategy, including the acquision of nascent competors, to maintain its mo-
nopoly, thereby allowing Meta to impose ancompeve terms on soware developers. The Commission
led an amended complaint in August 2021 and in January 2022, the judge denied Meta’s moon to
dismiss.
• Amazon Monopolizaon Case: In September 2023, the FTC, along with 17 state aorneys general, led
a complaint in federal court alleging that online retail and technology company Amazon.com, Inc. is a
monopolist that leverages a set of interlocking ancompeve and unfair strategies to illegally maintain
its monopoly power. According to the complaint, Amazon’s acons allow it to stop rivals and sellers from
lowering prices, degrade quality for shoppers, overcharge sellers, se innovaon, and prevent rivals
from fairly compeng. Importantly, the complaint makes clear that Amazon violates the law, not because
it is big, but because it engages in exclusionary conduct that ses the growth of exisng competors
and entry by new competors. The complaint focuses on two sets of ancompeve taccs employed by
the rm. These ancompeve taccs include an-discounng measures that punish sellers and deter
other online retailers from oering prices lower than Amazon’s, and condioning sellers’ ability to obtain
“Prime” eligibility for their products on the use of Amazon’s costly fulllment services, thus raising sellers’
costs. According to the complaint, these exclusionary taccs make it impossible for competors to gain
a foothold in the online superstore and online marketplace services markets. This maer is pending in
federal court.
• Mortgage Loan Originaon Plaorms Consent Order: In March 2023, the FTC issued a complaint seeking
to block Interconnental Exchange, Inc.’s proposed acquision of Black Knight Inc. The two rms are the
naon’s two largest providers of home mortgage loan originaon systems (LOS) and product pricing and
eligibility engines (PPE). The Commission alleged that the deal would drive up costs, reduce innovaon,
Fiscal Year 2025 Congressional Budget Justication - Budget Request
39
and reduce lenders’ choices. LOS are soware used to manage the documents and workow required to
generate a mortgage. PPEs are systems used by lenders to obtain the best interest rates for prospecve
homebuyers. ICE’s Encompass LOS competes head-to-head with Black Knight’s Empower plaorms, and
the rms also compete for the sale of a host of related services, including PPEs. The proposed deal would
eliminate the vital compeon and with it, and likely eliminate the discounts and price concessions the
two companies use to win or protect business from each other, to the detriment of lenders and home-
buyers. In August 2023, the Commission approved a consent order resolving its compeve concerns by
requiring Black Knight’s divesture of Empower and Opmal Blue, two businesses that provide crical
services in the mortgage originaon process, along with other terms designed to ensure the success of the
divested businesses.
• Cloud Compung Request for Informaon: The FTC issued a Request for Informaon (RFI) seeking in-
formaon on the business pracces of cloud compung providers, including issues related to the market
power of these companies, impact on compeon, and potenal security risks. The FTC also hosted a
virtual panel discussion with a diverse set of experts to discuss the business pracces of cloud compung
providers including issues related to security, compeon, and emerging technology issues associated with
cloud compung.
Promong Fair Compeon in Agriculture Markets
• Pescide An-compeve Conduct Case: The Commission connued to devote resources to its ongoing
ligaon alleging leading pescide manufacturers Syngenta Crop Protecon and Corteva blocked com-
petors from selling cheaper generic products to farmers. According to the complaint, the two pescide
manufacturers leveraged so-called “loyalty programs” in which distributors receive payments in exchange
for liming business with compeng manufacturers, allowing the rms to inate their prices, and forcing
American farmers to spend millions of dollars more for these crical products. The complaint seeks to
end these harmful pracces. In 2024, U.S. District Court Judge Thomas D. Schroeder denied Defendants’
Moon to Dismiss and this maer is pending.
• Retail Farm Stores Consent Order: In October 2022, the FTC issued a consent order to remedy concerns
related to Tractor Supply Company’s acquision of rival chain Orscheln Farm and Home LLC. Farm stores
oer customers a broad assortment of products to meet their farming, ranching, or other rural lifestyle
needs, including animal feed, supplies for the care of horses, livestock, and pets, fencing, and lawn and
garden supplies, among other products. The consent order requires Tractor Supply to divest several stores
and requires the receipt of prior approval before acquiring any other farm stores within 60 miles of any
divested locaon. The order also establishes prior approval provisions for the two divesture buyers for a
period of three years.
Promong Fair Compeon in Energy Markets
• Natural Gas: In August 2023, the FTC issued a consent order to resolve antrust concerns stemming from
a $5.2 billion deal between private equity rm Quantum Energy Partners and natural gas producer EQT
Corporaon. According to the complaint, Quantum and EQT are direct competors in the producon and
sale of natural gas in the Appalachian Basin, the largest natural gas-producing region in the United States;
the proposed deal would have made Quantum one of EQT’s largest shareholders and given Quantum (an
acve investor in natural gas in the region) a seat on EQT’s board of directors in violaon of the antrust
laws. The FTC’s order enacted ground-breaking structural relief, prohibing Quantum from occupying
the EQT board seat, requiring Quantum to divest its EQT shares, prohibing informaon exchange, and
unwinding a separate joint venture between the two enes, among other provisions – marking the rst
case in 40 years enforcing Secon 8 of the Clayton Act, which prohibits interlocking directorates.
Fiscal Year 2025 Congressional Budget Justication - Budget Request40
Promong Fair Compeon in Consumer Goods and Services
• Video Games: In December 2022, the FTC issued a complaint seeking to block Microso Corp. from acquir-
ing video game developer Acvision Blizzard, the largest proposed merger ever in the video game industry.
The FTC alleged that the deal would enable Microso to suppress competors to its Xbox gaming consoles
and its subscripon content (Xbox Game Pass) and cung-edge cloud-gaming business. According to the
complaint, Microso has a record of acquiring valuable gaming content and withholding that content from
rival consoles. Acvision is one of only a very small number of top video game developers in the world that
create and publish high-quality video games available for mulple devices. In July 2023, following a week-
long preliminary injuncon hearing, the federal court for the Northern District of California denied the
FTC’s request to temporarily enjoin the proposed transacon. This maer is pending on appeal in federal
court.
• Debit Card Payment Networks: In December 2022, the FTC issued a consent order ending the illegal
business taccs Mastercard employed to force merchants to route debit card payments through its pay-
ment network and requiring Mastercard to stop blocking the use of compeng debit payment networks.
Debit card payment networks are used by more than 80 percent of American adults and process $4 trillion
in purchases each year and are connuing to grow via new payment media such as Apple Pay, Google Pay,
and Samsung Wallet. These networks transmit payment informaon between points-of-sale and banking
instuons, transferring approvals or denials back to the merchant. Networks compete for the business
of banks that issue debit cards and for the business of merchants who accept debit card payments. The
payment networks charge processing fees for this transfer which are predominantly paid by the mer-
chant. In 2010, in an eort to increase compeon among these networks, Congress enacted the Durbin
Amendment to the Dodd-Frank Act, which requires banks to enable at least two unaliated networks
on every debit card, giving merchants a choice in which network to use for each transacon, and bars
payment networks from restricng the use of other networks. According to the complaint, Mastercard set
policies that blocked merchants from roung ecommerce transacons using Mastercard-branded debit
cards saved in e-wallets to alternave payment networks. The Commission approved a nal order in this
maer in May 2023.
• Supply Chain Disrupons Secon 6 Study: The FTC connues its study of the causes behind supply chain
disrupons, and three large retailers, three wholesalers, and three consumer good suppliers have been
ordered to provide detailed informaon.
Promong Fair Compeon in Labor Markets
• Noncompete Rulemaking: The FTC released a proposed rule to ban the use of noncompete agreements in
employment pracces, which binds about one in ve American workers, approximately 30 million people.
Empirical evidence shows that noncompetes suppress workers’ wages, deprive workers of dierent or bet-
ter employment opportunies, se innovaon, and block entrepreneurs from starng new businesses.
The FTC esmates that the proposed rule would raise all workers’ wages by up to $300 billion a year, save
consumers up to $148 billion annually on healthcare costs, and double the number of companies found-
ed by a former worker in the same industry. In response to the proposed rulemaking, the Commission
received tens of thousands of public comments from workers, employers, and business owners across a
broad range of income levels and sectors in the economy.
• Noncompete Enforcement: The Commission issued three orders to Ardagh Group, O-I Glass, Inc. and
Anchor Glass Container Corporaon, and a fourth to security services rm Prudenal Security Services
and Prudenal Command and their owners, that forced each rm to drop noncompete restricons in their
employment contracts. According to the complaints, the companies illegally imposed noncompete restric-
ons on workers in posions ranging from manufacturing to engineering or security guard services that
Fiscal Year 2025 Congressional Budget Justication - Budget Request
41
barred them from seeking or accepng work with another employer or operang a compeng business
aer leaving the companies.
• Partnership with NLRB: The Commission joined with the Naonal Labor Relaons Board (NLRB) in a
new inter-agency agreement aimed at bolstering the agency’s eorts to protect workers and promote
compeve U.S. labor markets. The agreement enables the FTC and NLRB to share informaon, conduct
cross-training, and partner in invesgave eorts within each agency’s respecve legal authories. The
areas of mutual interest outlined in the agreement include the extent and impact of labor market concen-
traon, labor market developments in the ‘gig economy,’ and the impact of algorithmic decision-making
on workers, among other areas.
• Partnership with DOL: The Commission and the U.S. Department of Labor signed a new agreement that
will bolster the FTC’s eorts to protect workers by protecng labor market compeon and pung an
end to unfair, decepve pracces that harm workers. The new memorandum of understanding (MOU)
between the two agencies outlines ways in which the FTC and DOL will work together on key issues such
as labor market concentraon, one-sided contract terms, and labor developments in the “gig economy.”
Compeon Law Enforcement Collaboraon and Advocacy
• Collaboraon with State Aorneys General: During FY 2023, the FTC strengthened collaboraon with
key state aorneys general. The FTC and a biparsan coalion of 10 state aorneys general connued its
ongoing ligaon against pescide manufacturers Syngenta and Corteva for blocking competors from
selling cheaper generic products to farmers, inang prices and forcing farmers to spend millions of dollars
more for their products. The FTC also joined with 17 state aorneys general in a lawsuit alleging that
Amazon illegally maintained its monopoly power and raised prices for sellers and shoppers. In addion,
the FTC has collaborated closely with state enforcers in protecng compeon in local markets, including
cooperang with 6 states on a consent order to address the potenal compeve harm that would have
otherwise resulted from Amgen Inc.’s acquision of Horizon Therapeucs plc.
• Advocacy in State Legislatures: In addion to the 6(b) Cercate of Public Advantage (COPA) study dis-
cussed above, the FTC submied a comment to North Carolina House Health Commiee members and
sta opposing North Carolina Senate Bill 743, which would aempt to prevent antrust authories from
challenging the University of North Carolina Health Care System for engaging in ancompeve mergers
and conduct. In a leer to the New York State Department of Health, FTC sta opposed a request by SUNY
Upstate Medical University and Crouse Health System to grant a COPA. The pares in that transacon
ulmately abandoned the transacon, protecng access to life-saving healthcare for paents in upstate
New York.
• Convening Compeon Enforcement Partners: The FTC and the DOJ Antrust Division hosted the second
annual Enforcers Summit, bringing together state, federal, and internaonal enforcement partners to
discuss compeon law enforcement and share insights on today’s market realies. The Enforcers Summit
included both publicly streamed plenary sessions as well as closed-door, in-person breakout sessions,
designed to share feedback, evidence, and ideas.
• Advocacy in the Courts: In FY 2023, the FTC led ve compeon amicus briefs in federal court.
• The Commission submied an amicus brief in Applied Medical Resources Corp. v. Medtronic, to clarify
the legal standards that apply in antrust cases involving exclusive-dealing and bundling arrangements,
both of which can harm compeon.
Fiscal Year 2025 Congressional Budget Justication - Budget Request42
• The Commission submied a second amicus brief in In re Bystolic Antrust Ligaon urging the Second
Circuit reverse the district court’s decision dismissing the private plains’ reverse-payment complaints
for failure to state a claim and to clarify the appropriate standards for pleading that a reverse payment
is unjused, arguing that the complaints met those standards.
• The Commission submied a third amicus brief in Sage Chemical, Inc. et al. v. Supernus
Pharmaceucals, Inc., et al. The brief explains: (1) the potenal harm to compeon and consumers
posed by a brand’s exclusion of generic compeon from the market; (2) that a competor’s markeng
of an FDA-approved generic pharmaceucal product intended to work with the branded product is not
improper free-riding under the antrust laws; (3) that exclusive agreements can substanally foreclose
compeon from the market by barring a potenal competor’s access to a key input even if that
competor could theorecally develop its own alternave to that input; and (4) that single-brand or
single-manufacturer markets are appropriate and not legally decient when there are no adequate
substutes.
• The Commission submied a fourth amicus brief in Deslandes v. McDonald’s. The FTC joined with the
Department of Jusce to argue that “no-hire” provisions in franchise agreements can be horizontal
in nature and that such agreements are per se unlawful unless the defendants establish that they are
ancillary to the franchise agreement, which requires a showing that they are reasonably necessary to
achieve a procompeve objecve. It also argues that the Supreme Court’s recent decision in NCAA v.
Alston did not change the standards for determining whether a horizontal restraint is per se illegal or
subject to quick-look condemnaon.
• The Commission led a h amicus brief in Jazz Pharmaceucals v. Avadel CNS Pharmaceucals. The
brief highlights the signicant harm to consumers when a brand company improperly lists a patent
on a distribuon system in the Food and Drug Administraon’s “Orange Book” and thereby blocks
generic or follow-on compeon. The FTC’s amicus brief explains how the Orange Book lisng process
can be abused and emphasizes the harm to compeon and consumers that can result from that
abuse, including depriving consumers of potenal price compeon and the ability to choose between
products.
• Providing Experse Internaonally: In February 2023, the FTC and the Antrust Division hosted a
workshop on compeon advocacy for the Compeon and Policy Law Group at the Asian and Pacic
Economic Cooperaon (APEC) Senior Ocials Meeng. This workshop built on APEC 2023 priories, which
include promong compeve markets throughout the Asia-Pacic region and fostering cooperaon
across APEC’s 21 economies. The FTC is also working with key partners in mullateral fora, such as the
Internaonal Compeon Network (ICN), the Compeon Commiee of the Organizaon for Economic
Cooperaon and Development, and the United Naons Conference on Trade and Development, to de-
velop enhanced cooperaon tools. For example, following the FTC’s signing the 2020 Mullateral Mutual
Assistance in Compeon Framework, the Commission is working with counterparts to develop enhanced
cooperaon agreements based on the Framework’s template, including the Canadian Compeon Bureau
and the New Zealand Commerce Commission.
Compeon Research, Outreach, and Public Educaon
• Open Commission Meengs: The FTC held eight Open Commission Meengs in FY 2023 to allow the
public to engage directly with the Commission and to open up agency work to the public. These meengs
give members of the public the opportunity to address the Commission and share their rsthand expe-
riences, and open up Commission deliberaon on key agency priories to the public—including how the
Commission is challenging improperly listed patents that raise prices for crical medical devices such as
inhalers and epi-pens, and the business pracces of cloud compung providers on which business and
Fiscal Year 2025 Congressional Budget Justication - Budget Request
43
entrepreneurs can be dependent. More than 150 members of the public, from small business owners to
independent pharmacists to grocery workers, shared rsthand accounts of challenges they are seeing in
the marketplace through these meengs in FY 2023, opening up the Commission’s work to thousands of
views across the country.
• Workshops: In FY 2023, the Bureau of Economics hosted its Fieenth Annual Microeconomics Conference.
The workshop brought together scholars working in areas related to the FTC’s antrust, consumer protec-
on, and public policy missions. The FTC also hosted a public forum examining the FTC’s proposed rule to
ban noncompete clauses. In partnership with the DOJ, the FTC hosted a workshop with former enforcers,
academics, economists, and praconers to discuss the 2023 Dra Merger Guidelines.
Annual Performance Report
For Fiscal Year 2023 and
Annual Performance Plan
For Fiscal Years 2024-2025
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
47
About This Report
The following document is the Annual Performance Report for scal year (FY) 2023 and the Annual
Performance Plan for FY 2024 and 2025 for the Federal Trade Commission (“FTC” or “Commission”). The report
is structured around three strategic goals and their supporng objecves as established in the FTC Strategic
Plan for FY 2022-2026. The FTC’s strategic goals, objecves, and performance metrics arculate what the
agency intends to accomplish to meet its mandated mission (Goals 1 and 2), support and improve the manage-
ment funcons vital to core mission success (Goal 3) and demonstrate the highest standards of stewardship.
• Strategic Goal 1: Protect the public from unfair or decepve acts or pracces in the marketplace.
• Strategic Goal 2: Protect the public from unfair methods of compeon in the marketplace and promote
fair compeon.
• Strategic Goal 3: Advance the FTC’s eecveness and performance.
Go to ftc.gov to see more of the agency’s performance and budget documents.
Agency and Mission Informaon
The FTC works to promote fair and open markets and protect the enre American public from decepve or
unfair business pracces. While primarily a law enforcement agency, the FTC uses a variety of other tools to
fulll its mission, including rulemaking, research, studies on marketplace trends and legal developments, public
outreach and engagement, and consumer and business educaon.
Our Mission
Protecng the public from decepve or unfair business pracces and from unfair methods of compeon
though law enforcement, advocacy, research, and educaon.
Our Vision
A vibrant economy fueled by fair compeon and an empowered, informed public.
Our History and Organizaon
The FTC is an independent agency that reports to the President and to Congress on its acons on behalf of the
American public. These acons include:
• Pursuing vigorous and eecve law enforcement;
• Advancing consumers’ interests by sharing experse with Congress, state legislatures, and U.S. and inter-
naonal agencies;
• Developing policy and research tools through hearings, workshops, and conferences;
• Creang praccal, plain language educaonal programs and materials for broad, diverse communies of
consumers and businesses in a global marketplace with constantly changing technologies;
• Disseminang informaon about the Commission’s acvies to the public to foster understanding, ac-
countability, public parcipaon, and transparency.
The FTC has a more than 100-year history of working to maintain a compeve marketplace for both consum-
ers and honest businesses. In 1914, the Federal Trade Commission Act created the FTC, to prevent unfair
methods of compeon in commerce as part of the bale to “bust the trusts.” Over the years, Congress
passed addional laws giving the agency greater authority over ancompeve pracces.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
48
In 1938, Congress amended the FTC Act and granted the FTC authority to stop “unfair or decepve acts or
pracces in or aecng commerce.” Since then, the FTC has been directed to enforce a wide variety of other
consumer protecon laws and regulaons.
The FTC is headed by a ve-member Commission nominated by the President and conrmed by the Senate,
each serving a staggered seven-year term. The President chooses one commissioner to serve as Chair. No more
than three commissioners may be from the same polical party.
The FTC’s mission is carried out by the Bureau of Consumer Protecon (BCP), the Bureau of Compeon (BC),
and the Bureau of Economics (BE). Their work is supported by the Oce of the General Counsel, the Oce
of Internaonal Aairs, the Oce of Technology, the Oce of Policy Planning, the Oce of the Secretary, the
Oce of the Execuve Director, the Oce of Congressional Relaons, the Oce of Public Aairs, the Oce
of Administrave Law Judges, the Oce of Workplace Inclusivity and Opportunity, the Oce of the Inspector
General, the Oce of the Chief Privacy Ocer, and eight regional oces across the country.
The FTC’s workforce is its greatest asset. At the end of FY 2023, the agency’s esmated full-me equivalent
ulizaon was 1,217. The total new budget authority for FY 2023 was $430 million.
Scope of Responsibilies
The FTC is an independent law enforcement agency with consumer protecon and compeon jurisdicon
in broad sectors of the economy. The agency administers a wide variety of laws, such as the Federal Trade
Commission Act (FTC Act), Fair Credit Reporng Act, and the Clayton Act. The Commission has enforcement
or administrave responsibilies under more than 70 laws. The FTC also enforces many rules issued pursu-
ant to the Federal Trade Commission Act or other laws, including the Business Opportunity Rule and the
Telemarkeng Sales Rule.
Performance Measurement Reporng Process
Bureau and oce representaves serve as the Performance Measure Reporng Ocials (PMRO), who act as
data stewards for each of the agency’s publicly reported performance metrics. The PMROs report performance
data to the Performance Improvement Ocer on a quarterly or annual basis via an internal data reporng tool.
The Financial Management Oce (FMO) also leads periodic performance metric reviews in coordinaon with
budget execuon reviews. Quarterly reports are sent to senior managers throughout the agency, allowing for
adjustments to agency strategies based on the interim results.
Vericaon and Validaon of Performance Data
The following outlines how the agency ensures the performance informaon it reports is complete, reliable,
and accurate:
• The FTC has adopted a central internal repository for performance data entry, reporng, and review. The
electronic data tool reduces human error, increases transparency, and facilitates review of the agency’s
performance informaon.
• Each PMRO is responsible for updang the data quality appendix (DQA) at least once per year. The DQA
serves as a process document, laying out data sources and collecon methods for performance informa-
on, as well as how metrics are calculated.
• PMROs must provide all supporng documentaon for their performance results at both the midpoint and
end of the scal year. This allows FMO Performance Sta to “dig beneath the surface” and see the data
underlying the metrics.
• Aer reviewing the underlying data, several metrics are selected each year to invesgate more thoroughly,
including interviewing the sta responsible for data collecon, asking about alternave methods, and
comparing data collecon and calculaons to those reported in the DQA.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
49
Strategic Goal 1: Protect the Public From Unfair or Decepve Acts or
Pracces in the Marketplace
The FTC uses a mul-pronged interdisciplinary approach to protect the public from unfair or decepve pracc-
es in the marketplace. The FTC conducts invesgaons, sues companies and people that violate the law, devel-
ops rules to protect the public, advocates to federal agencies for policies that protect consumers, and educates
consumers and businesses about their rights and responsibilies. The agency also collects reports about a host
of consumer issues, including fraud, identy the, nancial maers, and Do Not Call violaons. The FTC makes
these reports available to law enforcement agencies worldwide.
Because the FTC has jurisdicon over a wide range of consumer protecon issues, in order to carry out its
broad mission it must make eecve use of limited resources by targeng its law enforcement, advocacy, and
educaon eorts to achieve maximum impact and by working closely with federal, state, internaonal, and
private sector partners in joint iniaves. In addion, the agency engages in dialogue with a variety of stake-
holders to understand emerging issues. The FTC also conducts research on a variety of consumer protecon
topics.
The FTC focuses on invesgang and ligang conduct that causes or is likely to cause substanal injury to the
public. This includes not only monetary injury, but also, for example, unwarranted health, safety, and privacy
risks.
Through its Every Community Iniave, the FTC supports consumers in historically underserved communies,
which may be disproporonately aected by fraud and other consumer issues. These eorts include develop-
ing specic resources, conducng outreach and events, iniang law enforcement acons, and conducng
research to beer idenfy and understand the equity issues.
Four objecves guide work in this area:
• Objecve 1.1: Idenfy, invesgate, take acons against, and deter unfair or decepve acts or pracces
that harm the public.
• Objecve 1.2: Connect with individuals, communies, and businesses to provide praccal knowledge,
guidance, and tools, and to learn about key challenges and opportunies for future FTC engagement.
• Objecve 1.3: Collaborate with domesc and internaonal partners to enhance consumer protecon.
• Objecve 1.4: Support equity for historically underserved communies through the FTC’s consumer
protecon mission.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
50
Strategic Goal 1 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 1.1
Metric 1.1.1 Amount of money returned to the
public or forwarded to the U.S. Treasury resulng
from FTC enforcement acons.
$562.1
million
$639.8
million
$616.8
million
$65 million $65 million $65 million
Metric 1.1.2 Total consumer savings compared to
the amount of FTC resources allocated to consumer
protecon law enforcement.
$12.90 in
consumer
savings
per $1
spent
$9.40 in
consumer
savings
per $1
spent
$7.10 in
consumer
savings
per $1
spent
$7.00 in
consumer
savings
per $1
spent
$5.00 in
consumer
savings
per $1
spent
$5.00 in
consumer
savings
per $1
spent
Metric 1.1.3 Percentage of maers following up
on Commission market-wide policy iniaves, e.g.,
Noces of Penalty Oenses, Policy Statement on
Negave Opon Markeng, workshops, and reports.
N/A 25.5% 48.1% 20.0% 20.0% 20.0%
Metric 1.1.4 Percentage of maers seeking
signicant remedial, precedenal, or deterrent
eects across the marketplace.
N/A 72.3% 74.1% 65.0% 65.0% 65.0%
Metric 1.1.5 Percentage of cases involving
collaboraon across organizaonal units, e.g.,
regional oces and divisions, BC and BCP, Bureaus
and OPP.
N/A 39.2% 47.7% 35.0% 35.0% 35.0%
Metric 1.1.6 Percentage of the FTC’s consumer
protecon law enforcement acons that targeted
the subject of consumer reports in the FTC’s
Consumer Sennel Network.
85.2% 93.9% 97.7% 80.0% 80.0% 80.0%
Metric 1.1.7 User sasfacon with the FTC’s
Consumer Response Center call center.
84.0 84.0 85.0
Average
rate for
government
(72.1)
Average
rate for
government
Average
rate for
government
Metric 1.1.8 User sasfacon with the FTC’s
Consumer Response Center website.
(a) Mobile (b) Desktop
(a) 83.5
(b) 83.2
(a) 81.7
(b) 80.8
(a) 81.8
(b) 80.9
Average
rate for
government
(a) 72.1
(b) 69.7
Average
rate for
government
Average
rate for
government
Objecve 1.2
Metric 1.2.1 Rate of customer sasfacon with FTC
consumer educaon websites.
(a) Mobile (b) Desktop
(a) 73.5
(b) 70.9
(a) 70.5
(b) 69.1
(a) 70.0
(b) 64.7
(a) 70.70
(b) 69.26
Average
rate for
government
Average
rate for
government
Metric 1.2.2 Rate of customer sasfacon with the
c.gov website. (a) Mobile (b) Desktop
(a) 74.6
(b) 74.7
(a) 73.5
(b) 70.9
(a) 70.5
(b) 69.1
(a) 73.5
(b) 70.9
(a) 70.70
(b) 69.26
(a) 70.87
(b) 69.44
Metric 1.2.3 Number of outreach events. N/A 316 603 300 300 300
Metric 1.2.4 Number of unique page views for
consumer and business educaon digital arcle and
blog posts.
N/A
39.1
million
37.3
million
35.0
million
35.0
million
35.0
million
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
51
Strategic Goal 1 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 1.3
Metric 1.3.1 Number of invesgaons or cases
in which the FTC and other U.S. federal, state,
and local government agencies shared evidence
or informaon that contributed to FTC law
enforcement acons or enhanced consumer
protecon.
505 541 292 375 375 375
Metric 1.3.2 Number of invesgaons or cases in
which the FTC obtained foreign-based evidence or
informaon or engaged in other mutual assistance
that contributed to FTC law enforcement acons, or
in which the FTC cooperated with foreign agencies
and/or mullateral organizaons on enforcement
maers.
39 32 23 20 26 26
Objecve 1.4
Metric 1.4.1 Percentage of acons taken to
stop unfair or decepve pracces that we have
idened as 1) targeng historically underserved
communies; 2) disproporonately impacng
historically underserved communies; 3) involving
schemes or pracces that research has shown to
disproporonately impact historically underserved
communies; or 4) involving conduct in languages
other than English, including Nave American
languages.
N/A 23.4% 20.4% 20.0% 20.0% 20.0%
Metric 1.4.2 Percentage of redress payments made
to people who live in communies that have a high
proporon of members of historically underserved
communies.
(a) Based on total # of redress payments
(b) Based on the aggregate $$ distributed
N/A
(a) 35.1%
(b) N/A
(a) 26.0%
(b) 34.7%
30.0% met
by either
(a) or (b)
30.0% met
by either
(a) or (b)
30.0% met
by either
(a) or (b)
Metric 1.4.3 Number of outreach events targeng
diverse audiences.
N/A 179 308 165 165 165
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
52
Objecve 1.1: Idenfy, invesgate, take acons against, and deter unfair or decepve acts or pracces that
harm the public.
Goal Leaders: Director, Bureau of Consumer Protecon; Director, Bureau of Economics; Chief Technology
Ocer, Oce of Technology
The FTC protects the public by enforcing Secon 5 of the FTC Act, which prohibits unfair or decepve acts or
pracces in or aecng commerce, and by enforcing a number of statutes and rules proscribing specic unlaw-
ful pracces. The FTC’s Bureau of Consumer Protecon, with the support of the Bureau of Economics and the
Oce of Technology, invesgates cases and iniates civil enforcement acons, primarily by ling acons in
federal court, when there is reason to believe that enes have violated these laws and rules. The FTC’s en-
forcement acons seek injuncons and other relief. The FTC also brings enforcement acons via administrave
proceedings.
To fulll its goal of protecng the public, the FTC must idenfy consumer protecon issues and trends in the
fast-changing, increasingly global marketplace. The agency strives to understand the issues aecng the public,
including any newly emerging methods of fraud, so that it can target its enforcement, educaon, and advocacy
on those areas where the public suers the most harm. The FTC leverages its resources by sharing informaon
with and encouraging other law enforcement authories to assist it in its eorts, by acng either indepen-
dently or jointly.
To help ensure that its enforcement, educaon, and advocacy eorts are well-targeted, the Bureau of
Consumer Protecon works with the Bureau of Economics in evaluang economic harm to consumers as cases
and programs are developed.
The agency connues to collect consumer report informaon directly through the following sources:
• ReportFraud.ftc.gov for reporng fraud, scams, and bad business pracces, or through a toll-free helpline
(1-877-FTC- HELP)
• IdentityTheft.gov for reporng identy the, or through an identy the hotline (1-877-ID-THEFT)
• Donotcall.gov for reporng unwanted calls, or through the Naonal Do Not Call Registry helpline
(1-888-382-1222)
In addion, the FTC connues to gather consumer report informaon from other sources, including state,
federal, and internaonal law enforcement agencies, Beer Business Bureaus, postal mail, and private enes.
The Consumer Sennel Network (CSN) is the FTC’s secure website that provides nearly 3000 law enforcement
users worldwide with access to millions of consumer fraud, identy the, nancial, and Do Not Call Registry
reports collected during the past ve years. On a quarterly basis, the FTC includes informaon on the top con-
sumer reports received on its data analysis site at ftc.gov/exploredata. Data about the FTC’s refund program
is also available at ftc.gov/exploredata, including state-by-state and case-by-case breakdowns of the amount
refunded to consumers.
The FTC recognizes that consumers cannot always idenfy whether unfair or decepve pracces have oc-
curred. For example, consumers cannot evaluate for themselves the truthfulness of an environmental market-
ing claim, such as “made with recycled content.” The agency, therefore, idenes targets by augmenng its
complaint databases with other enforcement leads, such as ad monitoring, Internet “surfs” (monitoring the
Internet for potenally false or decepve adversing for a targeted product or service), evaluaon of mobile
pracces, and direct referrals from government and private sector partners.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
53
Strategies
• Idenfy consumer protecon violaons: Idenfy decepve and unfair business pracces that cause harm
to the public, including pracces that target or impact specic segments of the populaon, by monitoring
pracces in the marketplace and evaluang informaon from numerous sources, including reports sub-
mied to the Consumer Sennel Network (CSN) database by consumers and others. The FTC and its law
enforcement partners mine the CSN database to idenfy trends and targets, as well as to develop cases
against exisng targets.
• Enforce consumer protecon laws: Enforce the law to protect all segments of the populaon from fraud,
decepon, and unfair business pracces by safeguarding consumer privacy, monitoring naonal advers-
ing and new technologies, and suing enes that violate federal court and administrave orders obtained
by the FTC. Negoate consent orders and pursue ligated orders that have signicant remedial, preceden-
al, and deterrent eects.
• Improve ligaon skills: Improve sta negoaon and ligaon skills and rene invesgave and deci-
sional tools through connuous learning.
External Factors and Risks
• New Legislaon
• New Congressional legislaon could aect the agency’s ability to take law enforcement acon.
• Budget and Stang Levels
• A reducon in budget and/or stang levels could reduce the agency’s ability to take law enforcement
acon.
• Increasing Ligaon Costs
• Increasing costs related to ligaon, including processing and storing increasingly large amounts of
electronic invesgaon and case data, can lead to fewer invesgaons and cases.
• Legal Challenges
• Legal challenges and adverse court rulings on them, such as the AMG Capital Mgmt., LLC v. FTC
Supreme Court case, may limit the FTC’s enforcement authority or ability to obtain eecve relief for
consumers.
• In addion, recent court rulings have made it even more me consuming and resource intensive for
the Commission to use its administrave process to obtain refunds for harmed consumers in consumer
protecon cases.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Evaluate whether enforcement acvies are tracking the areas where the public suers the most harm
and whether new pracces or technologies require addional law enforcement focus, educaon, and
advocacy.
• Evaluate economic and other harms to consumers as cases and programs are developed.
• Connue to evaluate the ecacy of promulgated rules and regulaons and other policy documents.
• Connue to evaluate and implement opons for connuing to secure relief for consumers post-AMG
Capital Mgmt., LLC v. FTC.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
54
Performance Metrics
Metric 1.1.1: Amount of money returned to the public or forwarded to the U.S. Treasury resulng from FTC
enforcement acons.
This metric tracks the FTC’s eecveness in returning money to consumers who were defrauded and forward-
ing money to the U.S. Treasury (e.g., if sending money to individuals is impraccable, or if funds were paid
as a civil penalty). The FTC targets law enforcement eorts on violaons that cause the greatest amount of
consumer harm; the amount of money returned to consumers or forwarded to the U.S. Treasury is a useful
indicator that the FTC is targeng the right defendants. The amount of money returned to consumers and the
U.S. Treasury connues to be reduced due to the Supreme Court’s 2021 decision in AMG Capital Mgmt., LLC v.
FTC, which held that the FTC does not have the ability to obtain monetary relief pursuant to Secon 13(b) of
the FTC Act.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
$971.1
million
$5.65 billion
$562.1
million
$639.8
million
$616.8
million
$65.0
million
Exceeded
$65.0
million
$65.0
million
Note: In previous annual performance reports, the yearly results for this metric were reported as a three-year
rolling average (average of the current year and two prior year totals). Starng this year, we will be reporng
single year results for each scal year. This change also applies to Metric 1.1.2.
Note: For comparave purposes, prior scal year results have been updated to reect the new single year
reporng methodology as follows. The result for FY19 has changed from $3.52 billion, reported previously,
to $971.1 million. The result for FY20 has changed from $2.79 billion, reported previously, to $5.65 billion.
The result for FY21 has changed from $2.39 billion, reported previously, to $562.1 million. The result for FY22
has changed from $2.28 billion, reported previously, to $639.8 million. All of these changes are as a result of
removing the three-year rolling average that was previously used.
Note: In the FY 2023 Agency Financial Report, the FY 2023 Actual for Metric 1.1.1 was reported as $342.1
million. Since publicaon of that result, a mistake was found in the data. The civil penalty amount for the Epic
case was incorrectly listed as $275 thousand instead of $275 million. The result shown here ($616.8 million) is
the corrected result.
FY 2023 Highlights: In FY 2023, the FTC returned $99.1 million to consumers and forwarded $331.5 million to
the U.S. Treasury. The FTC returned money to more than 1.3 million consumers in dozens of cases, including
Napleton Automove, Warrior Trading, Passport Auto, Arete Financial, and American Financial Benets Center
(Ameritech). The money returned to the U.S. Treasury included civil penales obtained in selements with
Epic, Microso, and Amazon.com. In addion, some FTC orders required defendants to self-administer refund
programs worth more than $186.3 million in refunds to consumers, including the MoneyGram, Equifax, and
Western Union cases.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
55
Metric 1.1.2: Total consumer savings compared to the amount of FTC resources allocated to consumer protec-
on law enforcement.
This metric tracks the return on investment of the FTC’s consumer protecon law enforcement spending. We
compare how much money the FTC saves consumers each year through law enforcement to the amount the
FTC spends on consumer protecon law enforcement. Consumer savings are comprised of: (a) the amount of
money returned to consumers; and (b) an esmate of the amount of harm that would have occurred but for
the FTC’s law enforcement acon. To calculate this laer gure, the FTC assumes that the unlawful conduct
would have connued for one year but for our acon. The FTC also assumes that the amount of harm that
would have occurred in that year is the same as what consumers lost in the past. The amount of consumer
savings connues to be reduced due to the Supreme Court’s 2021 decision in AMG Capital Mgmt., LLC v. FTC,
which held that the FTC does not have the ability to obtain monetary relief pursuant to Secon 13(b) of the
FTC Act.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
$13.00 in
consumer
savings per
$1 spent
$12.70 in
consumer
savings per
$1 spent
$12.90 in
consumer
savings per
$1 spent
$9.40 in
consumer
savings per
$1 spent
$7.10 in
consumer
savings per
$1 spent
$7.00 in
consumer
savings per
$1 spent
Exceeded
$5.00 in
consumer
savings per
$1 spent
$5.00 in
consumer
savings per
$1 spent
Note: In previous annual performance reports, the yearly results for this metric were reported as a three-year
rolling average (average of the current year and two prior year totals). Starng this year, we will be reporng
single year results for each scal year. This change also applies to Metric 1.1.1.
Note: For comparave purposes, prior scal year results have been updated to reect the new single year
reporng methodology as follows. The result for FY19 has changed from $39.40 per $1 spent, reported previ-
ously, to $13.00 per $1 spent. The result for FY20 has changed from $14.80 per $1 spent, reported previously,
to $12.70 per $1 spent. The result for FY21 has changed from $12.80 per $1 spent, reported previously, to
$12.90 per $1 spent. The result for FY22 has changed from $11.60 per $1 spent, reported previously, to $9.40
per $1 spent. All of these changes are as a result of removing the three-year rolling average that was previously
used.
FY 2023 Highlights: In FY 2023, the agency saved consumers on average over 7.1 mes the amount of re-
sources devoted to the consumer protecon program. In FY 2023, the esmate of consumer harm prevented
was $569 million. Selements obtained in the Nudge, Epic Games, and Fleetcor Technologies cases comprised
a signicant poron of this amount.
Metric 1.1.3: Percentage of maers following up on Commission market-wide policy iniaves, e.g., Noces of
Penalty Oenses, Policy Statement on Negave Opon Markeng, workshops, and reports.
This metric tracks the FTC’s eecveness in following up on Commission market-wide policy iniaves. This
ensures we are understanding and responding to emerging trends in the marketplace, parcularly problems
that cause substanal consumer nancial losses.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 25.5% 48.1% 20.0% Exceeded 20.0% 20.0%
FY 2023 Highlights: In FY 2023, 26 of 54 enforcement maers followed up on Commission market-wide policy
iniaves.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
56
Metric 1.1.4: Percentage of maers seeking signicant remedial, precedenal, or deterrent eects across the
marketplace.
This metric tracks the FTC’s eecveness in negoang consent orders and pursuing ligated orders that have
a posive eect that goes beyond the individual defendant. Maers that seek signicant remedial, preceden-
al, and deterrent eects can have a larger impact on consumers.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 72.3% 74.1% 65.0% Exceeded 65.0% 65.0%
FY 2023 Highlights: In FY 2023, 40 of 54 enforcement maers sought signicant remedial, precedenal, or
deterrent eects across the marketplace.
Metric 1.1.5: Percentage of cases involving collaboraon across organizaonal units, e.g., regional oces and
divisions, BC and BCP, Bureaus and OPP.
This metric tracks the FTC’s eecveness in collaborang across organizaonal units. This interdisciplinary ap-
proach to protecng the public maximizes the agency’s ability to analyze and assess appropriate remedies.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 39.2% 47.7% 35.0% Exceeded 35.0% 35.0%
FY 2023 Highlights: In FY 2023, 31 of 65 completed cases involved collaboraon across organizaonal units.
Metric 1.1.6: Percentage of the FTC’s consumer protecon law enforcement acons that targeted the subject
of consumer reports in the FTC’s Consumer Sennel Network.
The FTC collects reports about a host of consumer issues, including fraud, identy the, nancial maers, and
Do Not Call violaons. Reports are an integral component when determining the areas of greatest concern
and injury to consumers. This metric gauges how well the FTC’s consumer protecon law enforcement acons
target the subject of consumer reports.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
87.8% 90.5% 85.2% 93.9% 97.7% 80.0% Exceeded 80.0% 80.0%
FY 2023 Highlights: In FY 2023, 42 of 43 of BCP’s law enforcement acons targeted the subject of consumer
complaints to the FTC. Because BCP augments idencaon of targets from its databases with other strategies
for generang enforcement leads—such as monitoring compliance with FTC orders, ad monitoring, internet
surfs, mobile applicaon surveys, and direct referrals from government and private-sector partners—the
results vary from year to year.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
57
Metric 1.1.7: User sasfacon with the FTC’s Consumer Response Center call center.
This metric quanes how sased consumers are with the FTC’s Consumer Response Center, which is respon-
sible for collecng consumer complaints. Sasfacon is measured separately for consumers ling complaints
through online forms, and for those ling complaints through the call center. The Consumer Response Center is
oen consumers’ rst contact with the FTC, and if consumers do not have a sasfactory experience, they may
be less likely to le complaints. Consumer complaints help the FTC idenfy consumer protecon issues and
trends in the fast-changing, increasingly global marketplace.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
84.0 84.0 84.0 84.0 85.0
Average
government
sasfacon
rate
(72.1)
Exceeded
Average
government
sasfacon
rate
Average
government
sasfacon
rate
FY 2023 Highlights: The FTC’s Consumer Response Center call center connues to perform above the private
and public industry benchmarks.
Metric 1.1.8: User sasfacon with the FTC Consumer Response Center website.
This metric quanes how sased consumers are with the FTC’s Consumer Response Center, which is respon-
sible for collecng consumer reports. Sasfacon is measured separately for consumers ling reports through
online forms, and for those ling reports through the call center. The Consumer Response Center is oen
consumers’ rst contact with the FTC, and if consumers do not have a sasfactory experience, they may be less
likely to le reports. Consumer reports help the FTC to idenfy consumer protecon issues and trends in the
fast-changing, increasingly global marketplace.
(a) Mobile
(b) Desktop
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
(a) N/A
(b) 81.2
(a) 83.3
(b) 82.0
(a) 83.5
(b) 83.2
(a) 81.7
(b) 80.8
(a) 81.8
(b) 80.9
Average
government
sasfacon
rate
(a) 72.1
(b) 69.7
(a) Exceeded
(b) Exceeded
Average
government
sasfacon
rate
Average
government
sasfacon
rate
Note: In previous annual performance reports, we reported a single combined desktop/mobile score for this
metric. Starng this year, we have decided to separately report our (a) mobile and (b) desktop scores.
FY 2023 Highlights: The FTC’s Consumer Response Center website connues to perform above the private and
public industry benchmarks.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
58
Secondary Metric 1.1.9: Number of reports collected and entered into the Consumer Sennel Network (CSN)
database.
The agency uses the Consumer Sennel Network (CSN) as a repository for millions of consumer complaints
from a variety of sources, including direct consumer reports to the FTC and complaints received by the FTC’s
partners. CSN provides law enforcement members with access to millions of consumer complaints.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
8.5 million 8.3 million 11.0 million 8.0 million 7.8 million
Secondary Metric 1.1.10: The percentage of redress cases in which money designated for distribuon is mailed
to consumers within 6 months.
This secondary metric ensures that the FTC returns redress dollars to injured consumers as quickly as pos-
sible. Money is considered “designated for distribuon” when the FTC is in receipt of all funds, legal issues are
resolved, and a usable claimant list is ready. If there is a claims process in which consumers must apply for a
refund, then dollars are “designated for distribuon” aer all claims have been reviewed and veried.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
91.7% 93.1% 100% 85.2% 100%
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
59
Objecve 1.2: Connect with individuals, communies, and businesses to provide praccal knowledge, guid-
ance, and tools, and to learn about key challenges and opportunies for future FTC engagement.
Goal Leaders: Director, Bureau of Consumer Protecon; Director, Bureau of Economics; Director, Oce of
Public Aairs
Consumer and business educaon serves as an important and vital resource in ghng against decepve or
unfair pracces. Well-informed consumers are beer able to recognize, avoid, and report fraud, and well-
informed business owners know where the FTC draws the line.
Most FTC law enforcement iniaves include a consumer and/or business educaon component aimed at
prevenng consumer injury and unlawful business pracces and migang nancial losses. The agency also
conducts consumer and business educaon campaigns to raise awareness of new or emerging marketplace
issues that have the potenal to cause harm.
The FTC holds open Commission meengs to allow the public to gain insight into the work and priories of the
agency. Establishing a regular public forum allows for the development of a robust parcipatory process that
includes the consumers, workers, and honest business owners the FTC has a legislave mandate to protect.
The FTC has a unique mandate to undertake certain forms of research based on Secon 6 of the FTC Act.
Under this authority, the FTC gathers, analyzes, and makes public certain informaon that serves the public
interest. The FTC also convenes conferences and workshops through which experts and other experienced and
knowledgeable pares idenfy emerging consumer protecon issues and discuss ways to address those issues.
The FTC recognizes that stakeholders outside the government have also been tasked with addressing certain
consumer protecon issues. The agency, therefore, carefully monitors self-regulatory eorts and partners with
the private sector to disseminate consumer educaon content developed by the agency.
Strategies
• Improve educaon and engagement eorts: Focus consumer and business educaon eorts on areas
where decepon, unfair pracces, and informaon gaps cause the greatest injury. Determine this by
understanding with qualitave and quantave approaches what harms are most impacng consumers.
Target groups with messages about marketplace issues that impact their health, safety, and economic
well-being in channels, formats, and methods people are most engaged in depending on the topic. Adopt
and employ usability tesng, user research, and other human-centered strategies to ensure that FTC sta
understands user needs and can help appropriately.
• Use consumer insights to share crical informaon with internal FTC members including leadership,
case, and legal teams: Through engaging with consumers and communies and employing dierent
consumer feedback mechanisms, including solicing public comments at open Commission meengs,
analyze and aggregate crical ndings to disseminate informaon learned directly from consumers to FTC
employees.
• Engage with local community and grassroots organizaons: Build a strategy to engage with and make
connecons with consumers. Maintain strong relaonships with community-based organizaons and ad-
vocacy organizaons naonwide, while connuously seeking new ways to build relaonships with trusted
community leaders (e.g., church leaders, teachers, community organizers, non-prot leaders, etc.). Follow
up with all organizaons to understand what materials were helpful or not and why and build relaonships
to maximize the agency’s public consumer outreach.
• Help vicms of identy the: Educate the public about identy the and provide user-friendly, aconable
informaon to those who have become vicms of identy the.
• Promote reporng, online resources, and avenues to beer engage directly with the public and gather
public feedback: Publicize the FTC’s “Report Fraud” and identy the websites and toll-free numbers in
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
60
an ongoing eort to increase public awareness and inform the public of ways to contact the FTC to obtain
informaon or le a fraud report.
• Engage with and educate small businesses: Understand and listen to small business needs by employ-
ing user feedback and engagement opportunies. Provide small businesses with praccal, user-friendly
educaonal resources to help them understand the law so they can comply with it and idenfy when they
are vicms of unlawful conduct.
• Reach out to workers: Provide workers and those looking for work, including those in historically under-
served communies, with praccal, user-friendly educaonal resources and informaon to help them
idenfy and report consumer protecon violaons in the marketplace.
• Study emerging consumer protecon issues: Idenfy emerging consumer protecon issues relang to the
marketplace and technological developments, hold workshops or conferences to examine and solve/im-
prove those issues, and, whenever possible, publish ndings or create ways to link the learnings to acon
to help prevent consumer harm.
• Work with the media: Engage the media as part of a strategic communicaons program to disseminate
usable, helpful, clear, and compelling content to the public at large with the goal of ensuring consumers
understand what companies did wrong and what the FTC is doing to stop them. Idenfy and make maxi-
mum use of upcoming media opportunies, maintain strong relaonships with Washington-based, re-
gional and trade reporters, while connuously seeking new outlets and reporters to maximize the agency’s
media outreach. Work to make sta available for interviews with print, digital, and broadcast outlets as
well as nontradional outlets such as podcasters and bloggers.
• Use dierent communicaon channels that consumers frequent including trusted leader distribuon,
digital communicaons, social media, or physical forms of informaon disseminaon: Connuously
assess where users most digest informaon from trusted sources to determine their messaging reach and
eecveness, and then add them to the OPA communicaons toolbox if appropriate. Use these plaorms
to reach members of the media and those marginalized members of the public who may not receive FTC
press releases, blog posts, and other informaon through tradional sources such as email. Connuously
monitor the user experience and performance of FTC informaon distribuon and success including FTC.
gov and make improvements to enable visitors to complete their tasks.
External Factors and Risks
• Budget and sta limitaons
• Budget limitaons aect the FTC’s ability to increase both sta and contract support, increase dissemi-
naon of informaon, and maximize its reach through web services.
• Rising costs for supplies and shipping aect the FTC’s ability to maintain the present level of distribu-
on of print materials and aect its ability to meet increasing demand as the agency expands its reach
to a broader audience.
• Rising costs of communicaons plaorms that are compliant with the agency and government’s cyber-
security requirements aect the FTC’s ability to disseminate and evaluate its online communicaons.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Review the focus and performance of FTC educaon eorts; determine whether the agency needs to
reach new audiences on new topics or in new languages, in light of changes in demographics, emerging
digital adversing issues, decepve markeng pracces, and emerging technologies; idenfy strategies or
partnerships that will allow the FTC to reach those audiences; engage in user tesng and human-centered
tesng, as appropriate; and apply learnings from analycs to improve educaon eorts and products.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
61
• Review the focus and performance of FTC educaon eorts in reaching historically underserved communi-
es, as described more fully in Objecve 1.4.
• Research and apply analycs data, customer sasfacon feedback, and website standards and best prac-
ces to connue improving the user experience, performance, and features of the FTC.gov websites.
• Review and apply guidance from OMB M-23-22 to deliver digital-rst experiences on FTC websites.
• Expand the agency’s capacity to target and engage Spanish-speaking media and thereby reach the growing
Spanish-speaking populaon.
Performance Metrics
Metric 1.2.1: Rate of consumer sasfacon with FTC consumer educaon websites.
(a)Mobile
(b)Desktop
Consumer and business educaon serves as an important and vital resource in ghng against decepve or
unfair pracces. Well-informed consumers are beer able to recognize and report fraud, and well-informed
business owners know where the FTC draws the line. This metric gauges the eecveness, helpfulness, and
usability of the FTC’s consumer educaon website and includes the customer sasfacon scores for
consumer.ftc.gov.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
(b) 77.7 (b) 76.2 (b) 72.9
(a) 73.5
(b) 73.4
(a) 73.4
(b) 74.9
Average
government
sasfacon
rate
(a) 72.1
(b) 69.7
(a) Exceeded
(b) Exceeded
Average
government
sasfacon
rate
Average
government
sasfacon
rate
FY 2023 Highlights: The FTC’s consumer educaon websites performed above the average cizen sasfacon
score for parcipang federal government websites. The Division of Consumer and Business Educaon web-
sites oer mely and relevant content that answers users’ quesons and helps them complete their desired
task, like learn if something is a scam and how to report it. Desktop sasfacon for consumer educaon web-
sites exceeded the federal government benchmark by more than ve points.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
62
Metric 1.2.2: Rate of customer sasfacon with the c.gov website.
(a) Mobile
(b)Desktop
This metric gathers site visitor feedback to determine the eecveness of the FTC.gov website in enabling
visitors to successfully complete their tasks and nd the informaon they seek. Customer sasfacon is deter-
mined in a variety of funconal areas and is benchmarked against other federal websites. The data enables the
FTC to idenfy strengths and weaknesses in site components such as navigaon, look and feel, search, content,
etc., analyze the weaknesses, and take acon to migate or prevent issues that hamper customer task comple-
on and negavely impact sasfacon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
(b) 76.7
(a) 74.6
(b) 74.7
(a) 73.5
(b) 70.9
(a) 70.5
(b) 69.1
(a) 70.02
(b) 64.7
(a) 70.70
(b) 69.26
(a) Not Met
(b) Not Met
Average
government
sasfacon
rate
Average
government
sasfacon
rate
FY 2023 Highlights: The new FTC.gov websites launched in March 2022 with improved navigaon, an updated
and more secure plaorm, a new Legal Library, and a more modern look and feel. Although not unexpected,
customer sasfacon numbers declined aer launch due to repeat visitors’ inial frustraon in nding that
content had been relocated or removed. However, numbers were higher among rst-me visitors of the site
who reported that the look and feel and site informaon were sasfactory. Overall sasfacon rates are in-
creasing as the OPA Web and Digital Strategy team connues to review website analycs and customer experi-
ence data to determine the best ways users can nd and execute important tasks on FTC.gov.
Metric 1.2.3: Number of outreach events.
The FTC conducts outreach events to provide praccal knowledge, guidance, and tools, and to learn about key
challenges and opportunies for future FTC engagement.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 316 603 300 Exceeded 300 300
FY 2023 Highlights: In FY 2023, the FTC parcipated in more than 600 outreach events that reached thousands
of community leaders and advocates, business owners, librarians, and others in communies across the na-
on. These events were both in-person and virtual, in English and Spanish, and many focused on tradionally
underserved communies. For example, the FTC spoke at a panel to discuss latest iniaves to protect service-
members, veterans, and families, distributed print materials on cybersecurity at an event targeted to African
American business owners, and shared advice on scams that target Lanos and how to avoid and report them,
among others.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
63
Metric 1.2.4: Number of unique page views for consumer and business educaon digital arcles and blog
posts.
This metric gauges the reach of the agency’s educaon messages for consumers and businesses via the web.
The metric counts the number of unique page views of FTC consumer educaon arcles, blog posts, and other
materials on FTC websites, as well as the unique page views of FTC business educaon plain-language guidance
arcles, blog posts, and other materials.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 39.1 million 37.3 million 35.0 million Exceeded 35.0 million 35.0 million
FY 2023 Highlights: DCBE consumer and business websites exceeded the target of 35 million unique pageviews
in FY 2023. DCBE consumer and business websites draw visitors from a variety of sources. The sites are op-
mized to aract visitors searching for specic informaon. Many external websites link to DCBE consumer and
business educaon websites. DCBE acvely promotes new consumer and business blog posts through email
markeng and the FTC’s Oce of Public Aairs regularly distributes them the FTC’s social media channels.
Secondary Metric 1.2.5: Number of consumer protecon reports the FTC issued.
FTC sta prepare reports regarding current important topics in consumer protecon, and these reports are
the basis for this secondary metric. Consumer protecon reports provide informaon to decisionmakers, both
internally and externally, to help them understand important contemporary issues. This metric also ensures
that the FTC releases a variety of informave reports to the public that help promote the understanding and
awareness of consumer protecon issues.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
11 23 13 12 11
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Objecve 1.3: Collaborate with domesc and internaonal partners to enhance consumer protecon.
Goal Leaders: Director, Bureau of Consumer Protecon; Director, Oce of Internaonal Aairs
Geographic locaon and other demographics may aect the types of decepve and unfair conduct that con-
sumers encounter. It is, therefore, important for governmental and non-governmental organizaons to share
informaon and resources to enhance consumer protecon. The FTC works with partners in the United States
and internaonally to address consumer protecon challenges, including new and emerging ones.
The FTC promotes consumer protecon domescally by partnering with federal and state law enforcement in
lawsuits that challenge and stop unlawful pracces and seek redress for vicms. It also promotes consumer
protecon through advocacy by ling comments with federal, state, and local government bodies and amicus
briefs with the courts.
Because telemarkeng and internet fraud, privacy violaons, and data security breaches are increasingly
cross-border in scope, the FTC rounely cooperates and collaborates with its foreign counterparts to imple-
ment broad-based internaonal programs that combine cross-border law enforcement, policy, and technical
assistance work.
Strategies
• Collaborate on law enforcement at home and abroad: Build strong bilateral relaons with foreign and
domesc counterparts, share informaon, engage in invesgave assistance, and develop and strengthen
other types of enforcement cooperaon on invesgaons, cases, and enforcement-related projects.
Cooperate and collaborate with our foreign counterparts on cross-border law enforcement iniaves and
policy development consistent with U.S. and internaonal best pracces.
• Provide internaonal technical assistance: Provide technical assistance to countries that are establishing
consumer protecon regimes. Provide selected foreign ocials with an opportunity to work alongside
FTC aorneys, economists, and invesgators to enhance their capacity to develop and implement sound
consumer protecon policy and enforcement.
External Factors and Risks
• Budget limitaons
• Budget limitaons could lead to fewer invesgaons and cases, which could decrease the amount of
informaon sharing with domesc and internaonal partners.
• Limited control over state, local, federal, and internaonal agency and private enty cooperaon
• Hurdles to informaon sharing can se enforcement eorts.
• Providing internaonal technical assistance would be hampered if external resources are not available,
U.S. embassies abroad are not supporve, or foreign governments are not willing to accept U.S. assis-
tance and advice.
• The FTC uses its U.S. SAFE WEB Act authority to expand its internaonal enforcement eorts and con-
nues its outreach eorts to foreign governments to increase cooperaon. With the Act due to sunset
in 2027, it may be dicult for the agency to enter new, long-term cooperaon arrangements without
having the informaon sharing and invesgave assistance authority provided by the Act as part of its
permanent authority.
• Resource Constraints
• Some foreign counterparts may not have the resources to cooperate with the FTC or may operate with
reduced goals or priories that do not align fully with those of the FTC.
• The Internaonal Fellows Program may be hampered if travel is restricted due to resource or other
limitaons.
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FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Connue to work with other U.S. government agencies as appropriate to address global issues of mutual
concern, including by engaging with agencies that are developing legislaon on consumer and privacy
issues, by parcipang in the negoaon of consumer protecon provisions of trade agreements, and to
develop mechanisms for transatlanc data ows consistent with strong privacy protecons.
• Develop new iniaves with foreign counterparts on consumer fraud and other unlawful conduct, nding
new ways of working with foreign counterparts due to connued concerns about in-person gatherings.
• Work with internaonal partners to strengthen cooperaon among enforcement partners, bilaterally and
through mullateral organizaons such as the ICPEN, UCENet, and GAEN (Global An-Fraud Enforcement
Network). Encourage coordinated enforcement acons that protect U.S. consumers. Enhanced coopera-
on may include new and expanded iniaves with foreign criminal authories and private sector part-
ners, parcularly in countries that are increasingly the source of fraud directed at American consumers.
• Restart the Internaonal Fellows program and pursue technical assistance in appropriate regions, in
cooperaon with USAID and otherwise, taking into consideraon opportunies to enhance enforcement
cooperaon to protect American consumers.
• Connue to highlight the importance of strong enforcement as a key component of consumer protec-
on, including on privacy and data security and messaging abuses such as robocalls and spam, within the
OECD, APEC (including the Digital Commerce Steering Group), the Global Privacy Assembly (formerly the
Internaonal Conference of Data Protecon and Privacy Commissioners), and other mullateral policy
organizaons.
• Work closely through GPEN and directly with foreign data protecon authories to provide enforcement
assistance, which, in appropriate cases, could include informaon sharing and invesgave assistance
pursuant to the U.S. SAFE WEB Act.
• Engage in enforcement cooperaon pursuant to the APEC Cross-Border Privacy Rules (CBPR) and work to
expand membership in the CBPR system.
• Seek permanent reauthorizaon of the U.S. SAFE WEB Act, which provides the FTC with crical tools for
cross-border enforcement and cooperaon. On October 20, 2020, the Act was reauthorized with a seven-
year sunset provision, expiring in 2027.
• Further develop empirical evidence internaonally on eects of new technologies and business models on
consumer behavior, including work on measuring the eects of consumer protecon, such as measuring
harm from consumer fraud and consumer law violaons.
• Engage with the Intergovernmental Group of Experts on Consumer Protecon at the UNCTAD to develop
and implement best pracces under the revised 2015 UN Guidelines on Consumer Protecon and develop
new opportunies for capacity building and technical cooperaon with developing agencies.
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Metric 1.3.1: Number of invesgaons or cases in which the FTC and other U.S. federal, state, and local
government agencies shared evidence or informaon that contributed to FTC law enforcement acons or
enhanced consumer protecon.
This metric tracks the amount of informaon sharing by the FTC and other domesc law enforcement agencies
to further the goal of protecng consumers from fraud. The geographic locaon and other demographics may
aect the types of fraud that consumers encounter, making it important for government agencies to share
informaon and resources to enhance consumer protecon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
453 551 505 541 292 375 Not Met 375 375
FY 2023 Highlights: Although the FTC shared evidence in 292 invesgaons or cases, the FTC fell short in meet-
ing its target for performance goal 1.3.1. BCP connues to place an emphasis on leveraging resources with
domesc partners and encourages sta to work with other U.S. federal, state, and local government agencies
to further to goal of protecng consumers from fraud. In FY 2023, BCP shared informaon with other U.S.
federal, state, and local government agencies in 160 invesgaons or cases. In FY 2023, BCP received informa-
on from other U.S. federal, state, and local government agencies in 132 invesgaons or cases. The FY 2023
results do not include more than 180 acons resulng from a new crackdown on illegal telemarkeng calls, a
joint iniave between the FTC and more than 100 federal and state law enforcement partners naonwide,
including the aorneys general from all 50 states and the District of Columbia. Eecve FY 2024, we will revise
our calculaon for this measure to include law enforcement sweeps.
Metric 1.3.2: Number of invesgaons or cases in which the FTC obtained foreign-based evidence or informa-
on or engaged in other mutual assistance that contributed to FTC law enforcement acons or in which the
FTC cooperated with foreign agencies and/or mullateral organizaons on enforcement maers.
The FTC’s Oce of Internaonal Aairs works to expand cooperaon and coordinaon between the FTC and
internaonal consumer protecon partners through informaon sharing, invesgave assistance, and the
development of invesgave best pracces and enforcement capacity. This metric counts the number of inves-
gaons and cases in which the FTC and foreign consumer protecon agencies shared informaon or engaged
in other enforcement cooperaon, such as sharing consumer complaints, obtaining corporate records, and
providing other invesgave informaon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
48 42 39 32 23 20 Exceeded 26 26
FY 2023 Highlights: In FY 2023, the FTC cooperated in 23 instances on consumer protecon and privacy mat-
ters to obtain or share evidence or engage in other enforcement cooperaon in invesgaons, cases, and
enforcement related projects. The lingering eects of the global pandemic, as expected, connue to adversely
impact our cross-border cooperaon. It remains to be seen how quickly our enforcement cooperaon numbers
return to pre-pandemic levels.
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Objecve 1.4: Support equity for historically underserved communies through the FTC’s consumer protec-
on mission.
Goal Leaders: Director, Bureau of Consumer Protecon; Director, Bureau of Economics; Director, Oce of
Workplace Inclusivity and Opportunity
The FTC is commied to protecng the public, including meaningfully addressing barriers that historically
underserved communies face in parcipang in and beneng from a fair and thriving marketplace. Research
shows that certain pracces may harm some consumers more than others, and companies employing emerg-
ing technologies may engage in decepve or unfair pracces that are especially harmful to historically under-
served communies.
The FTC’s Every Community Iniave uses research and collaboraon to ensure that the FTC is responsive
to the needs of historically underserved communies. Historically underserved communies include Black
Americans, Lanos, Indigenous/Nave American peoples, Asian American/Pacic Islanders or other persons
of color, members of religious minories, lesbian, gay, bisexual, transgender, and/or queer persons, persons
with disabilies, persons who live in rural areas, persons adversely aected by persistent poverty or inequality,
and persons who primarily speak languages other than English. The Every Community Iniave also works to
address consumer protecon issues facing older adults as well as servicemembers, veterans, and their families,
including during the transion to civilian life.
Strategies
• Evaluate and bring acon against conduct that harms historically underserved communies: Evaluate
the impact of decepve or unfair pracces on historically underserved communies, including in the use
of emerging technologies, such as algorithmic bias or scams using AI-powered technology. Ensure that
enforcement addresses decepve or unfair pracces conducted in languages other than English, including
Nave American languages. Bring enforcement acons to stop idened conduct.
• Engage with, and reach out to historically underserved communies: Provide historically underserved
communies with praccal, language-appropriate, and user-friendly educaonal resources and informa-
on to demonstrate how the FTC is protecng them and to idenfy and report market power abuses and
consumer protecon violaons in the marketplace. Reach new audiences, including those who have not
tradionally received informaon directly from the FTC, through established outreach strategies that
include in-language resources, new technologies, and private and public partnerships.
External Factors and Risks
• Resource Constraints
• Budget limitaons aect the FTC’s ability to increase sta, including bilingual sta, enforcement ac-
ons, and outreach as well as the ability to increase contract support for translaon services.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Evaluate whether enforcement acvies are addressing pracces that target or disproporonately impact
historically underserved communies, and whether these areas require addional law enforcement focus.
This includes connuing to develop strategies to ensure that enforcement acons address decepve or
unfair pracces conducted in languages other than English. As it develops, use this new ability to take
reports in-language as an input.
• Review the focus and performance of FTC educaon eorts to reach historically underserved communies
in culturally and language-appropriate ways, using new in-language reports to the Call Center as an input;
determine whether the agency needs to reach new audiences on new topics in mulple languages, in light
of changes in demographics, emerging digital issues and decepve markeng pracces, and emerging
technologies; idenfy strategies or partnerships that will allow the FTC to reach those audiences; engage
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
68
in user tesng and human-centered tesng, as appropriate, and apply learnings from analycs to improve
educaon eorts and products.
• Connue to rene data collecon and analysis for new metrics.
• Implement the agency’s Equity Acon Plan, which includes developing a toolkit to aid sta in evaluang
the impact of decepve or unfair pracces in the use of emerging technologies (e.g., algorithmic bias and
the gig economy) on underserved communies.
Performance Metrics
Metric 1.4.1: Percentage of acons taken to stop unfair or decepve pracces that we have idened as 1)
targeng historically underserved communies; 2) disproporonately impacng historically underserved com-
munies; 3) involving schemes or pracces that research has shown to disproporonately impact historically
underserved communies; or 4) involving conduct in languages other than English, including Nave American
languages.
The FTC’s core mission is to protect all consumers from unfair or decepve pracces in the marketplace. Fraud,
as well as certain other business pracces, have a disproporonately negave impact on communies of color,
as well as other historically underserved communies. This metric seeks to gauge the impact of FTC law en-
forcement acons on historically underserved communies.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 23.4% 20.4% 20.0% Met 20.0% 20.0%
FY 2023 Highlights: In FY 2023, 20.4 percent of BCP’s enforcement acons involved conduct that had an impact
on historically underserved communies. For example, some of these cases involved allegedly discriminatory
car nancing terms, false endorsement claims, decepve nancing providers, decepve claims about student
loan debt relief, bogus money-making opportunies, and dark paerns.
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Metric 1.4.2: Percentage of redress payments made to people who live in communies that have a high pro-
poron of members of historically underserved communies.
The FTC works to halt illegal conduct harming historically underserved communies. FTC acons may result in
redress payments to those harmed by the defendants’ acons. This metric seeks to gauge the impact of those
FTC law enforcement acons that result in redress payments by measuring the degree to which people in
historically underserved communies receive payments.
(a) % based on total # of redress cases
(b) % based on aggregate dollars distributed
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A (a) 35.1%
(a) 26.0%
(b) 34.7%
30.0% met
by either (a)
or (b)
Met
30.0% met
by either (a)
or (b)
30.0% met
by either (a)
or (b)
Note: The agency connues to rene our newer metrics, including those included here in Objecve 1.4. New
this year, we have included two ways to calculate the percentage of redress payments for this metric.
FY 2023 Highlights: In FY 2023, 34.7 percent of redress payments, based on aggregate dollars distributed, were
made to people who are likely to be members of historically underserved communies. Within the 34.7 per-
cent, 15.6 percent of the dollars distributed went to people who are likely to be Black Americans, 14.7 percent
to people who are likely to be Lano Americans, 4.0 percent to people who are likely to be Asian Americans/
Pacic Islanders, and 0.5 percent to people who are likely to be Indigenous/Nave American persons.
In FY 2023, 26.0 percent of redress payments, based on the total number of redress cases, were made to
people who are likely to be members of historically underserved communies. Within the 26.0 percent, 11.4
percent of the payments went to people who are likely to be Black Americans, 10.9 percent to people who are
likely to be Lano Americans, 3.1 percent to people who are likely to be Asian Americans/Pacic Islanders, and
0.5 percent to people who are likely to be Indigenous/Nave American persons.
FTC redress programs that had a notable impact on historically underserved communies include Career
Educaon Corporaon, Ameritech, Arete Financial, Passport Auto, Napleton Auto, Herbalife, and University of
Phoenix. In FY 2023, these redress programs resulted in nearly $18 million in refunds to consumers who are
likely to be members of historically underserved communies.
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Metric 1.4.3: Number of outreach events targeng diverse audiences.
The FTC conducts outreach and events to reach out to historically underserved communies to deliver mely
and aconable consumer protecon advice, including in languages other than English, hear about the con-
sumer issues they experience, and help sta develop specic educaon messages and resources.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 179 308 165 Exceeded 165 165
FY 2023 Highlights: In FY 2023, the FTC parcipated in more than 300 events that reached advocates, con-
sumers, and intermediaries who are trusted sources in the diverse communies they serve. For example, the
FTC distributed hundreds of printed copies of educaonal material at in-person events that reached African
American small business owners, librarians from small and rural communies, immigrants, Nave American
tribal leaders, and other diverse and hard to reach communies. The FTC also shared informaon at a wide
range of virtual outreach events, including those aended by community-based organizaons serving Lano
communies across the country, low income and rural communies, Senior Medicare Patrol volunteers, and
ethnic media reporters, among others. In addion, the FTC worked extensively with ethnic media outlets to
spread the word about the scams aecng those communies: placing print and radio ads in mulple lan-
guages; holding roundtables and briengs; doing dozens of interviews for outlets; and conducng radio media
tours for a wide range of staons.
Secondary Metric 1.4.4: Number of new organizaons that partner with the FTC through the Community
Advocate Center iniave.
The FTC’s Community Advocate Center iniave is aimed at partnering with community legal aid organizaons
to expand its outreach to lower-income communies to encourage them to report fraud and provide them
with advice to help recover. The Community Advocate Center iniave provides a way for organizaons that
provide free and low-cost legal services to report fraud and other illegal business pracces their clients have
experienced directly to the FTC, on behalf of their clients. By parcipang with the FTC’s Community Advocate
Center, organizaons can connect members of their communies to specic, concrete steps they can take to
try to get their money back.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
N/A N/A N/A 10 3
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Strategic Goal 2: Protect the Public from Unfair Methods of Compeon
in the Marketplace and Promote Fair Compeon.
The FTC’s eorts to prevent and police unfair methods of compeon focus on prevenng ancompeve
mergers and business pracces through enforcement. The FTC also engages in policy research and develop-
ment, advocacy, and educaon to deter ancompeve pracces and encourage federal, state, and local
governments to evaluate the eects of their policies on fair compeon. The FTC advances these goals inter-
naonally by fostering enforcement and policy convergence and through case cooperaon with counterpart
foreign enforcement authories. This work is crical to protect and strengthen free and open markets – the
cornerstone of a vibrant economy.
Four objecves guide work in this area:
• Objecve 2.1: Idenfy, invesgate, and take acons against ancompeve mergers and business
pracces.
• Objecve 2.2: Engage in research, advocacy, and outreach to promote public awareness and understand-
ing of fair compeon and its benets.
• Objecve 2.3: Collaborate with domesc and internaonal partners to check unfair methods of
compeon.
• Objecve 2.4: Support equity for historically underserved communies through the FTC’s compeon
mission.
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Strategic Goal 2 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 2.1
Metric 2.1.1 Total consumer savings and other
measurable benets generated by antrust
enforcement.
$2.84
billion
$3.19
billion
$3.29
billion
$2.4 billion $2.4 billion $2.4 billion
Metric 2.1.2 Total consumer savings and other
measurable benets generated by antrust
enforcement compared to resources spent.
$35.50 in
consumer
savings
per $1
spent
$38.20 in
consumer
savings
per $1
spent
$35.70 in
consumer
savings
per $1
spent
$35.00 in
consumer
savings
per $1
spent
$25.00 in
consumer
savings
per $1
spent
$25.00 in
consumer
savings
per $1
spent
Metric 2.1.3 Percentage of cases and invesgaons
involving collaboraon with BCP.
N/A 5.0% 4.2% Baseline 5.0% 5.0%
Metric 2.1.4 Percentage of antrust maers seeking
signicant remedial, precedenal, or deterrent
eects across the marketplace.
N/A 58% 44% Baseline 50% 50%
Metric 2.1.5 Percentage of full-phase invesgaons
that (1) proceeded to ligaon that ulmately
halted or deterred lawbreaking or resulted in greater
claricaon of the law, or (2) ended when a merger
was abandoned in ancipaon of an FTC challenge.
N/A 38% 27% Baseline 30% 30%
Objecve 2.2
Metric 2.2.1 Number of reports and studies issued
on compeon related topics.
8 6 8 7 6 6
Metric 2.2.2 Number of cases for which BE
economists prepared to tesfy as expert witnesses
in FTC antrust enforcement acons.
N/A 5 5 Baseline 3 3
Metric 2.2.3 Percentage of compeon advocacy
maers led with enes including federal and state
legislatures, agencies, or courts that were successful.
N/A N/A TBD Baseline TBD TBD
Objecve 2.3
Metric 2.3.1 Percentage of FTC cases involving at
least one substanve contact with a foreign antrust
authority in which the agencies followed consistent
analycal approaches and reached compable
outcomes.
100% 100% 100% 85% 85% 85%
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Strategic Goal 2 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 2.4
Metric 2.4.1 Dollar value of harm from potenally
ancompeve conduct and transacons having an
adverse economic impact on consumers, workers,
and small businesses in historically underserved
communies.
N/A
< Poverty
Line: $343.1m
Hispanic:
$476.4m
Other
Underserved
Communies:
$358.1m
< Poverty Line:
$89.0m
Hispanic:
$123.2m
Other
Underserved
Communies:
$93.5m
Baseline N/A N/A
Metric 2.4.2 Percentage of populaons impacted by
acons taken to maintain compeon who belong
to historically underserved communies.
N/A
< Poverty Line:
11.8%
Hispanic:
15.7%
Other
Underserved
Communies:
11.8%
< Poverty Line:
14.3%
Hispanic:
25.0%
Other
Underserved
Communies:
12.9%
Baseline N/A N/A
Metric 2.4.3 Percentage of acons taken to
maintain compeon where the merger or conduct
was idened as adversely impacng historically
underserved communies.
N/A 25% 21% Baseline N/A N/A
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74
Objecve 2.1: Idenfy, invesgate, and take acons against ancompeve mergers and business pracces.
Goal Leaders: Director, Bureau of Compeon; Director, Bureau of Economics; Chief Technology Ocer,
Oce of Technology
Ancompeve mergers and business pracces harm Americans through higher prices, lower wages, or re-
duced quality, choice, and innovaon. Enforcement of antrust laws provides substanal benets to the public
by helping to ensure that markets are open and compeve.
The FTC’s Bureaus of Compeon, with support from the Bureau of Economics and the Oce of Technology,
invesgate proposed and consummated mergers, as well as business conduct that may be ancompeve. The
FTC takes enforcement acon when it has reason to believe that mergers or conduct are unlawful, using its
enforcement tools (including federal court and administrave ligaon and consent orders) to prevent or rem-
edy harm. In each case, the FTC strives to eciently address the compeve concerns raised by a merger or
business pracce and works toward a soluon that maintains compeon in the marketplace without unduly
burdening legimate business acvity.
The Hart-Sco-Rodino (HSR) Premerger Nocaon Act is the FTC’s primary tool in idenfying ancompeve
mergers. The FTC administers the HSR program for itself and the Antrust Division of the Department of Jusce
(DOJ), which shares authority to challenge ancompeve mergers. Premerger nocaon gives the agencies
the opportunity to block, or remedy proposed mergers before they are consummated. Both for mergers not
subject to HSR nocaon requirements and for ancompeve conduct maers, the FTC relies on other tools
such as referrals, the trade press, consumer and competor complaints, and other means to idenfy potenal
or ongoing harm to compeon.
Strategies
• Invesgate: Invesgate potenally ancompeve mergers and business conduct eciently using rigor-
ous, economically sound, and fact-based analyses that enhance enforcement outcomes for the benet of
consumers, workers, and honest businesses. Leverage revised HSR form and Merger Guidelines to imple-
ment Congressional requirements and to more eecvely and eciently screen transacons subject to
premerger nocaon.
• Enforce the antrust laws: Enforce the law to protect all segments of the populaon from ancompeve
mergers and business pracces, including by enforcing federal court and administrave orders obtained by
the FTC.
• Improve compliance: Improve oversight to ensure compliance with Commission orders and with HSR
reporng obligaons. Increase the use of structural remedies in consent orders and seek increased use in
ligated maers. Likewise, decrease the use of behavioral remedies in consent orders and seek them less
oen in ligated maers. Encourage pares to propose standalone, operang businesses as selements.
Increase use of provisions to improve worker mobility including restricng the use of non-compete provi-
sions. Seek higher penales for order violaons and HSR violaons. Increase use of prior approval provi-
sions to prevent illegal transacons in the same markets as those already under order. Provide transpar-
ency in the decision-making process through comment periods, press releases, blog posts, updated policy
guidance, and analyses to aid public comment.
• Improve ligaon skills: Improve negoaon and ligaon skills and rene invesgave and decisional
tools through connuous learning. Negoate merger and nonmerger consent orders and pursue ligated
orders that have signicant remedial, precedenal, and deterrent eects.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
75
External Factors and Risks
• Resource constraints
• Invesgaons and ligaon are increasingly complex because of the need to process, store, and review
large amounts of electronic discovery materials and the need to hire economic and other experts. This
complexity, coupled with uctuaons in merger acvity and complaints of potenally harmful business
conduct, can put pressure on the FTC’s stang and nancial resources.
• HSR Statutory Deadlines
• The HSR Act typically provides the agencies with a 30-day window to determine whether a deal war-
rants close invesgaon and then typically a 30-day meline to make a decision whether or not to chal-
lenge a merger aer pares cerfy they have “substanally complied” with the invesgatory requests.
Given increased volume and complexity of transacons and our limited stang resources, this imposes
further strain on the agency’s ability to scrunize potenally ancompeve transacons.
• State and federal legislave and judicial landscape
• The ever-evolving landscape, with respect to both federal and state antrust enforcement authority,
may directly impact the Commission’s ability to challenge ancompeve mergers and business con-
duct. The dynamic environment also pushes sta to idenfy dierent approaches to enforcement to
preserve compeon for the benet of the American public.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Work to secure the resources necessary to eecvely enforce the antrust laws to ensure that the public
benets from the lower prices, higher quality, increased innovaon, and expanded choices that compe-
on brings.
• Expand employee development programs to increase the antrust experse and invesgave, negoaon,
and ligaon skills of legal sta through connuous learning and retrospecve analysis.
• Ulize BC’s Training Council to idenfy legal sta development opportunies and provide targeted training
programs to meet those needs. Focus on enhancing the invesgave process using improved technological
tools and the idencaon of “best pracces” to streamline and standardize management of invesga-
ons and ligaon.
• Connue to pursue updates to premerger nocaon ling requirements and screening methods to
maximize eciency and eecveness.
• Employ novel enforcement techniques in response to a challenging judicial environment, including work-
ing with state enforcement partners to remediate harm to compeon.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
76
Performance Metrics
Metric 2.1.1: Total consumer savings and other measurable benets generated by antrust enforcement.
This metric reports the esmated amount of money that the Commission saved consumers by acng against
potenally ancompeve mergers and business conduct. The number reported is a ve-year “rolling average”
(average of the current year and four prior year totals).
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
$4.87 billion $2.68 billion $2.84 billion $3.19 billion $3.29 billion $2.4 billion Exceeded $2.4 billion $2.4 billion
Note: The result for FY21 has changed from $2.77 billion, reported previously, to $2.84 billion. The result for
FY22 has changed from $3.12 billion, reported previously, to $3.19 billion. The result for FY23 has changed
from $3.14 billion, reported in the FY23 Agency Financial Report, to $3.29 billion. In each instance, cases from
those years were discovered that were missing from the results.
FY 2023 Highlights: The FTC concluded 19 full-phase invesgaons with acons in FY 2023, including 13 merg-
er maers and six conduct maers. Three of the concluded maers involved successful federal court ligaon
or administrave adjudicaon, while seven were concluded with a selement, and nine were resolved when
the pares abandoned their transacons in ancipaon of an FTC challenge.
Metric 2.1.2: Total consumer savings and other measurable benets generated by antrust enforcement
compared to resources spent.
This metric tracks the return on investment of the FTC’s antrust enforcement spending. We compare the
esmated consumer savings and other measurable benets that the Commission saved consumers by acng
against potenally ancompeve mergers and business conduct to the amount spent on the merger and
nonmerger programs. The amount reported is a ve-year “rolling average” (average of the current year and
four prior year totals).
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
$66.00 in
consumer
savings per
$1 spent
$34.40 in
consumer
savings per
$1 spent
$35.50 in
consumer
savings per
$1 spent
$38.20 in
consumer
savings per
$1 spent
$35.70 in
consumer
savings per
$1 spent
$35.00 in
consumer
savings per
$1 spent
Exceeded
$25.00 in
consumer
savings per
$1 spent
$25.00 in
consumer
savings per
$1 spent
Note: The result for FY21 has changed from $34.70 per $1 spent, reported previously, to $35.50 per $1 spent.
The result for FY22 has changed from $37.30 per $1 spent, reported previously, to $38.20 per $1 spent. The
result for FY23 has changed from $34.10 per $1 spent, reported in the FY23 Agency Financial Report, to $35.70
per $1 spent. In each instance, cases from those years were discovered that were missing from the results.
FY 2023 Highlights: Despite increasing costs driven by the expanding scope and complexity of antrust inves-
gaons and the Commission’s substanal compeon ligaon docket, the agency exceeded its target for
this performance metric, saving the public nearly an esmated $36 for every dollar spent on its enforcement
programs.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
77
Metric 2.1.3: Percentage of cases and invesgaons involving collaboraon with BCP.
This metric reports the percentage of full-phase invesgaons concluded in which the Bureau of Compeon
collaborated in some aspect(s) of the invesgaon, with FTC colleagues in the Bureau of Consumer Protecon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 5.0% 4.2% Baseline N/A 5.0% 5.0%
FY 2023 Highlights: The Commission is increasingly streamlining the invesgave process and idenfying
synergies between the agency’s dual missions to protect consumers and compeon. The Commission accord-
ingly has priorized informaon sharing and cross-funconal invesgaons, wherever possible, which makes
more ecient use of the Commission’s limited resources and has the potenal to reduce redundancy in inves-
gave processes. In the rst two years that the agency has tracked this endeavor, the Bureau of Compeon
and Bureau of Consumer Protecon collaborated substanvely in between 4 percent and 5 percent of the
full-phase maers concluded during each scal year. The Commission will connue to track this important
informaon-sharing iniave and will strive to pursue collaboraon wherever appropriate.
Metric 2.1.4: Percentage of antrust maers seeking signicant remedial, precedenal, or deterrent eects
across the marketplace.
This metric reports the percentage of concluded full-phase invesgaons that sought signicant remedial ac-
on, or which were ancipated to have substanal precedenal value or eectuate broad deterrence of future
ancompeve mergers or conduct.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 58% 44% Baseline N/A 50% 50%
FY 2023 Highlights: Increasingly, the Commission is adapng its invesgave and ligaon strategies to clarify
antrust law and ensure our approach is reecve of modern market realies. Accordingly, the agency is
priorizing maers that seek signicant remedies, or that idenfy precedenal theories of harm or further
signicant deterrence of future ancompeve behavior in the marketplace. In FY 2023, the Commission con-
cluded 48 full-phase antrust maers. Of those concluded maers, 21 sought or achieved signicant remedial,
precedenal, or deterrent eects, including ligaon challenges pleading unique theories of harm and taking
broad acon against harmful non-compete clauses in mulple industries.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
78
Metric 2.1.5: Percentage of full-phase antrust invesgaons that (1) proceeded to ligaon that ulmately
halted or deterred lawbreaking or resulted in greater claricaon of the law or (2) ended when a merger was
abandoned in ancipaon of an FTC challenge.
This metric reports the percentage of concluded full-phase invesgaons that either, 1) proceeded to liga-
on which ulmately halted or deterred lawbreaking or for which the holding claried the law in a way
deemed benecial to future compeon enforcement, or 2) which ended when a merger was abandoned or
restructured by the pares in ancipaon of the Commission authorizing either federal court or administrave
adjudicaon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 38% 27% Baseline N/A 30% 30%
FY 2023 Highlights: Federal court and administrave ligaon are the two most powerful enforcement tools
at the Commission’s disposal and are also the most resource-intensive. This metric assesses the outcomes of
maers in federal court ligaon or administrave adjudicaon, or where pares abandon or restructure their
transacons due to an impending challenge. Of the 48 full-phase maers concluded in FY 2023, six maers
progressed to ligaon, including three ligated victories, and one unsuccessful challenge that nonetheless
claried key elements of antrust jurisprudence, paving the way for future ligaon eorts. In nine addional
maers, the pares abandoned or restructured their proposed transacons in ancipaon of a Commission
challenge.
Secondary Metric 2.1.6: Total sales in the aected markets in which the Commission took antrust enforce-
ment acons.
This metric demonstrates that the Commission’s merger acons are guided in part by the size of the relevant
product/geographic markets involved. It is important that the FTC use its resources in areas where it can
achieve the most posive change. The number reported is a ve-year “rolling average” (average of the current
year and four prior year totals).
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
$193.2 billion $81.3 billion $79.2 billion $54.1 billion $54.6 billion
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
79
Objecve 2.2: Engage in research, advocacy, and outreach to promote public awareness of fair compeon
and its benets.
Goal Leaders: Director, Bureau of Compeon; Director, Bureau of Economics; Chief Technology Ocer,
Oce of Technology; Director, Oce of Policy Planning; General Counsel, Oce of the General Counsel
Through research, advocacy, and rulemaking, the FTC seeks both to understand the marketplace as it evolves
over me and to provide guidance to the business community, policymakers, and the public. Whether through
analyzing industry data, holding public hearings and workshops, or conducng economic studies, the FTC
gathers informaon for its sta of economists, technologists, and other researchers to analyze. Our research
work directly informs our law enforcement work and is oen released to the public through sta reports and
studies.
As the economy connues to evolve the FTC must ensure we are fully grasping market realies, especially as
the economy becomes increasingly digized. The agency plans to be especially aenve to next-generaon
technologies, innovaons, and nascent industries across sectors. By staying apprised of new developments,
the agency can learn from new evidence and course correct as needed. An interdisciplinary team of research-
ers and analysts will best posion the FTC to migate informaon asymmetries and narrow the gap between
theory and pracce.
The FTC also promotes compeon through advocacy and educaon. In its advocacy work, the FTC les com-
ments with federal, state, and local government bodies and encourages them to consider the eect their
proposed acons will have on compeon. In another form of advocacy, the FTC les amicus briefs with
federal courts to develop antrust law in the public interest. The FTC also endeavors to educate consumers and
businesses about compeon law and policy. Rules and guidance inform businesses and their legal advisers
about antrust risks and can deter ancompeve mergers and business pracces and reduce businesses’ cost
of compliance. Open Commission meengs allow the public to gain insight into the work and priories of the
agency.
Strategies
• Research new developments in the marketplace: Improve the agency’s understanding of various pracces
and developments in the marketplace by conducng economic research on these issues and holding public
hearings, conferences, and workshops that bring together interested pares that represent the diversity of
the American public. Use the informaon gathered to inform the agency’s enforcement agenda. Improve
the disseminaon of material gathered through hearings, conferences, and workshops.
• Research eecveness of remedies: Conduct market research, including evaluang the eecveness of
merger and conduct remedies, to inform future enforcement eorts.
• Educate small businesses: Provide small businesses with praccal, user-friendly educaonal resources to
help them understand the law so they can comply with it and idenfy when they are vicms of unlawful
conduct.
• Focus on workers: Study and invesgate the impact on worker wages and benets from merger and
nonmerger conduct, as well as non-compete and other potenally unfair contractual terms resulng from
power asymmetries between workers and employers.
• Work with the media: Engage the media to disseminate clear and compelling content to the public with
the goal of ensuring consumers understand what companies did wrong and what the FTC is doing to stop
them, and to publicize clear rules to give guidance to businesses in the marketplace. Ensure that regional
and local outlets and reporters are aware of developments that impact their audiences and communies.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
80
External Factors and Risks
• Resource constraints
• Financial and personnel resource limitaons, driven primarily by the volume and complexity of liga-
on, may reduce resources available to provide reports, studies, workshops, and conferences.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• To expand our sta’s skillsets, the FTC will invest in more training and educaonal resources for exisng
and incoming talent.
• The FTC will invest more me to develop its relaonships with small businesses as well as state and federal
government policymakers. This will inform the FTC about changing issues that are relevant to small busi-
nesses and will provide a resource to state and federal government policymakers.
Performance Metrics
Metric 2.2.1: Number of reports and studies the FTC issued on compeon related topics.
This metric reports compeon policy-related acvies such as Commission or sta research, reports, eco-
nomic or policy papers, studies, or other signicant antrust guidance produced aer substanve invesga-
on, study, or analysis. These acvies enhance the public’s knowledge of compeon issues and promote the
adopon of policies based on sound compeve principles to the extent possible. Also included as part of this
metric are reports to other federal agencies that report on the FTC’s acvies.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
4 7 8 6 8 7 Exceeded 6 6
FY 2023 Highlights: The Commission issued eight reports, studies, or policy statements in FY 2023, including
two annual reports, a report on the compeve marketplace for biosimilars, and three policy statements,
including the dra FTC-DOJ Merger Guidelines.
Metric 2.2.2: Number of cases for which BE economists prepared to tesfy as expert witnesses in FTC antrust
enforcement acons.
The performance metric is the number of cases for which BE economists (including economists, nancial ana-
lysts, research analysts, stascians, and other BE sta) prepared to tesfy as expert witnesses in FTC antrust
enforcement acons. This number is a measure of BE experse developed through economic research related
to compeon analysis and represents not only the experse of the tesfying expert, but also the experse of
the BE economists and other sta who are supporng that expert.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 5 5 Baseline N/A 3 3
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
81
Metric 2.2.3: Percentage of compeon advocacy maers led with enes, including federal and state
legislatures, agencies, or courts that were successful.
The FTC’s compeon advocacy takes many forms—including advocacy comments, amicus briefs, workshops,
reports, and tesmony. This metric evaluates the success rate for resolved compeon advocacy comments
and amicus briefs. Although the FTC is primarily a law enforcement agency, advocacy work is a cost-eecve
way to further the FTC’s compeon mission and allows the FTC to address situaons where compeon may
be aected by the acons of public enes, including regulators and legislators.
To determine whether an advocacy comment or amicus brief is successful, sta waits for the relevant case,
legislave process, or agency rulemaking to be fully resolved. Once resolved, the outcome is compared to
the policy recommendaons within the advocacy comment, or the legal arguments set forth in the amicus
brief. Advocacies are classied as successful, parally successful, moot, or unsuccessful based on the outcome
achieved. We do not aempt to quanfy or measure how much eect our advocacy had on the decision.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A N/A N/A Baseline N/A TBD TBD
FY 2023 Highlights: Data for this metric is oen delayed and was not yet available for FY 2023 at me of publi-
caon. The agency is working on improving the process to collect this data.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
82
Objecve 2.3 Collaborate with domesc and internaonal partners to check unfair methods of compeon.
Goal Leaders: Director, Oce of Internaonal Aairs; Director, Bureau of Compeon; Director, Bureau of
Economics
The FTC connues to build cooperave relaonships with domesc and foreign antrust agencies to ensure
close cooperaon on cases, in a pracce long welcomed by the business community, and foster the exchange
of learning and understanding of policy issues of common concern. On the domesc front, the FTC seeks to
collaborate with other agencies and the state aorneys general to obtain the best results and maximize the
use of limited resources in the enforcement of the U.S. antrust laws.
Lawful cooperaon with foreign compeon agencies of other jurisdicons is one element of an eecve FTC
compeon enforcement program. With over 130 antrust enforcers worldwide, it is crical that agencies
work together to ensure that the internaonal compeon law system funcons coherently and eecvely. To
accomplish this, the FTC builds strong bilateral relaons with foreign counterparts, including new and emerging
agencies through our technical assistance program, and takes a lead role in mullateral fora to promote case
enforcement cooperaon, greater policy understanding, and best pracces. The FTC also works with relevant
U.S. government agencies to develop, promote, and maintain compeve domesc markets and to address
compeon issues that implicate broader U.S. policy interests in a coordinated and eecve manner.
Strategies
• Collaborate domescally: Work more extensively within the U.S. government inter-agency process and
with other domesc government enes to support the FTC’s eorts to promote market-based compe-
on and policy convergence.
• Cooperate internaonally: Work with internaonal government and non-government partners to pro-
mote internaonal cooperaon and policy consistency aimed at sound and eecve antrust enforce-
ment. Lawful cooperaon with foreign compeon agencies on antrust maers that are subject to
concurrent review improves the eecveness of invesgaons and promotes eciency that benets both
agencies and businesses. The FTC’s promoon of policy understanding encourages the development of
internaonal best pracce standards and their applicaon to transacons and conduct aecng the global
marketplace.
External Factors and Risks
Case compability and policy consistency involve numerous stakeholders, polical consideraons, compeng
compeon laws, and economic factors
• Promong consistency is a long-term endeavor that can be aected by events beyond the agency’s con-
trol, such as foreign court proceedings and polical or legislave changes aecng a foreign counterpart
agency’s policies or priories. Internaonal technical assistance would be hampered if external resources
are not available, U.S. embassies abroad are not supporve, or if foreign governments are unwilling to
accept U.S. assistance.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Support BC’s enforcement by assisng with the internaonal aspects of its invesgaons and ligaon.
• Pursue opportunies for improving internaonal cooperaon tools bilaterally and mullaterally, e.g.,
through the ICN, the Organisaon for Economic Co-operaon and Development (OECD), and UNCTAD,
including the development of addional agreements to promote enhanced cooperaon, e.g., pursuant to
the Mullateral Mutual Assistance and Cooperaon Framework.
• Enhance opportunies for the promoon of policy understanding and consistency, including the applica-
on of compeon law to the digital economy.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
83
• Connue the FTC’s leadership role in the ICN by: guiding the ICN’s strategic direcon through Steering
Group parcipaon; leading the network’s promoon and implementaon work; co-leading the project
on the intersecon of compeon, data privacy, and consumer protecon law and policy; helping advance
work on unilateral conduct, agency eecveness, digital markets, cooperaon, mergers, and compeon
advocacy; serving as ICN Vice Chair for digital market issues; and creang and leading ICN’s forum for
agency technologists and digital work. Strengthen relaons with key partner compeon agencies through
dialogue on policy iniaves, case cooperaon, and the provision of technical assistance.
• Facilitate dialogue and compeon policy and enforcement understanding and consistency through
engagement in addional mullateral fora including the OECD Compeon Commiee, UNCTAD, and
regional organizaons such as the Asia-Pacic Economic Cooperaon regional economic forum.
• Connue the Internaonal Fellows and sta exchange programs and pursue technical assistance programs,
notably regional programs in coordinaon with the U.S. Agency for Internaonal Development and other
interagency funding partners.
• Work with other U.S. agencies bilaterally and in interagency and intergovernmental fora such as the G7
and the EU-US Technology and Trade Council, and in the development of trade arrangements to address
appropriate compeon-related issues.
Performance Metrics
Metric 2.3.1: Percentage of FTC cases involving at least one substanve contact with a foreign antrust author-
ity in which the agencies followed consistent analycal approaches and reached compable outcomes.
OIA strives to ensure appropriate cooperaon on and coordinaon of invesgaons under parallel review
by the FTC and foreign compeon agencies. This metric gauges the eecveness of the FTC’s enforcement
cooperaon with foreign antrust authories pursuing parallel enforcement acvies.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
100% 100% 100% 100% 100% 85% Exceeded 85% 85%
FY 2023 Highlights: In FY 2023, the FTC cooperated on 27 enforcement maers. FTC sta engaged in substan-
ve case cooperaon with 19 agencies, including those of Australia, Brazil, Canada, the European Union,
Israel, Japan, Singapore, and the United Kingdom. The FTC and its counterpart agencies reached compable
outcomes in all cases completed during the scal year. While the FTC will connue to strive for 100 percent
success, the target reects the possibility of inconsistent outcomes as each reviewing agency independently
assesses the transacon or conduct in accordance with the laws and compeve realies in its jurisdicon.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
84
Secondary Metric 2.3.2: Percentage of full invesgaons in which the FTC and other U.S. federal, state, and
local government agencies shared evidence or informaon that contributed to FTC law enforcement.
Due to the wide geographic impact of merger and nonmerger acons, it is important that the FTC share infor-
maon and resources with other domesc federal, state, and local government agencies in the invesgaon
and enforcement of compeon cases. This metric reports the number of full merger and nonmerger inves-
gaons concluded in a given scal year that involved informaon sharing with domesc federal, state, or local
government agencies.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
31.8% 22.2% 52.0% 60.0% 47.0%
FY 2023 Highlights: In FY 2023, the Commission engaged in informaon sharing and collaboraon in 9 of the
nineteen substanal invesgaons concluded with acon, demonstrang a connued commitment to working
with state and other enforcement partners in furtherance of the compeon mission.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
85
Objecve 2.4: Support equity for historically underserved communies through the FTC’s compeon
mission.
Goal Leaders: Director, Bureau of Compeon; Director, Bureau of Economics; Director, Oce of Workplace
Inclusivity and Opportunity
The FTC strives to ensure that all members of the public benet from compeon in the marketplace, includ-
ing members of historically underserved communies. These communies, oen low-income, rural, veterans,
and/or communies of color, may be more suscepble to the harms caused by ancompeve conduct and
mergers. Some conduct may even seek to deliberately exploit or prey upon unique challenges these communi-
es experience.
The FTC enforces the antrust laws aer analyzing the harms and potenal remedies based on the informaon
available. Connuing eorts to improve the agency’s informaon requests and case evaluaon process will
ensure that harms to less visible groups are not going unnoced and will enable the Commission to ensure it is
focusing its resources on cases that promote a fair and equitable marketplace for all.
Strategies
• Improve informaon gathering that precedes the case selecon and evaluaon process: Develop and
rene informaon requests in merger and ancompeve conducts cases to solicit informaon about the
impact of transacons and conduct on historically underserved communies. This may include idenfying
communies within specic geographic areas that are aected and ensuring that merger analysis includes
eects on workers and restricve covenants.
• Further research: Conduct research to study the economic impact of ancompeve conduct and transac-
ons on consumers, workers, and small businesses in historically underserved communies.
External Factors and Risks
• Resource constraints
• Financial and personnel resource limitaons, driven primarily by the volume and complexity of liga-
on, may limit the number of invesgaons and ligaons the agency can pursue, which may in turn
impact the FTC’s ability to achieve the goals of this objecve.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Connue to rene data collecon and analysis for new metrics.
• BC will update its case selecon and evaluaon process by systemacally collecng available informa-
on regarding the impact of proposed mergers and alleged ancompeve conduct on underserved
communies.
• BC will ensure that merger analysis includes eects on workers and restricve covenants.
• BC sta will connue ongoing eorts to develop—and rene—informaon requests (via voluntary access
leers, second requests, and civil invesgave demands) in merger and ancompeve conduct cases to
solicit informaon about the impact of transacons on underserved communies.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
86
Performance Metrics
Metric 2.4.1: Dollar value of harm from potenally ancompeve conduct and transacons having an ad-
verse economic impact on consumers, workers, and small businesses in historically underserved communies.
This metric reports the percentage of consumer savings and other measurable benets applicable to individu-
als who 1) are under the federal poverty line, or who 2) idenfy as Black, Hispanic, American Indian/Alaska
Nave, or Nave Hawaiian/Other Pacic Islander in the relevant geographic markets of concluded, full-phase
invesgaons.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A
< Poverty
Line: $343.1m
Hispanic:
$476.4m
Other
Underserved
Communies:
$358.1m
< Poverty
Line: $89.0m
Hispanic:
$123.2m
Other
Underserved
Communies:
$93.5m
N/A N/A N/A N/A
Note: As explained in the FTC Strategic Plan, the agency is not currently seng targets for the metrics in
Objecve 2.4.
FY 2023 Highlights: The Commission’s enforcement acons to stop ancompeve conduct and mergers
saved historically underserved communies millions of dollars. Consistent with Metric 2.1.2, the Commission’s
compeon enforcement acons saved the public, and more specically, underserved racial/ethnic and socio-
economic groups, many mes the costs of the agency’s compeon enforcement programs.
Metric 2.4.2: Percentage of populaons impacted by acons taken to maintain compeon who belong to
historically underserved communies.
This metric reports the percentage of populaons who 1) are under the federal poverty line, or who 2) idenfy
as Black, Hispanic, American Indian/Alaska Nave, or Nave Hawaiian/Other Pacic Islander in the relevant
geographic markets of concluded, full-phase invesgaons.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A
< Poverty
Line: 11.8%
Hispanic:
15.7%
Other
Underserved
Communies:
11.8%
< Poverty
Line: 14.3%
Hispanic:
25.0%
Other
Underserved
Communies:
12.9%
N/A N/A N/A N/A
Note: As explained in the FTC Strategic Plan, the agency is not currently seng targets for the metrics in
Objecve 2.4.
FY 2023 Highlights: The Commission took enforcement acons to stop ancompeve conduct and mergers in
markets that largely aligned with naonal populaon averages for certain historically underserved communi-
es. As the Commission connues to rene its focus on disparate impact in underserved communies, these
percentages may increase in years to come.
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Metric 2.4.3: Percentage of acons taken to maintain compeon where the merger or conduct was idened
as adversely impacng historically underserved communies.
This metric reports the percentage of full-phase invesgaons concluded with an acon for which sta iden-
ed a potenally adverse impact on one or more historically underserved communies during the course of its
invesgaon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 25% 21% N/A N/A N/A N/A
Note: As explained in the FTC Strategic Plan, the agency is not currently seng targets for the metrics in
Objecve 2.4.
FY 2023 Highlights: This metric recognizes that harm to underserved communies, while challenging to quan-
fy, is cognizable and signicant. In FY 2023, sta idened a likely adverse impact on one or more historically
underserved communies in four of the 19 full-phase invesgaons concluded with an enforcement acon. As
the Commission connues to rene its focus on disparate impact in underserved communies, this percentage
may increase in years to come.
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Strategic Goal 3: Advance the FTC’s Eecveness and Performance
The FTC believes that advancing organizaonal eecveness and performance at all levels creates a strong
foundaon for overall mission success. The agency’s work in Strategic Goal 3 highlights ongoing eorts to im-
prove the management of agency stang, nances, informaon, and physical assets to create a more ecient
and more agile agency.
Three objecves guide work in this area:
• Objecve 3.1: Opmize resource management, space, and administrave programs.
• Objecve 3.2: Culvate a high performing, diverse, inclusive, and engaged workforce.
• Objecve 3.3: Opmize informaon management.
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89
Strategic Goal 3 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 3.1
Metric 3.1.1 Audit opinion from the agency’s
independent nancial statement auditors.
Unmodied
opinion
Unmodied
opinion
Unmodied
opinion
Unmodied
opinion
Unmodied
opinion
Unmodied
opinion
Metric 3.1.2 Percentage of contract acons awarded
within FTC’s established procurement acon lead
me.
94.5% 90.6% 90.1% 90.0% 90.0% 90.0%
Metric 3.1.3 Percentage of contract dollars awarded
to small disadvantaged businesses.
18.1% 15.5% 15.8% 15.0% 15.0% 15.0%
Metric 3.1.4 Number of training and informaon
oerings to sta on climate literacy and resilience
topics.
N/A 4 4 4 4 4
Objecve 3.2
Metric 3.2.1 Annual score on the FEVS Employee
Engagement Index.
74% 74% 79%
Exceed
government-
wide average
(72%)
Exceed
government-
wide average
Exceed
government-
wide average
Metric 3.2.2 Annual score on the FEVS Global
Sasfacon Index.
60% 62% 68%
Exceed
government-
wide average
(64%)
Exceed
government-
wide average
Exceed
government-
wide average
Metric 3.2.3 Annual score on the FTC Diversity and
Inclusion Index.
N/A 85% 87%
Exceed
government-
wide average
(71%)
Exceed
government-
wide average
Exceed
government-
wide average
Metric 3.2.4 Percentage of people with disabilies in
the FTC workforce.
8.8% 8.6% 9.3%
Equal or
greater
than
previous
FY
Equal or
greater
than
previous
FY
Equal or
greater
than
previous
FY
Metric 3.2.5 Percentage of people with targeted
disabilies in the FTC workforce.
1.4% 1.4% 1.2%
Equal or
greater
than
previous
FY
Equal or
greater
than
previous FY
Equal or
greater
than
previous FY
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Strategic Goal 3 Metrics
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2024
Target
FY 2025
Target
Objecve 3.3
Metric 3.3.1 Percentage of FTC IT systems hosted
outside of the FTC’s data center.
N/A 90.0% 91.4% 90.0% 90.0% 90.0%
Metric 3.3.2 Availability of informaon technology
systems.
99.94% 99.67% 99.52% 99.50% 99.50% 99.50%
Metric 3.3.3 Annual score on the FTC Cybersecurity
Index.
6 of 8 7 of 8 7 of 8
Baseline
[new
Index]
7 of 8 7 of 8
Metric 3.3.4 Meet project milestones for developing
an agency email records schedule and associated
email capture and management process.
N/A
Email
records
schedule
and policy
draed
Submied
email
records
schedule
Submit email
records
schedule to
NARA for
approval
Implement
Capstone
email
records
schedule
Complete
evaluaon
of FTC email
management
pracces
Metric 3.3.5 Meet project milestones for developing
and implemenng an agency wide approach for
managing Controlled Unclassied Informaon (CUI).
N/A
Finalized
CUI
processes
Implemented
CUI marking
and launched
training
Implement
CUI marking
and launch
training
agency-wide
Conduct CUI
program
evaluaon for
DC oces
Conduct CUI
program
evaluaon
for regional
oces
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91
Objecve 3.1: Opmize resource management and infrastructure.
Goal Leader: Execuve Director, Oce of the Execuve Director
The creaon, modernizaon, and maintenance of physical and nancial resources and infrastructure not only
provides for a safe, secure, and ecient workplace but also helps the agency achieve its mission and respond
to, and ancipate, future needs. These eorts span several oces and funcons.
The safety and security of the workforce is of paramount importance, and the FTC must ensure that mission
essenal work can be completed in both normal and adverse condions. The work in this area covers emer-
gency preparedness, space and administrave operaons, and climate acon planning and migaon that will
limit the agency’s climate impact wherever possible.
The FTC believes in the importance of accountability and transparency, as shown through resource stewardship
and nancial oversight. The work in this area covers a wide range of administrave and operaonal acvies,
such as formulang and execung the agency budget, managing procurements, internal controls, accounng
operaons, audit resoluon, and ensuring compliance with nancial management laws and regulaons.
Strategies
• Enhance agency procurement: Improve the eecveness and eciency of procurement-related work,
especially as relates to expert witness contracts, which are among the most me sensive. Strive to
maintain the proper level of sta and resources to complete procurements on me. Develop the necessary
policies and procedures and adherence to those processes that ensure proper oversight and management
of contracts. Provide addional training to agency Contracng Ocers and Acquision support sta on the
agency’s contract wring system.
• Increase emergency and climate readiness: Enhance emergency and climate readiness and resilience,
including the ability to ancipate, prepare for, and adapt to changing condions and to withstand, respond
to, and recover rapidly from climate related disrupons by updang the FTC’s facility emergency plans and
reviewing its Connuity of Operaons plan annually. Update all emergency plans to reect climate impacts
in specic geographic locaons over the next four years.
• Improve availability of agency nancial data: Leverage Oracle Business Intelligence (OBI) reporng func-
ons to create and deploy tools such as interacve dashboards, alerts, and visual analycs to advance
more informed and mely management decisions, especially those related to budget execuon and the
availability of funds. Format and align nancial data with users’ needs to support sound decisions related
to accomplishing the agency’s consumer protecon and compeon missions.
• Enhance overall agency nancial management: Develop capabilies obtained through the integraon
of the FTC nancial system and OBI. Maximize the FTC’s ability to perform more targeted analycs that
assess the eecveness and eciency of its nancial management operaons. Conduct a systemac
review of all nancial processes to ensure eciency and eecveness. Collaborate with the Department
of the Treasury to implement G-invoicing, a long-term soluon to improve the quality of the agency’s
Intragovernmental Transacons.
External Factors and Risks
• Changes in government requirements for nancial management:
• Changes to federal nancial management regulaons, including acquision regulaons, can lead to un-
expected shis in priories or work processes. If contract processing consequently slows down, needed
equipment, supplies, and services, including expert witnesses for ligaon, may be delayed, slowing
down mission-crical work.
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92
FY 2023 Progress Update
• Security / Emergency Preparedness
• The FTC completed the Eagle Horizon Connuity of Operaons exercise and developed an aer-acon
report to address idened improvement areas during the training.
• The FTC updated its Headquarters Occupant Emergency Plan to address the hybrid work environment
and to implement FEMA’s best pracce of an all-hazards emergency management approach, including
likely climate-related impacts. The FTC conducted security assessments of three regional oces to
evaluate changing condions and idenfy areas requiring approvement and to recommend next steps
to ensure safety of FTC regional sta.
• The FTC installed badging staons in all regional oces to ensure proper badging of all employees
regardless of locaon.
• Facilies
• The FTC leased its rst electric vehicle and installed an electric recharging staon in its headquarters
building.
• The FTC expanded its bike room to accommodate e-bikes and bikes that need to be stored horizontally
to accommodate sta with special needs.
• Completed gathering requirements for its Micro Program of Requirements and submied them to
General Services Administraon as the next step in the process to procure new space to replace the
FTC’s satellite building in Washington D.C.
• Finance
• The FTC’s Enterprise Risk Management program connues to ensure that internal controls are achiev-
ing their intended objecves supporng eecve and ecient programmac operaons, reliable
nancial reporng, and compliance with applicable laws and regulaons. The Financial Management
Oce (FMO) idened, assessed, and monitored risks related to mission performance and updated the
agency risk prole. The risk-management eorts helped agency leadership determine where to apply
resources to address the FTC’s highest priories and risks.
• The agency made progress towards paperless procurement and automated reporng of acquision
acvies through more comprehensive use of its nancial reporng tool, Oracle Business Intelligence.
The agency’s transion to an electronic procurement le management system was delayed by the
pandemic, and the FTC is sll exploring opons in this area.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Complete the review of Occupant Emergency Plans and establish a schedule to incorporate climate im-
pacts into these plans over the coming four years.
• Deliver targeted messaging and informaonal training to increase sta awareness on climate resiliency
and adaptaon.
• Pursue a contract to develop a master plan for the Headquarters building to evaluate space use
improvements.
• Explore opons for improving security of the Headquarters entrances.
• Update egress and waynding signage in the Headquarters building.
• Enhance collecon development procedures to ensure ongoing evaluaon of electronic subscripons as
the agency explores a hybrid work environment.
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93
• Pursue cercaon to the new FAC-C-IT standard for contracng ocers required to sign future IT
contracts.
• Pursue greater use of OBI nancial dashboards, parcularly to assist acquisions in tracking Procurement
Acon Lead Time (PALT) and other contracng metrics.
• Connue to support eorts to monitor and update the agency risk prole and risk registers to highlight
and help agency leadership manage the most signicant risks and analyze areas of concern that may
elevate to a signicant risk in the future.
Performance Metrics
Metric 3.1.1: Audit opinion from the agency’s independent nancial statement auditors.
FTC management is responsible for the preparaon and fair presentaon of annual nancial statements in
accordance with U.S. generally accepted accounng principles. As required by law, the FTC’s nancial state-
ments are audited annually by independent auditors. The auditors will determine whether the annual nancial
statements and related notes present fairly, in all material respects, the assets, liabilies, and net posion in
accordance with U.S. generally accepted accounng principles. The ideal outcome is an unmodied “clean” au-
dit opinion. Potenal negave outcomes include a qualied or adverse opinion, or a disclaimer from opinion.
FY97 - FY19
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
Unmodied
Opinion
Unmodied
opinion
Unmodied
Opinion
Unmodied
opinion
Unmodied
Opinion
Unmodied
Opinion
Met
Unmodied
opinion
Unmodied
opinion
FY 2023 Highlights: The FTC takes very seriously its commitment of responsible stewardship of the public re-
sources entrusted to us by the American taxpayers and Congress. The agency’s FY 2023 independent nancial
audit yielded its 27th consecuve unmodied opinion, the highest audit opinion available. The independent
auditors did not idenfy any material weaknesses, signicant deciencies, or instances of non-compliance with
internal controls, nancial systems, or laws and regulaons. The management leer did provide ndings and
recommendaons for improvement to internal controls or business pracces. These ndings will be addressed
in correcve acon plans and through regular updates on acons to implement correcons.
Metric 3.1.2: Percentage of contract acons awarded within FTC’s established Procurement Acon Lead Time
(PALT).
The agency’s Acquisions Branch engages in the me-intensive process of awarding government contracts,
task orders, and modicaons. To measure the eciency of this work, this metric tracks the percentage of con-
tract acons awarded within established lead mes. The lead-me varies depending on the type of contract.
Timely awarding of contracts is important to keep mission work moving forward.
FY 2023 Highlights: The FTC awarded 51 of 56 new contracts within established me frames, just meeng its
PALT target. FMO connues to focus on ways to improve procurement processes, especially for expert wit-
ness contracts, which have the shortest PALT of two weeks. Four of the ve contracts awarded that missed
their PALT were expert witness contracts. The PALT rate for expert witness contracts, which are a subset of the
contracts included here, was 75% (12 of 16 new contracts).
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A 91.1% 94.5% 90.6% 90.1% 90.0% Exceeded 90.0% 90.0%
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Metric 3.1.3: Percentage of contract dollars awarded to small disadvantaged businesses.
The federal government strives to ensure small businesses, not just large corporaons, are capable of winning
federal contracts. The FTC typically awards over $90 million in contracts each year to private companies for
supplies and services needed to complete its work. This metric tracks the percentage of FTC contract dollars
that are awarded to companies that classify as small (as measured in annual receipts and number of employ-
ees) and disadvantaged (owned by persons who are socially and economically disadvantaged), as classied by
the Small Business Administraon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
11.7% 15.4% 18.1% 15.5% 15.8% 15.0% Exceeded 15.0% 15.0%
FY 2023 Highlights: The FTC obligated funding of $18.1 million to small disadvantaged businesses in FY 2023,
out of a total of $114.3 million in total obligaons. Data for this metric, and other contract awards, is available
on https://www.usaspending.gov.
Metric 3.1.4: Number of training and informaon oerings to sta on climate literacy and resilience topics.
The FTC’s Climate Acon Plan, established in FY 2021, calls for enhancing FTC employees’ understanding of
how climate change impacts the FTC, and to promote educaonal resources and opportunies for those
employees where an understanding of climate resilience or climate change is integral to their work. The FTC
launched a series of voluntary acvies and will track training, educaonal products, and related acvies.
OCASO’s Communicaons and Informaon Management branch is responsible for implemenng FTC’s Climate
Adaptaon Acon to improve climate literacy.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 4 4 4 Met 4 4
FY 2023 Highlights: The FTC’s Chief Sustainability Ocer oversees selected provisions and government-wide
sustainability iniaves and provided climate-related training opportunies for interested FTC sta to improve
their understanding of climate resilience and climate change. The FTC has also begun implemenng provisions
like zero-emissions eet vehicles.
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Secondary Metric 3.1.5: Number of FOIA Requests Received, Processed, and the Cost of FOIA Ligaon
This metric tracks the number of incoming Freedom of Informaon Act (FOIA) requests, the number of re-
quests processed by the FTC’s FOIA team, and the cost of ligaon related to FOIA requests. While the number
of incoming FOIA requests is out of the FTC’s control, the FOIA team strives to respond to each request within
statutory deadlines.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
Number of FOIA Requests Received 1381 1177 1385 1619 1818
Number of FOIA Requests Processed 1361 1298 1375 1579 1811
Cost of FOIA Ligaon $22,988 $102,489 $166,155 $348,178 $787,889
FY 2023 Highlights: The Freedom of Informaon Act Unit connues to see increasing numbers of FOIA re-
quests received. Since 2020, the unit has seen rates of FOIA requests increase by approximately 200 each
year, a trend that is consistent with increases experienced by other government agencies. With the increased
number of FOIA requests, the unit has also seen high level of FOIA appeals and FOIA ligaons. Indeed, FY
2023 saw the highest-ever number of ongoing FOIA ligaons in a single year, a fact that led to the substanal
increase in FOIA ligaon costs shown on the table.
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Objecve 3.2: Culvate a high-performing, diverse, inclusive, and engaged workforce.
Goal Leaders: Execuve Director, Oce of the Execuve Director; Director, Oce of Workplace Inclusivity
and Opportunity; Director, Bureau of Consumer Protecon; Director, Bureau of Compeon; Director,
Bureau of Economics; General Counsel, Oce of the General Counsel
The FTC’s workforce is its greatest asset. The FTC will focus on recruing, developing, movang, and retaining
a high-performing, diverse, inclusive, and engaged workforce as the FTC advances organizaonal performance.
Having a workforce that looks like, and draws from, the public it protects strengthens the FTC’s ability to meet
its mission.
Connuous learning is a foundaon of the FTC’s training eorts. FTC sta needs to be aware of new develop-
ments in the marketplace and be agile enough to adjust to changing developments. A focus on training, includ-
ing cross-training sta on both consumer protecon and compeon issues, will ensure the FTC is ready to
accomplish its dual mission.
This objecve also captures eorts to ensure that all workers are compeng on a fair and level playing eld and
that all have the opportunity to achieve their utmost potenal.
Strategies
• Streamline and expedite hiring procedures: FTC looks to streamline and increase its hiring capability
by onboarding addional human resources personnel, idenfying and encouraging use of special hiring
authories when possible, streamlining internal processes through automaon, and working to ensure FTC
models OPM’s hiring meline.
• Improve recruitment: Explore use of expanded workplace exibilies to improve recruitment. Expand
hiring at regional oces. Place a stronger emphasis on targeted recruitment eorts to expand applicant
pools. Increase the FTC’s presence at job fairs and other events designed for specic job seekers (e.g.,
racial minories, veterans, persons from rural communies, persons with disabilies, members of the
LGBTQIA+ community, women aorneys, and law students, etc.).
• Expand sta skillsets: In addion to aorneys and economists, the FTC seeks to hire technologists, data
analysts, nancial analysts, business analysts, child psychologists, youth development experts, bilingual
and mullingual sta, and experts from other outside disciplines. This will allow the agency to build on
exisng talent and posion the FTC to analyze conduct, assess harms and remedies, and pursue market
studies with an interdisciplinary approach.
• Cross-train sta to develop a more exible workforce: Increase agency agility and exibility by training
sta in both mission areas (consumer protecon and compeon). Provide educaon and training oppor-
tunies that support the FTC workforce’s varied demographic backgrounds, experiences, and perspecves
at all levels and occupaons.
• Support performance management and accountability: Support an agency-wide performance culture that
focuses on individual and organizaonal accountability while meeng established agency goals. Reinforce
the FTC’s programmac priories and objecves using a system governing performance management.
Provide opportunies for employee recognion that reinforce FTC values and culture while improving
engagement and producvity.
• Develop leaders: Recruit and develop strategic and forward-thinking leaders who are agile, movated, and
knowledgeable and who can posion the FTC for success. Strengthen leadership in a way that embraces
an agency-wide approach to supporng a diverse, inclusive, and equitable workforce. Support current and
future leaders who provide eecve direcon, inspiraon, and guidance in nurturing the strengths and
talents of the workforce through building teams commied to achieving FTC goals.
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97
External Factors and Risks
• Current job market impacts
• Strong job markets have led talented sta to seek more lucrave opportunies at higher-paying agen-
cies or in the private sector.
• Eorts from Congress to require agencies to return to telework postures equivalent to 2019 may
impact recruitment and retenon, as current and potenal employees may seek alternate employment
opportunies.
• Workplace exibilies connue to be crical factors in aracng and retaining highly qualied per-
sonnel. Applicants and many current employees are seeking maximum telework and remote work
exibilies.
• Changes to government requirements for human capital management
• Changes to federal human capital regulaons, legal authories, mandates, and requirements may af-
fect the ability of the FTC to implement specic human capital strategies related to recruitment, train-
ing, and retenon.
• Availability of cost-eecve external training sources
• Cost-eecve external training resources may not be available to supplement and expand the agency’s
internal employee development and training opportunies.
FY 2023 Progress Update
• Workplace Flexibilies Policy
• The FTC nalized a “next phase” policy that provides a framework for the management and operaon
of FTC workplace exibilies programs. Workplace exibilies, such as telework, remote work, and
alternave work schedules, may be used as ecient and eecve strategic management tools for
aracng, retaining, and engaging talent to accomplish the agency’s mission as well as for advancing
diversity, equity, inclusion, and accessibility within the FTC workforce.
• The policy is designed to oer workplace exibilies to agency sta while maintaining a physical
workplace that serves as a hub of connecon and community. The FTC believes high quality perfor-
mance and achievement can be maintained in a hybrid environment while underscoring the value
of coming together in-person to collaborate, learn, mentor, and build relaonships.
• The policy reinforces the agency’s commitment to building a successful, sustainable, collaborave,
agile, and innovave hybrid workplace environment that embraces the work-life balance and well-
being of FTC employees, posioning them to work at their best in service of the agency’s mission.
The policy is designed to achieve fair and equitable implementaon of covered programs across the
agency and provide Bureaus and Oces sucient exibility to make individualized workforce and
workplace decisions that are crical to advancing the FTC mission.
• Oce of Workplace Inclusivity and Opportunity (OWIO)
• The FTC’s Oce of Equal Employment Opportunity and Workplace Inclusion was renamed this year,
into the Oce of Workplace Inclusivity and Opportunity. Their work connued its long-standing part-
nerships with employees and senior ocials across the agency regarding diversity, equity, inclusion,
and accessibility. FTC employees and senior ocials have an ongoing presence in volunteer groups and
commiees including the FTC Diversity Council, the Women’s Employee Resource Group, the Pride
Employee Resource Group, the Hispanic Employee Resource Group, and the Black Alliance Employee
Resource Group.
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• Training and Employee Development
• The FTC is focusing on learning modernizaon and systems opmizaons supporng employee’s
professional development needs and organizaonal mandated requirements. Specically, in FY23, the
learning management system eTrain2 underwent a signicant upgrade to provide improved services
to learners and update technical processes and procedures. Learning content was upgraded to the
Percipio plaorm providing addional content for all topic areas, including advanced leadership topics,
and DEIA content. Several FTC internal programs were designed, developed, and implemented and an
Execuve Leadership Development program was launched in FY23 with two cohorts and 50 execuves
compleng the program.
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Iniate eorts to establish an agency-wide workforce plan that supports succession planning within HCMO
and other FTC Bureaus and Oces.
• Integrate an HR Service Center with exisng FTC Service Now plaorm. This will enable FTC sta to iniate
HC service requests and research answers to frequently asked quesons on the same plaorm used for
technical support requests and queries.
• Use Microso Power Business Intelligence and other data analysis tools to create dynamic reports to
inform the agency’s workforce planning and decision-making processes.
• Improve the integrity of human capital data through periodic reviews to provide reliable, accurate, data-
driven insights to the FTC’s leadership team.
• Partner with hiring managers to deploy recruitment and outreach strategies to aract a diverse workforce,
including using the Schedule A hiring authority to increase the representaon rate of people with disabili-
es and using Veteran’s Recruitment Appointment and other hiring authories to increase the representa-
on of veterans at the agency to support diversity and encourage inclusion.
• Promote and expand the use of federal compensaon exibilies such as recruitment, retenon and relo-
caon incenves; superior qualicaons/special needs pay seng; and student loan repayments as well as
other human resources exibilies such as telework, reasonable accommodaon, and wellness programs
that support employee retenon and recruitment.
• Provide new managers with the training, skills, and resources to process reasonable accommodaon
requests correctly and foster an inclusive environment.
• Update internal Standard Operang Procedures to ensure the standardizaon and consistency of HCMO’s
operang processes and procedures.
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Performance Metrics
Metric 3.2.1: Annual score on the FEVS Employee Engagement Index
This metric tracks the Employee Engagement Index of the Federal Employee Viewpoint Survey (FEVS), an
annual survey of federal employees conducted by the Oce of Personnel Management (OPM). The index
gauges the extent to which employees believe that management listens and provides meaningful support and
feedback in various areas that assist sta in supporng the overall mission of the agency. The index is based on
FEVS quesons that assess three sub-factors: percepons of agency leadership, relaonships between workers
and supervisors, and feelings of movaon and competency.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
84% 89% 60% 62% 68%
Exceed
government-
wide average
(64%)
Exceeded
Exceed
government-
wide average
Exceed
government-
wide average
FY 2023 Highlights: The FTC’s Employee Engagement Index score rose 5 points to 79%, which is above the
government-wide average of 72% and the medium-size agency average of 76%.
Metric 3.2.2: Annual score on the FEVS Global Sasfacon Index
This metric tracks the FEVS Global Sasfacon Index. Measuring the overall job sasfacon of FTC employees
provides managers with important informaon regarding employees’ general sasfacon with their organiza-
on and the work they do. Overall job sasfacon is closely correlated with employee retenon.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
84% 87% 74% 74% 79%
Exceed
government-
wide average
(72%)
Exceeded
Exceed
government-
wide average
Exceed
government-
wide average
FY 2023 Highlights: The FTC’s Global Sasfacon Index score rose 6 points to 68%, which is above the govern-
ment-wide average of 64%, but below the medium-size agency average of 70%.
Metric 3.2.3: Annual score on the FTC Diversity and Inclusion Index.
This metric tracks the Diversity, Equity, Inclusion, and Accessibility (DEIA) Index of the Federal Employee
Viewpoint Survey (FEVS). This new index was established by OPM in 2022 to measure diversity, equity, inclu-
sion, and accessibility in the workforce.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 85% 87%
Exceed
government-
wide average
(71%)
Exceeded
Exceed
government-
wide average
Exceed
government-
wide average
FY 2023 Highlights: The FTC’s DEIA Index score rose 2 points to 87%, which is far above the government-wide
average of 71% and the medium-size agency average of 76%.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
100
Metric 3.2.4: Percentage of people with disabilies in the FTC workforce.
Each agency in the Execuve Branch of the federal government has established programs to facilitate the hir-
ing, placement, and advancement of individuals with disabilies. Calculaon of the percentage of people with
targeted disabilies in the FTC workforce allows the agency to track the success of these programs. This metric
shows the FTC’s progress toward the U.S. Equal Employment Commission’s (EEOC) target for federal agencies
to have 12% of a federal agency’s workforce be persons with disabilies, and 2% of a federal agency’s work-
force be persons with targeted disabilies.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
8.1% 8.0% 8.8% 8.6% 9.3%
Equal or
greater than
previous FY
Exceeded
Equal or
greater than
previous FY
Equal or
greater than
previous FY
Note: Results for FY 2021 and FY 2022 have changed from what was previously reported, from 8.7% to 8.8% in
FY 2021 and from 8.7% to 8.6% in FY 2022. In reviewing the data collecon for this metric, it was found that we
weren’t consistently gathering data from the same pay period each scal year. The data reported now consis-
tently uses the last pay period of the scal year as its recording point.
Metric 3.2.5: Percentage of people with targeted disabilies in the FTC workforce.
Each agency in the Execuve Branch of the federal government has established programs to facilitate the
hiring, placement, and advancement of individuals with disabilies. Calculaon of the percentage of people
with targeted disabilies in the FTC workforce allows the agency to track the success of these programs.
Self-idencaon of targeted disability status is essenal for eecve data collecon and analysis of the FTC’s
eorts. While self-idencaon is voluntary, employee cooperaon in providing accurate informaon is crical
to these eorts. Every precauon is taken to ensure that the informaon provided by each employee is kept in
the strictest condence.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
1.4% 1.3% 1.4% 1.4% 1.2%
Equal or
greater than
previous FY
Not Met
Equal or
greater than
previous FY
Equal or
greater than
previous FY
Note: In reviewing the data collecon for this metric, it was found that we weren’t consistently gathering data
from the same pay period each scal year. The data reported now consistently uses the last pay period of the
scal year as its recording point. Previously reported results were not aected by the change.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
101
Secondary Metric 3.2.6: Average number of days from job vacancy closing to making a tentave oer for new
hires.
This metric tracks the average number of days from job vacancy closing to making a tentave oer for new
hires. Performing the hiring process in a mely manner enables the FTC to connue to meet its mission by ll-
ing vacant posions with qualied persons as quickly as possible. Making mely hiring decisions increases the
likelihood that the agency will be able to recruit qualied, top candidates.
FY 2019 Actual FY 2020 Actual FY 2021 Actual FY 2022 Actual FY 2023 Actual
60 days 47.8 days 51.1 days 64.6 days 55.2 days
Note: The result for FY22 has changed from 57 days, reported previously, to 64.6 days. The previous result was
miscalculated.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
102
Objecve 3.3 Opmize informaon management.
Goal Leader: Execuve Director, Oce of the Execuve Director; Secretary, Oce of the Secretary
FTC mission success is increasingly dependent on IT systems and services. FTC sta relies on the agency’s IT
systems to manage the high volume of informaon gathered as part of the agency’s mission, and to comply
with mandates concerning the preservaon and handling of agency records. The FTC must invest in IT services
that will improve the user experience, allowing the agency to manage increasing data volumes eecvely while
meeng regulatory obligaons.
The FTC’s Informaon Resource Management (IRM) Strategic Plan establishes a mul-year plan for modern-
izing FTC’s IT capabilies, eliminang outdated systems, and using cloud-based soluons when praccal. By
properly assessing the future IT landscape, FTC can take advantage of emerging IT services while ensuring a
clear focus on mission objecves.
The FTC is also commied to eecve and ecient management of informaon resources and connues its
transion to managing informaon electronically to enable sta to perform their work more eciently, facili-
tate public access, and protect sensive informaon from inappropriate access.
The FTC must connue to address the challenges of a constantly evolving cyber security landscape. Informaon
and informaon systems must be protected from unauthorized access, use, disclosure, disrupon, modica-
on, or destrucon to ensure data integrity, condenality, and availability in the face of increasing cyber
threats.
Strategies
• Modernize technology: Transform and modernize informaon technology resources, using innovave ap-
proaches and best pracces, to increase funconality, improve performance, and achieve mission success.
Support transformaon and modernizaon that includes architecng applicaons and services on cloud-
based technology plaorms, upgrading and replacing end-of-support infrastructure and endpoints, and
increasing the use of automaon in business processes and IT management.
• Protect FTC data: Secure and protect informaon and technology resources from aack and loss of data,
accessibility, or integrity, whether from external malicious actors or insider threats. Ensure data and
informaon of all kinds are secure through use of secure authencaon pracces, implementaon of a
zero-trust security architecture, and monitoring of systems, services, and user behavior.
• Comply with federal records requirements: Develop an agency email records schedule and an associated
email capture and management process, which will allow idencaon and retenon of email records and
to associate emails with specic cases or maers. Addionally, implement an agency-wide program for
managing controlled unclassied informaon (CUI), starng with a standard method for marking docu-
ments and emails containing CUI, and reinforcing the importance of informaon management through
training, electronic and physical safeguarding, and other procedures.
• Mul-disciplinary collaboraon: Using modern technology with eecve controls for the protecon and
control of data and informaon, remove organizaonal barriers to collaboraon so agency leaders can
assign skilled resources to areas of most need in a way that imbues mul-disciplinary crical thinking into
all aspects of agency law enforcement.
External Factors and Risks
• Rate of change in the informaon technology industry
• If informaon technology providers release new products and features too quickly, the FTC may lag in
technology implementaon, increasing the likelihood of using obsolete or unsupported technologies.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
103
• New technologies may present unique informaon security challenges or require creave soluons to
securing the system without aecng user experience.
• Emerging and unforeseen informaon security threats and malicious actors
• Evolving informaon security threats aect the security of individual IT systems and services and the
FTC’s overall risk posture.
• New federal mandates and guidance on informaon security and IT management create new and
unexpected challenges and increase costs.
• Downward pressure in IT spending across the federal government
• Resources with skills needed to support emerging informaon security challenges and technologies are
drawn to agencies and organizaons with higher paying posions and benets.
• Downward pressure on federal spending could lead to limited funding/reduced resources available for
signicant upfront investments needed for IT modernizaon eorts.
• Hybrid work environment
• A hybrid work environment increases the complexity of securing IT networks and providing IT systems
and services to remote workers.
• Compliance with Records Management Direcves
• Potenal delay in transion of electronic records could occur due to dependence on approved records
schedules that the FTC is in the process of updang.
• FTC’s IT infrastructure modernizaon may delay idenfying the best soluon for the agency.
• Resource Constraints
• Constraints on personnel and funding may limit resources available to implement records retenon
schedules or develop agency-wide training and may hinder eorts to audit compliance with policies.
• Limited availability of Naonal Archives and Records Administraon (NARA) sta may delay approval of
email records schedule.
• Inexible Policies and Procedures
• As the FTC modernizes IT systems and increases the use of shared and cloud-based services, agency
policies and procedures regarding records management, privacy, informaon security, and risk manage-
ment may not align with technology and best pracces for modernized digital services, causing delays
in deployment, increased level of eort, and customer dissasfacon if expected funconality is not
available.
• Tradional methods of contracng for IT services may hinder the FTC’s ability to leverage agile develop-
ment methods and promote creavity and innovaon among contractors.
FY 2023 Progress Update
• Informaon Technology
• The FTC connued to advance toward a zero-trust network architecture, focusing on projects and
investments to improve the agency’s identy, credenal, and access management program. Specic
achievements include upgrades and enhancements to FTC’s chosen identy management and single-
sign-on soluon, updang user authencaon policies and password requirements, and “cleanup” of
old and unneeded system conguraons.
• The FTC upgraded technology components that serve as the infrastructure backbone for mission-
crical systems, including a complete replacement of the agency’s storage area network infrastructure,
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
104
replacement of aging data center power components, and upgrades to operang systems and eco-
nomic analysis applicaons.
• The FTC deployed a cloud-based, automated onboarding/ooarding applicaon, known as OchO, to
coordinate personnel onboarding, moves, changes, and ooarding across FTC organizaons.
• The FTC further strengthened its cybersecurity posture by moving to a cloud-based secure external le
sharing plaorm to the cloud, a major step towards the goal of eventually eliminang any on-premises
systems that accept external incoming trac.
• The FTC expanded the use of the Microso 365 oce producvity suite to include the use of
SharePoint Online, Teams, and OneDrive to enhance employee communicaon and collaboraon in a
hybrid workplace.
• The FTC awarded a new contract for a centralized security operaons center (SOC) with an integrated
security informaon and event management (SIEM) plaorm. The SOC will provide the security moni-
toring tools and specialized skills needed to analyze log data across FTC IT resources, using advanced
machine learning to proacvely detect and migaon security incidents.
• During FY 2023, the FTC further enhanced the security of user endpoints. The FTC migrated its
endpoint detecon and response (EDR) capabilies to a new plaorm managed by the DHS CISA
Connuous Diagnoscs and Monitoring (CDM) program to facilitate improved data sharing with CISA
and remove dependencies for EDR operaons on the FTC data center. Addionally, the FTC imple-
mented “geo-blocking” on all FTC standard issue laptops to block the use of FTC devices overseas.
Employees travelling outside of the United States must use a specially congured laptop to ensure
maximum protecon from foreign bad actors.
• The FTC updated several policies and processes regarding security and compliance in key areas such as
supply chain risk management and system authorizaon and completed the migraon of FTC-managed
systems to NIST 800-53 Rev 5 controls.
• The FTC improved user cybersecurity awareness and incident reporng through implementaon of
a new method for phishing reporng, which uses machine learning and automated responses based
on categories. The FTC also implemented automated phishing simulaon exercises and conducted
increased role-based security training for users with elevated system privileges.
• The FTC migrated agency le shares, data backups, and user authencaon services to a cloud-based
infrastructure environment to remove dependencies for mission-crical case data and le storage on
the FTC data center and improve resiliency. The FTC’s le share migraon represented a signicant
level of eort as the project migrated approximately 250TB of data from all FTC locaons, including the
Regional Oces, represenng crical documents from every organizaon within the FTC.
• Records Management
• The agency draed a role-based email records schedule for NARA review and appraisal and nalized a
policy on the use of electronically stored informaon.
• The FTC fully implemented an agency-wide controlled unclassied informaon (CUI) program. In ad-
vance of the program’s launch, FTC sta were required to complete mandatory training on designang
(marking), safeguarding, transming, and decontrolling CUI. Marking of CUI has begun agency-wide,
including the use of sensivity labels in Microso Outlook to designate informaon containing CUI.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
105
FY 2024 Next Steps and Future Acons to Meet Strategic Objecve
• Connue the move toward a Zero Trust Network Architecture, in accordance with the OMB
Memorandum 22-09 (Federal Zero Trust Strategy), including the opmizaon of the FTC’s remote
access and identy management plaorms and strengthening of privileged access management and
vulnerability management pracces.
• Implement an electronic ling system for the Hart-Sco-Rodino (HSR) Premerger Filing process. The
HSR electronic ling system will streamline the process for both FTC sta and public stakeholders. The
system will automate and digize the current manual process for subming complex and voluminous
lings for external pares preparing to merge or acquire.
• Complete the deployment of a cloud-based security informaon and event management (SIEM) plat-
form. The SIEM will provide security monitoring tools to analyze log data across FTC IT resources, using
advanced AI and machine learning to proacvely detect and migate security incidents.
• Upgrade the network backbone at the Commission’s Headquarters building. The HQ building has
not had any major network or infrastructure modernizaon in almost 10 years and no longer meets
the needs of the agency’s hybrid workforce and increasing bandwidth usage due to the use of cloud
compung.
• Rebuild the TexleRN applicaon in a secure cloud environment. This project will not only improve
FTC’s cloud adopon but will also enhance FTC’s security posture by allowing the agency to shut o
inbound external trac to the FTC data center, eliminang a major security vulnerability.
• Modernize all workspaces to support the new hybrid workforce. This includes the deployment of hotel-
ing staons that support remote workers vising the oce and the upgrade of all conferencing spaces
to support hybrid meengs using modern web collaboraon tools.
• Roll out agency-wide training on best pracces for email records management, including separate train-
ing for Commissioners and other senior ocials.
• Deploy new conferencing, communicaons, and collaboraon tools to support a hybrid workplace.
Performance Metrics
Metric 3.3.1: Percentage of FTC IT systems hosted outside of the FTC’s data center.
The FTC intends to move most of its informaon systems and services to externally hosted environments to
comply with Federal requirements for migrang to cloud soluons and away from in-house data centers to
improve availability, performance, and security. This metric tracks the number of systems hosted outside the
FTC’s Enterprise Data Center.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A 90.0% 91.4% 90.0% Exceeded 90.0% 90.0%
FY 2023 Highlights: During FY 2023, FTC added seven new cloud systems to its system inventory, including four
FedRAMP authorized soware-as-a-service applicaons. As new requirements emerge, FTC will connue to
priorize the use of cloud services to meet technology needs. In FY 2024 and FY 2025, FTC does not ancipate
any major increase in the number of cloud systems in use as the agency is focusing on ulizing available capa-
bilies in exisng cloud services to meet changing business needs.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
106
Metric 3.3.2: Availability of informaon technology systems.
Informaon technology systems must be available and accessible to support the FTC mission. Lack of availabil-
ity and accessibility severely constrains employees’ and managers’ ability to serve the public and stakeholders.
This metric tracks service outages and monitors the upme of crical informaon technology and end user
services, as well as the agency’s infrastructure backbone, including:
• Email
• FTC-specic applicaons and systems
• Wireless services
• Internet
• Intranet
• Phone and Voicemail
• Wide Area Network
• Ligaon support applicaons and systems
• Economic support systems
• Remote employee access
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
99.98% 99.97% 99.94% 99.67% 99.52% 99.50% Met 99.50% 99.50%
FY 2023 Highlights: The FTC met its availability target, reaching an actual availability of 99.52% for scal year
2023. In the rst quarter of FY 2023, FTC completed a transfer of connecvity services from a legacy soluon
dependent on Managed Trusted Internet Protocol (MTIPS) to a modernized virtual wide-area network solu-
on. This transion led to substanal system modicaons directed at enhancing overall system performance
and aligning with a Zero Trust network approach. However, the transion impacted legacy conguraons
for specic applicaons which led to signicant downme for certain individual applicaons and services.
Post-transion, FTC adjusted conguraons and contractor service level agreements (SLAs) to improve overall
accessibility, stability and availability for the aected applicaons. In subsequent quarters, availability im-
proved dramacally as FTC’s modernized network led to an increase in overall availability during the remaining
quarters of FY 2023. In FY 2024, the FTC ancipates connued improvements in overall system availability of
the agency connued to migrate mission-crical systems to high availability cloud environments and performs
major upgrades to the FTC’s headquarters building infrastructure.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
107
Metric 3.3.3: Annual score on the FTC Cybersecurity Index.
This metric monitors the agency’s progress in achieving mulple crical cybersecurity metrics, each of which
measures the agency’s cybersecurity posture and strength in protecng the condenality, integrity, and avail-
ability of informaon systems. The cybersecurity metrics that go into this Index are:
• Percentage of major system internal users using phishing resistant authencators
• Percentage of total of major systems where the desired state host inventory matches the actual state host
inventory
• Percentage of government-furnished equipment (GFE) host listed in the desired state host:
• Endpoint Detecon and Response (EDR) soware inventory matching the actual state host EDR so-
ware inventory
• Applicaon Control inventory matching the actual state host Applicaon Control soware inventory
• Zscaler Private Access (ZPA) soware inventory matching the actual state host ZPA soware inventory
• Data Loss Detecon or Prevenon (DLD or DLP) soware inventory matching the actual state host DLD/
DLP soware inventory
• Credenal vulnerability scan inventory matching the actual state host credenal vulnerability scan
inventory
• Log forwarding inventory matching the actual state host log forwarding inventory
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
6 of 8 7 of 8 6 of 8 7 of 8 7 of 8
Baseline
[new Index]
N/A 7 of 8 7 of 8
FY 2023 Highlights: The FTC met or exceeded 7 of 8 cyber security index targets. The one metric not met tracks
the percentage of endpoints meeng the desired state for applicaon control. The target for this specic met-
ric was not met due to discrepancies in reporng for endpoints with legacy applicaons and operang systems.
The FTC connues to learn and adjust its data collecon methods for this performance metric over me.
Annual Performance Report for FY 2023 and Annual Performance Plan for FYs 2024 and 2025
108
Metric 3.3.4: Meet milestones for developing an agency email records schedule and associated email capture
and management process.
As most recently arculated in OMB Memorandum M-19-21, Transion to a Fully Electronic Government,
federal agencies are required to move towards electronic informaon resource management and electronic
recordkeeping. Various reviews of the FTC’s internal processes have idened email management and records
schedules as signicant weaknesses in the FTC’s records management program. Sta is working on the devel-
opment of an email records schedule and associated process to capture and idenfy email records and dispose
of these records in accordance with the appropriate retenon schedule. This metric tracks progress on this
important project.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A
Email
records
schedule
and policy
draed
Submied
email
records
schedule
Submit email
records
schedule to
NARA for
approval
Met
Implement
Capstone
email
records
schedule
Complete
evaluaon
of FTC email
management
pracces
FY 2023 Highlights: In FY 2023, the FTC submied a role-based email records retenon schedule to the
Naonal Archives and Records Administraon (NARA) for approval. Under this role-based model, also known
as the Capstone approach, the length of me that an email record is preserved is based on an email account
owner’s role or posion rather than on the content of each individual email message. NARA approved this
Capstone-based email records schedule in August 2023, and the FTC is working to fully implement it.
Metric 3.3.5: Meet project milestones for developing and implemenng an agency wide approach for manag-
ing Controlled Unclassied Informaon (CUI).
Federal agencies are required to standardize the designaon of condenal yet unclassied informaon, or
CUI, in accordance with 32 CFR 2002, et seq. Designaon of this informaon in a standard manner assures fed-
eral agencies that CUI will consistently be handled properly. The agency’s CUI Working Group has been working
to implement an agency-wide program. This metric tracks progress on this important project.
FY 2019
Actual
FY 2020
Actual
FY 2021
Actual
FY 2022
Actual
FY 2023
Actual
FY 2023
Target
FY 2023
Status
FY 2024
Target
FY 2025
Target
N/A N/A N/A
Finalized CUI
processes
Implemented
CUI marking
and launched
training
Implement
CUI marking
and launch
training
agency-wide
Met
Conduct CUI
program
evaluaon
for DC oces
Conduct CUI
program
evaluaon
for regional
oces
FY 2023 Highlights: In FY 2023, the FTC fully implemented an agency-wide controlled unclassied informaon
(CUI) program. In advance of the program’s launch, FTC sta were required to complete mandatory training on
designang (marking), safeguarding, transming, and decontrolling CUI. Refresher training will be required
annually for all sta going forward. The FTC is acvely engaging with sta to monitor progress in complying
with program requirements and will begin conducng program evaluaons in FY 2024.
Descriptions
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions
111
Protecting Consumers: Budget by Activity
($ in thousands)
Fiscal Year 2024 Fiscal Year 2025
FTE Dollars FTE Dollars
Privacy and Identy Protecon 78 $18,060 82 $21,456
Financial Pracces 92 21,239 92 23,967
Markeng Pracces 96 22,342 98 25,784
Adversing Pracces 76 17,621 78 20,452
Enforcement 56 12,914 58 15,143
Consumer Response and Operaons 26 19,619 26 20,430
Ligaon Technology and Analysis 40 9,260 40 10,507
Consumer and Business Educaon 23 8,209 23 8,926
Economic and Consumer Policy Analysis 11 2,470 12 2,943
Management 12 2,753 12 3,106
Subtotal Direct 510 $134,487 521 $152,714
Support 171 $82,176 178 $108,870
Total 681 $216,663 699 $261,584
Protecng Consumers
The FTC advances its goal of protecng consumers through ve law enforcement areas (Privacy and Identy
Protecon, Financial Pracces, Markeng Pracces, Adversing Pracces, and Enforcement), as well as
through ve addional funcons (Ligaon Technology and Analysis, Consumer Response and Operaons,
Consumer and Business Educaon, Economic and Consumer Policy Analysis, and Management). The FTC’s
eight regional oces also further this goal by bringing a variety of consumer protecon cases within the ve
law enforcement areas and maintaining important contacts with state Aorneys General and other state and
local consumer protecon ocials.
Privacy and Identy Protecon
The goal of Privacy and Identy Protecon is to protect consumers’ privacy and to help consumers prevent,
migate, and remediate the damage caused by identy the. This program uses a combinaon of law enforce-
ment, consumer and business educaon, and policy iniaves to accomplish this goal.
• Consumer Privacy and Data Security: Privacy and Identy Protecon leads naonwide eorts to protect
consumers from unfair, decepve, or other illegal pracces involving the use and protecon of consumers’
informaon. Law enforcement under Secon 5 of the FTC Act is a central part of this program, including
cases in which companies collect, use, or share user informaon in ways inconsistent with user expecta-
ons, or fail to take reasonable steps to secure users’ data. Another key priority is protecng the privacy of
children under age 13 by enforcing the Children’s Online Privacy Protecon Act, which requires online ser-
vices that collect personal informaon from children to provide parents with noce and get their consent
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions112
prior to collecon, minimize data collecon and retenon, delete kids’ data upon request, and limit uses of
data. In the area of nancial privacy, the FTC enforces rules implemenng the privacy- and security-related
provisions of the Gramm-Leach-Bliley Act, including requirements that nancial instuons implement
reasonable administrave, technical, and physical safeguards to protect customer records and informaon.
In the area of health privacy, the FTC enforces the Health Breach Nocaon Rule, which requires certain
companies that experience a breach of consumers’ health informaon to nofy aected consumers,
the FTC, and, in some cases, the media. In addion to its enforcement eorts, the FTC issues reports and
hosts workshops, such as the annual PrivacyCon, at which new research on privacy and security issues is
presented. Privacy and Identy Protecon also conducts rulemaking relang to consumer privacy and data
security.
• Accuracy and Privacy of Credit Informaon: Privacy and Identy Protecon works to ensure the accu-
racy and privacy of consumer informaon used to screen applicants for loans, jobs, insurance, and other
benets. Privacy and Identy Protecon enforces the Fair Credit Reporng Act, which holds credit bureaus
and furnishers of informaon responsible for the accuracy of credit report informaon, gives consumers
the right to check and correct their credit reports, limits how such informaon may be used, and requires
reasonable procedures to ensure maximum possible accuracy of consumer reports, and that such informa-
on is obtained only by enes with a permissible purpose to use it.
• Identy The: The FTC serves as a centralized repository for consumer reports, vicm assistance, and edu-
caon services on avoiding and responding to identy the and is the leading source of this informaon
for consumer assistance and law enforcement training. Consumers can report incidents of identy the
online or by phone, and the complaints are entered into the FTC’s Consumer Sennel Network, which is
accessible to domesc and internaonal law enforcement partners. Addionally, the Commission also is-
sues numerous educaon materials to help consumers protect themselves from identy the and to deal
with its consequences when it does occur. Through the FTC’s IdentyThe.gov website (robodeidendad.
gov in Spanish), the agency provides a free, one-stop resource people can use to report and recover from
identy the that includes specic advice tailored to the types of identy the the consumer reported.
Financial Pracces
Financial services play an important role in the daily lives of virtually all Americans. Financial Pracces works
to ensure nancial services providers give truthful informaon, gain consumers’ consent to charges, and abide
by other basic rules, so that consumers can make beer-informed decisions and law-abiding companies can
operate on a level playing eld.
• Short-Term Lending and Lead Generaon: Financial Pracces protects consumers applying for short-term
loans, by ensuring that lending companies do not gain an unfair compeve advantage by promising false
loan terms, enrolling consumers in hard-to-cancel membership programs for access to credit or saddling
consumers with junk fees. It also takes acon against companies that subject consumers to potenal fraud
by selling their sensive loan applicaon informaon (leads) to non-lenders, oen without the consumers’
consent.
• Small Business Financing: Small businesses are a crical part of the economy, and they rely on nancing
to survive and grow. Through both law enforcement and, Financial Pracces protects small businesses and
their owners from decepve and unfair pracces in the markeng, servicing, and collecon of loans and
other alternave forms of nancing.
• Motor Vehicle Sales, Financing, and Leasing: For most consumers, the purchase of a car or truck is their
most expensive nancial transacon, other than the cost of housing. Financial Pracces leads the FTC’s
eorts to protect consumers from decepve or unfair pracces in auto purchasing, nancing, and leasing
transacons.
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• Debt Collecon: The Fair Debt Collecon Pracces Act prohibits decepve, unfair, and abusive debt collec-
on pracces that can harm consumers who are unable to pay their debts due to job loss or other nan-
cial problems. Financial Pracces uses enforcement and educaon to protect consumers from such harm-
ful pracces. It also makes policy recommendaons on developments in the debt collecon marketplace.
• Debt Relief and Credit Repair Services: Financial Pracces targets rms that make decepve oers to
assist consumers in reducing or renegoang their debt, including a mortgage, or repairing their credit.
These claims mislead consumers already in nancial distress about what services they will provide and
how much they charge for them. The scams vary, and include oers to provide mortgage loan modica-
on, foreclosure relief, short sales, mortgage renancing, loan forgiveness, debt selement, debt negoa-
on, and credit counseling. Vicms oen nd themselves in even more dire nancial straits than before
engaging the services.
• Student Loans and Educaon: Consumers invest substanal me and money in educaon, oen incurring
steep debt. Financial Pracces leads the FTC’s enforcement eorts against decepve and unfair pracces
in the educaon sector. Those eorts include taking acon against higher educaon instuons that de-
ceive consumers about their employment and earnings prospects, and against educaon lead generators
that lure consumers into providing their personal informaon under false pretenses.
• Emerging Financial Pracces: New consumer and small business nancial products connually emerge in
the non-bank nancial marketplace, from cryptocurrency to crowdfunding and more. Financial Pracces
has been examining these developments, reaching out to stakeholders, gathering informaon through
public dialogue and workshops, and bringing acons emphasizing that companies using new technologies
must follow the same basic laws as tradional market parcipants, including by honoring promises to
consumers and obtaining consumers’ consent to charges.
Markeng Pracces
Markeng Pracces ghts frauds and enforces rules to protect consumers. Its enforcement priories include
scams with high-dollar losses and those that target or disproporonately impact parcular segments of the
populaon. Markeng Pracces enforces the Commission’s rules that prohibit spam and protect purchasers
of franchises and business opportunies, funeral services, and certain products with warranes, including
protecng purchasers’ right to repair products where the consumer chooses without voiding the warranty.
Markeng Pracces also spearheads the FTC’s work to pursue those that violate the Do Not Call and robocall
provisions of the Telemarkeng Sales Rule (TSR) and tackles online and high-tech fraud. By leading the Every
Community Iniave and Legal Services Collaboraon, Markeng Pracces seeks to enhance the FTC’s work to
ght fraud that targets or disproporonately aects lower-income communies, communies of color, older
consumers, veterans and acve service members, small business owners, gig economy workers, rural commu-
nies, and others.
• Fraudulent Schemes: One focus of the FTC’s fraud program is to stop scams harming people who seek
to work independently or generate addional income. Markeng Pracces targets fraudulent business
opportunity and investment schemes, including coaching and mentoring scams, fraudulent mul-level
markeng operaons, schemes purporng to teach consumers how to generate income trading in nan-
cial markets and invesng in real estate, and invenon-promoon scams. Markeng Pracces also targets
“imposter” schemes, where scammers impersonate government agencies or well-known companies to
enhance the credibility of otherwise decepve sales pitches. In addion, Markeng Pracces brings ac-
ons to stop decepve prize promoon schemes, grant scams, fake healthcare plans, and sham charitable
fundraising. Markeng Pracces also coordinates the FTC’s work to reduce fraud through research and
analysis into how fraud aects dierent segments of the populaon and how the agency can best respond
to ght fraud aecng every community. As part of this mission, Markeng Pracces leads the coordina-
on of the FTC’s elder jusce work.
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• Rule Enforcement: In addion to enforcing the TSR, Markeng Pracces enforces the Commission’s
Franchise and Business Opportunity Rules, which require specic material disclosures in the markeng and
sale of a franchise or a business opportunity. Markeng Pracces also enforces the CAN-SPAM Rule, the
BOTS Act, and the FTC’s interpretaons of the Magnuson-Moss Warranty Act and coordinates the agency’s
enforcement of the Funeral Rule. As an outgrowth of its work under the Magnuson-Moss Warranty Act,
Markeng Pracces is spearheading the agency’s work addressing repair restricons imposed by manufac-
turers and sellers.
• Telemarkeng Fraud and Do Not Call: Markeng Pracces enforces the TSR, including its Do Not Call and
Robocall rules, to shut down abusive and decepve telemarkeng schemes. Working closely with state
Aorneys General, other federal, state and internaonal law enforcers, as well as private sector partners,
Markeng Pracces targets areas for law enforcement, organizes enforcement sweeps, and helps publicize
consumer and business educaon to combat telemarkeng fraud and violaons of the Do Not Call and
Robocall Rules. Markeng Pracces also has spurred the development of technological tools that block un-
wanted calls, helped advance the next generaon of Caller ID authencaon, and worked with the Oce
of Technology to iniate a public challenge to address the proliferaon voice-cloning scams.
• Facilitang Fraud: Markeng Pracces enforces the law against enes that facilitate fraud. Those enes
include Voice over Internet Protocol service providers and lead generators that assist illegal robocallers, as
well as payment processors that provide fraudsters with access to the banking or credit card systems.
• Internet Fraud: Markeng Pracces leads the FTC’s law enforcement eorts to prevent and halt online
fraud, including “tech support” scammers, who mislead consumers into believing that their computers
are infected with malware or have performance problems in order to sell them expensive online repair
soware.
Adversing Pracces
Adversing Pracces enforces the naon’s “truth-in-adversing” laws and, through reports, advocacy, and
industry outreach, arculates the FTC’s policies on adversing regulaon. Whether ads appear online, on
social media, television, or radio, or in print, these laws require companies to tell the truth and to back up their
claims with reliable, objecve evidence. Adversing Pracces uses a variety of tools to protect consumers from
misleading claims, including bringing law enforcement acons in federal and administrave courts, issuing
cease and desist demands, providing guidance to industries, and providing consumer and business educaon.
Working to protect consumers’ health, safety, and economic interests, these eorts span a broad range of
products and pracces.
• Online Adversing and Markeng: Adversing Pracces monitors and develops eecve enforcement
strategies for issues including inuencer markeng, online reviews, nave adversing, arcial intel-
ligence, adversing to kids , and other emerging trends in digital adversing and technology. Adversing
Pracces enforces the basic principles, as laid out in the FTC’s Endorsement Guides, that endorsements
must be truthful and not misleading, and that material connecons between adversers and endorsers
should be disclosed clearly. Adversing Pracces also enforces the Consumer Review Fairness Act, which
prohibits contract provisions that restrict a consumer’s ability to post truthful reviews about a seller’s
goods, services, or conduct. Adversing Pracces engages in signicant outreach to educate businesses,
especially small businesses, about how to comply with the FTC Act when using endorsers, inuencers, and
online reviews.
• Adversing for Foods, Over-the-Counter Drugs, Dietary Supplements, Medical Devices, and Health-
Related Services: Adversing Pracces devotes substanal resources to ensuring the accuracy of health
claims in adversing and takes acon against companies making decepve representaons. During the
Coronavirus pandemic, Adversing Pracces sued marketers for violaons of the COVID-19 Consumer
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Protecon Act. In addion to tradional law enforcement acons, Adversing Pracces works with other
federal agencies such as the Food and Drug Administraon to protect consumers’ health, including by
sending cease and desist demands to companies making misleading health claims. Adversing Pracces
also monitors decepve adversing of addicon-related services, including enforcement of the Opioid
Addicon Recovery Fraud Prevenon Act. The FTC also creates educaonal materials to help companies
understand claims substanaon requirements and to help consumers spot decepve claims.
• Decepve Naonal Adversing, including about Junk Fees: Adversing Pracces addresses decepve
naonal adversing pracces in a variety of media and marketplaces through law enforcement, sta guid-
ance, and policy work. The FTC’s targets have included junk fees, consumer products and food companies,
retailers, event cket companies, online travel sites, and adversing agencies. Adversing Pracces has
also issued guidance to adversers on making eecve disclosures online and held workshops on the
cket resale market and lootboxes in online games.
• Tobacco, E-Cigaree, and Alcohol Adversing: Adversing Pracces leads the FTC’s eorts to stop the
decepve or unfair markeng of tobacco, including e-cigarees, and alcohol, administers federal laws
governing the rotaon of health warnings on ads and packaging for cigarees, and publishes annual
reports on cigaree and smokeless tobacco adversing and markeng. In 2022, the FTC issued its rst
report on e-cigaree sales and adversing. The FTC coordinates with the FDA, as the FDA has assumed
many tobacco-related responsibilies pursuant to the Family Smoking Prevenon and Tobacco Control
Act. Adversing Pracces also monitors self-regulaon of the alcohol adversing industry and encourages
improved standards and compliance.
• Contact Lens and Eyeglass Rule Administraon and Enforcement: Adversing Pracces enforces the
Contact Lens and Eyeglass Rules, which require that contact lens and eyeglass prescribers (optometrists
and ophthalmologists) automacally provide paents with a copy of their prescripons at the comple-
on of a lens or eyeglass ng. The Contact Lens Rule also prohibits lens sellers from providing lenses to
customers without rst verifying prescripon informaon. Adversing Pracces has brought a number of
cases enforcing the Contact Lens Rule, has sent cease and desist demands to numerous prescribers and
sellers regarding possible Contact Lens Rule or Eyeglass Rule violaons, and engages in ongoing business
educaon.
Enforcement
Enforcement ligates civil contempt and civil penalty acons to enforce federal court injuncons and admin-
istrave orders in consumer protecon cases; coordinates acons with criminal law enforcement agencies
through its Criminal Liaison Unit; develops, reviews, and enforces a variety of consumer protecon rules and
guides; administers the Bureau’s green markeng program; coordinates the negave opon iniave; and
handles bankruptcy and collecon maers in consumer protecon cases.
• Order Enforcement: Enforcement is responsible for ensuring compliance with all administrave and
federal court orders entered in FTC consumer protecon cases. To carry out this mission, Enforcement
acvely monitors compliance with consumer protecon orders, conducts invesgaons of possible order
violaons, ligates civil contempt acons in federal court to enforce injuncons, and iniates court acons
to obtain civil penales for administrave order violaons.
• Criminal Liaison Unit: The Criminal Liaison Unit (CLU) encourages criminal prosecuon of those respon-
sible for consumer fraud by idenfying fraudulent acvies, bringing them to the aenon of criminal law
enforcement authories, and coordinang civil and criminal enforcement acons. CLU works closely with
prosecutors, criminal invesgave agents, and FTC sta to ensure the smooth progress of parallel prosecu-
ons. In addion to idenfying and referring specic fraudulent acvity, CLU also educates criminal law
enforcement authories about the FTC and its mission and provides legal and praccal advice to FTC sta.
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• Rules and Guides: Enforcement develops, reviews, and enforces a variety of consumer protecon rules
and guides. For example, to protect consumers in the energy arena, Enforcement is responsible for rules
requiring the disclosure of operang costs of home appliances (the Energy Labeling Rule), octane rat-
ings for gasoline (the Fuel Rang Rule), and the eciency rang of home insulaon (the R-Value Rule).
Enforcement also presides over rules and guides as diverse as the Mail or Telephone Order Merchandise
Rule, which requires companies to ship goods when promised; the Texle, Wool, Fur, and Care Labeling
Rules, which require proper origin and ber content labeling of texle, wool, and fur products, and care
instrucons; and the Jewelry Guides, which provide guidance on the markeng of precious metals, gem-
stones, and pearls.
• Green Markeng: The FTC’s Green Markeng program focuses on adversing claims that tout the envi-
ronmental benets of products and services. Enforcement administers the program by developing the
Commission’s Environmental Markeng Guides, ligang enforcement acons, and conducng consumer
research and other studies to beer understand the marketplace.
• Negave Opon Markeng: Enforcement coordinates the Negave Opon Markeng iniave that ad-
dresses decepve pracces in the use of negave opon oers. To accomplish this mission, Enforcement
ligates civil acons against marketers that deceive consumers; manages the Commission’s enforcement
of key tools like the Restore Online Shoppers’ Condence Act; and issues reports that discuss markeng
trends and provide guidance to industry.
• Made in USA (MUSA) Claims: The Enforcement Division runs the Commission’s MUSA program, bringing
law enforcement acons against those who decepvely make country-of-origin claims; draing rules to
address MUSA claims; and providing guidance to companies to ensure consumers receive accurate, truth-
ful informaon.
• Bankruptcy: Enforcement’s bankruptcy/commercial law aorneys represent the Commission in federal
bankruptcy court and advise sta generally on a host of bankruptcy and commercial law issues. The bank-
ruptcy group preserves and enforces the Commission’s claims for monetary relief, ensures that defendants
do not use bankruptcy as a haven from law enforcement acons, and counsels sta on a wide variety of
bankruptcy and commercial law issues related to monetary relief.
• Collecons: Enforcement conducts invesgaons, aaches assets, and ligates contempt acons in order
to collect outstanding monetary judgments obtained by the Bureau of Consumer Protecon. Addionally,
Enforcement coordinates collecon acvies with the Department of the Treasury.
Ligaon Technology and Analysis
Ligaon Technology and Analysis plays a central role in BCP’s invesgaon and ligaon of consumer protec-
on maers, including working with aorneys to assess ligaon support needs, managing the technological
tools used to conduct invesgaons and ligaon, and evaluang and implemenng emerging technologies. In
an age of increasingly complex technology, sta needs access to the best tools available in order to invesgate
targets and marshal evidence. Ligaon Technology and Analysis is responsible for various eorts and acvi-
es, including:
• Digital Forensic Unit: The Digital Forensic Unit conducts forensic examinaons of digital media to idenfy,
collect, analyze, and preserve electronically stored informaon for use in court.
• E-Discovery Unit: The E-Discovery Unit uses technological tools to process, organize, manage, and produce
electronically stored informaon.
• Forensic Accounng: Forensic accountants analyze nancial informaon to calculate consumer harm, help
locate assets, and maximize the amount of money that can be recovered and returned to the public.
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• Honors Paralegal Program: Honors paralegals provide a wide range of assistance to BCP on invesgaons,
ligaon, and policy iniaves.
• Tech Lab: The Tech Lab provides BCP sta innovave tools to invesgate targets, detect unfair or decepve
acvity, capture evidence, and conduct research. The Lab’s stand-alone network is designed to allow BCP
sta to replicate consumers’ experiences with desktop, mobile, and other devices.
• Technology Planning: The Division’s sta analyzes and ancipates BCP’s technological needs in fullling its
consumer protecon mission.
Consumer Response and Operaons
Consumer Response and Operaons hears directly from consumers across the country and analyzes informa-
on to assist in targeng law enforcement and educaonal eorts, measures the impact of mission acvies,
returns money to consumers obtained as a result of FTC lawsuits, and idenes needs and allocates resources
within BCP.
• Consumer Response Center: The Consumer Response Center responds to consumer reports and in-
quiries received by the toll-free consumer lines, 877-FTC-HELP and 877-ID-THEFT, the online form at
www.ReportFraud.ftc.gov, and postal mail. Informaon from consumer reports is entered into the FTC’s
Consumer Sennel Network and used to target law enforcement and consumer and business educaon
acvies. Recently, Consumer Response and Operaons enhanced the agency’s capability to take and
respond to fraud and identy the reports and provide guidance on what to do next in the consumers’
preferred languages, all through telephone interpreters.
• Consumer Sennel Network: The Consumer Sennel Network is the FTC’s secure database that provides
nearly 3,000 law enforcement users worldwide with access to millions of consumer fraud, identy the,
nancial, and Do Not Call Registry complaints largely collected during the past ve years. The FTC rounely
shares this data in dierent formats such as visualizaons, reports, API endpoints, and datasets.
• Naonal Do Not Call Registry: The Naonal Do Not Call Registry is the mechanism through which consum-
ers can elect to avoid receiving telephone solicitaons from telemarketers. Telemarketers are required to
remove any telephone numbers included in the registry from their calling lists. The registry currently has
over 248 million acve telephone number registraons.
• Data Analysis Team: The Data Analysis Team performs analycal research, provides data to the public on
interacve dashboards, and creates reports about trends in consumer protecon complaints. The Data
Analysis Team also provides analycal support to the Bureau’s law enforcement eorts through collecng,
rening, and analyzing data in support of ligaon and invesgave eorts.
• Oce of Claims and Refunds: The Oce of Claims and Refunds (OCR) is responsible every year for distrib-
ung millions of dollars of refunds obtained as a result of FTC lawsuits. For example, from January 2022
through December 2022, the FTC’s law enforcement acons resulted in more than $392 million in refunds
to more than 1.9 million people.
• Operaons: Operaons manages budget and performance measurements, including strategic planning for
the Bureau; oversees and supports procurement eorts on behalf of the Bureau; monitors and reports on
human capital management to the Director’s Oce; and works closely with the other Bureau divisions and
regions to ensure administrave and resource needs are met.
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Consumer and Business Educaon
Consumer and Business Educaon runs creave naonal campaigns to educate consumers about their rights
and businesses about their responsibilies.
• Outreach to Consumers and Businesses: Consumer and Business Educaon creates print and online
consumer and business educaon material in partnership with other divisions in the Bureau of Consumer
Protecon. It parcipates in hundreds of outreach events each year, including webinars, trainings, and
presentaons. Working with naonal and local partners that are trusted in their communies, Consumer
and Business Educaon reaches a range of audiences, including older adults, ethnic media, housing organi-
zaons, small businesses, and higher educaon organizaons. Many of these outreach eorts are focused
on reaching specic communies, including the Lano, Black, Asian American and Pacic Islander, Nave
Hawaiian, Tribal, and the LGBTQ+ communies. By aending conferences and using webinars, tele-town
halls, Twier chats, Facebook Live events, mailings, as well as interviews with local and naonal media,
Consumer and Business Educaon ensures that messages get to people where they are. Consumer and
Business Educaon publishes hundreds of consumer and business alerts, many in English and Spanish, and
regularly emails them to nearly 540,000 subscribers. It also manages the FTC’s bulk publicaon ordering
website, through which an average of 10,000 organizaons a year order free material to distribute in their
communies.
• Pandemic Response: Consumer and Business Educaon conducted signicant outreach during the
pandemic, focusing on reaching the communies targeted the most by pandemic-related scams and hit
hardest by the nancial impact of the pandemic. Consumer and Business Educaon held 16 Ethnic and
Community Media Briengs that brought together journalists, state and local law enforcement, legal
services, and community advocates to discuss scams and bad business pracces aecng communies of
color, immigrant communies, Tribal communies, and English language learners. Consumer and Business
Educaon has targeted millions of consumers in communies across the United States to promote a
website aimed at helping people deal with the nancial impact of the pandemic. Topics from the site have
been featured in six naonal and targeted radio tours, reaching millions of listeners naonwide.
• IdentyThe.gov: Consumer and Business Educaon and Consumer Response and Operaons operate
IdentityTheft.gov, the government’s one-stop resource for people to report and recover from identy
the. The website produces personal recovery plans and identy the reports that people can use in place
of police reports to help restore their credit to its pre-crime status. The site also helps people report tax
identy the to the IRS and is integrated with the Consumer Sennel Network to aid law enforcement.
Since its launch in January 2016 through May 2023, people have submied nearly 5.2 million identy the
reports through IdentyThe.gov. Consumer and Business Educaon and Privacy and Identy Protecon
also lead Identy The Awareness Week, an annual event during which the FTC joins with other federal
agencies, non-prot groups, and consumer advocates to promote identy the prevenon. In the rst
eight months of FY 2023, Consumer and Business Educaon distributed nearly 1.1 million identy the
print publicaons.
• Outreach to Military Servicemembers: Consumer and Business Educaon developed and currently man-
ages the Military Consumer iniave together with the U.S. Department of Defense’s (DoD’s) Oce of
Financial Readiness, the Consumer Financial Protecon Bureau, and a network of more than 50 other
military, federal, and state partners. The campaign addresses unique challenges of military life that oen
make military personnel and families targets for scammers. Servicemembers and their families, along with
the DoD’s Personal Financial Managers who serve them, use the campaign website, MilitaryConsumer.
gov, as a tool for nancial readiness. The iniave also includes outreach to veterans and their families
and includes FTC parcipaon in an ongoing iniave organized by the Execuve Oce of the President
and Department of Veterans Aairs to convene stakeholders around outreach to alert veterans and their
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families about evolving scams. The FTC has distributed nearly 1.25 million Military Consumer bookmarks
since their creaon in 2017.
• Outreach to Older Adults: A key priority for Consumer and Business Educaon is helping older adults
know how to spot, avoid, and report scams. The FTC’s Pass It On campaign helps older adults do just that.
Recently updated, the research-based campaign covers 13 topics that oen aect older adults; Consumer
and Business Educaon has distributed nearly 18.8 million pieces of Pass It On educaonal material since
the campaign launched in July 2014 through May 2023. The Agency’s work and experience on Pass It On
is closely linked to its Congressionally mandated work under the Stop Senior Scams Act (SSSA). As part of
SSSA, Consumer and Business Educaon co-leads commiees focused on expanding consumer educaon
and outreach eorts and improving industry training on scam prevenon. Together, commiee members
— including 60 federal, state, and local agencies, consumer advocates, and industry representaves — are
formulang recommendaons to address gaps in exisng resources, as well as highlighng best pracces
to ght scams that aect older adults. Consumer and Business Educaon also launched a pilot outreach
program that works with a diverse set of partners to test messaging and approaches to more eecvely
reach older adults with informaon on spong, avoiding, and reporng scams.
• Data Security: The FTC connues its successful eorts to educate businesses and consumers alike about
privacy and data security. From 2015 through May 2023, Consumer and Business Educaon distributed
more than 12.7 million copies of educaonal materials to help consumer and business address these
issues. The agency’s popular Start with Security and Cybersecurity for Small Business business outreach
campaigns feature a suite of free publicaons, including guides and videos, that help businesses protect
personal informaon and learn steps to take if a data breach occurs. Consumer and Business Educaon
also publishes materials in English and Spanish to help business and their customers stay safer online,
avoid identy the, and protect children’s privacy. In addion, Consumer and Business Educaon provides
resources to parents and educators to help protect children online.
• Business Educaon: Consumer and Business Educaon manages the FTC’s online business educaon web-
site and publishes hundreds of blog posts annually for businesspeople from companies small and large,
aorneys, and other professionals. Most case announcements, rulemaking updates, and other iniaves
are accompanied by a to-the-point Business Blog post that summarizes what companies need to know and
links them to primary resources. Consumer and Business Educaon has devoted parcular aenon to
advising businesses about developments in the use of arcial intelligence, including guidance on how the
misuse of consumers’ personal informaon to power AI-related algorithms violates the FTC Act. Consumer
and Business Educaon issued guidance on complying with the recently enacted INFORM Consumers Act,
worked with the Division of Adversing Pracces to promote the new Health Products Compliance Guide,
and addressed developments in social media markeng by signicantly revising “FTC Endorsement Guides:
What People are Asking.” In addion, Consumer and Business Educaon sta regularly speak with small
business owners, community business organizaons, and business students to demysfy legal compliance
and explain the fundamentals of statutes and rules enforced by the FTC.
• Small Business: Consumer and Business Educaon makes materials for small business accessible in English
and in Spanish, including relevant business blogs, such as a series on franchise fundamentals. Eorts to
have informaon available for small business in other languages are ongoing. Outreach eorts to give
guidance to small business in other communies of color are also ongoing. Most recently, Consumer and
Business Educaon sta oered a webinar on cybersecurity and protecng personal and business informa-
on to the African Career and Educaon Center, an organizaon that gives technical assistance to busi-
ness owners in Minnesota, and oered cybersecurity advice on the Hoporenkv Podcast, which provides
resources and informaon to Nave American communies.
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• Partnerships with Law Enforcement: Many law enforcement groups use Consumer and Business
Educaon materials to do community outreach and use FTC resources for their consumer fraud inves-
gaons. Those groups include the Internaonal Associaon of Chiefs of Police, the Naonal Sheris’
Associaon, and the Hispanic American Police Command Ocers Associaon. Consumer and Business
Educaon works with other federal law enforcement agencies and the Naonal Associaon of Aorneys
General to promote consumer protecon messages. It also leads the Naonal Consumer Protecon Week
campaign, an annual weeklong event whereby the agency partners with state aorneys general, local law
enforcement, and consumer protecon, regulatory, and advocacy groups .
• Outreach in Mulple Languages: Consumer and Business Educaon conducts ongoing outreach in mul-
ple languages in addion to English and Spanish. At ftc.gov/languages, consumers can nd informaon
in a dozen languages to help them spot and avoid scams, as well as know what to do if they paid a scam-
mer. People can nd informaon in Amharic, Arabic, Chinese (Simplied and Tradional), French, Hmong,
Korean, Russian, Somali, Spanish, Tagalog, Vietnamese, and Ukrainian. Consumer and Business Educaon
also shares this informaon with sources trusted within these communies, including refugee and im-
migrant organizaons, legal advocates, chambers of commerce, Congressional commiees and caucuses,
ethnic media, and state, local, and community liaisons. Consumer and Business Educaon also regularly
conducts media interviews in Spanish and parcipates in ethnic media briengs and community round-
tables held across the country as part of the FTC’s Every Community Iniave.
Economic and Consumer Policy Analysis
Sta in the Bureau of Economics conducts economic and consumer policy analysis to provide the Commission
and other policy makers with informaon to assess and formulate consumer protecon policy. Economic and
Consumer Policy also works to ensure that consumer interests are represented before various governmental
and self-regulatory bodies dealing with consumer-related issues.
• Consumer Research and Data Development: To advance the development of sound policy, Economic and
Consumer Policy Analysis supports data and research projects by analyzing how policies aect consumers’
and rms’ decisions. Past studies on markeng claims examined the eects of dierent types of disclo-
sures on consumers’ understanding of “recycled content” and “organic” claims for non-food products and
the likely eects on consumer choice of “resort fee” pricing in the hotel industry. Ongoing research also
includes analysis of the demographic composion of recipients of redress in FTC cases.
• Economic Studies of Markets for Consumer Goods and Services: Economic and Consumer Policy Analysis
supports targeted economic studies of issues in consumer goods markets that are important to improving
our understanding of key consumer protecon issues. Recent examples include studies of credit reporng
accuracy, consumer auto buying experiences, class-acon nocaon pracces, and consumer complaints
among dierent demographic groups. The program also supports consumer surveys, such as those mea-
suring consumer suscepbility to fraud, and workshops with outside experts in relevant areas, such as
research roundtables on individualized pricing, privacy and data security, the sharing economy, and con-
sumer understanding of recyclability claims.
• Economic Support of Consumer Protecon Advocacy: Bureau of Economics sta also provides input for
comments to other federal agencies on issues related to consumer protecon goals. In the past, they have
supported the development of comments to the FDA on food labels and direct-to-consumer prescripon
drug adversing, homeopathy, and to the Consumer Financial Protecon Bureau and the Department of
Housing and Urban Development on various changes in mortgage disclosure documents. More recently,
sta has consulted with NIST on designing Internet of Things security cercaon programs and USDA on
Made in USA labeling.
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• Economic Support of Rulemaking: Bureau of Economics sta develops regulatory analyses to support
rulemaking acvies that advance consumer protecon objecves. Recent advance noce of proposed
rulemakings and proposed rules include the click-to-cancel, commercial surveillance and data security, and
unfair or decepve fees rulemakings.
Other Direct Funcons
Several other funcons within the consumer protecon mission directly support our primary law enforcement
work, including:
• Employee Development and Training: Through its Employee Development and Training Program, the FTC
ensures that sta receives the training necessary to perform their jobs. BCP provides training through
ongoing seminars, “brown bags,” and lectures on topics such as the anatomy of a maer, privacy “nutri-
on labels,” and generave arcial intelligence. BCP also sponsors periodic seminars for invesgators and
provides technical trainings throughout the year. In addion, BCP oers a mentoring program to sta. Sta
also parcipates in the FTC Agency-Wide Diversity Council.
• Administrave Support: Sta in the Director’s oce provide support to senior Bureau management to
ensure all administrave needs are met, such as arranging travel, tracking the Bureau’s accomplishments,
scheduling internal and external meengs, maintaining a log of current cases, and interacng with callers
and visitors.
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Promoting Competition: Budget by Activity
($ in thousands)
Fiscal Year 2024 Fiscal Year 2025
FTE Dollars FTE Dollars
Premerger Nocaon 19 $4,798 19 $5,595
Merger and Joint Venture Enforcement 256 62,944 269 76,112
Merger and Joint Venture Compliance 11 2,744 11 3,184
Nonmerger Enforcement 188 46,926 198 57,300
Nonmerger Compliance 1 252 1 294
Antrust Policy Analysis 33 7,911 35 9,111
Other Direct 22 5,422 22 6,258
Subtotal 530 $130,997 555 $157,854
Support 177 $82,340 189 $115,562
Total 707 $213,337 744 $273,416
Promong Compeon
The FTC promotes compeon through ve primary law enforcement acvies (Premerger Nocaon,
Merger and Joint Venture Enforcement, Merger and Joint Venture Compliance, Nonmerger Enforcement, and
Nonmerger Compliance) supported by Antrust Policy Analysis and other direct funcons.
Premerger Nocaon
Mergers that substanally reduce compeon or tend to create a monopoly violate the law. The Premerger
Nocaon Program, codied in the Hart-Sco-Rodino (HSR) Act, is the FTC’s primary means of idenfying
potenally illegal deals. Under the Act, enes meeng certain thresholds must le nocaons with the FTC
and the Department of Jusce and wait a prescribed period before consummang their transacons. This wait-
ing period provides the antrust enforcement agencies an opportunity to prevent potenally ancompeve
mergers before they occur. In addion, the FTC reviews news publicaons, industry research, and customer
complaints to idenfy potenally harmful mergers not subject to the HSR reporng requirements. To deter-
mine if a transacon may violate the law, the FTC conducts invesgaons using a range of methods and tools.
The FTC’s Premerger Nocaon Program supports eecve and ecient compeon enforcement by:
• Facilitang Compliance with HSR Requirements: The FTC’s Premerger Nocaon Oce (PNO) provides
informaon and guidance to ensure that pares understand when a ling is required and what informa-
on they must supply under the HSR Act. In doing so, the PNO’s eorts also seek to deter companies from
failing to comply with HSR requirements. When HSR violaons do occur, the PNO takes acon accordingly.
• Spearheading HSR rulemaking: In June 2023, the FTC and DOJ proposed changes to the premerger no-
caon form and instrucons, as well as the premerger nocaon rules implemenng the HSR Act. The
proposed changes to the HSR Form and instrucons would enable the Agencies to more eecvely and
eciently screen transacons for potenal compeon issues within the inial waing period, which is
typically 30 days.
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• Providing Inial HSR Review: To idenfy potenally ancompeve transacons, the PNO prepares a
summary descripon and a preliminary antrust analysis of reported transacons. These summaries
are then reviewed by the Bureau of Compeon’s ligaon divisions, the Bureau of Economics, and the
Merger Screening Commiee, which includes parcipants from both Bureaus and convenes regularly to
consider which maers require further acon.
• Coordinang with the Antrust Division of the Department of Jusce: The PNO administers the HSR
Program for the FTC and the Antrust Division of the Department of Jusce (the Antrust Division), which
share authority to challenge ancompeve mergers. The PNO shares transacon informaon and works
with the Antrust Division to ensure that the two agencies consistently and uniformly apply Premerger
Nocaon Rules.
• Modernizing E-Filing System: In FY 2020, due to the COVID-19 pandemic, the Premerger Nocaon
Oce suspended all hard-copy and DVD ling submission and implemented a temporary e-ling system
for use by the FTC and DOJ to accept HSR lings. Electronic ling improves processing me, minimizes
data entry, and reduces costs for both the enforcement agencies and ling pares. This temporary e-ling
system will remain in use while the PNO works to develop a permanent, cloud-based e-ling soluon.
Merger and Joint Venture Enforcement
The Merger and Joint Venture Enforcement Program seeks to prevent these eects in any market in which
the FTC has reason to believe a merger may substanally lessen compeon, parcularly in sectors of the
economy that are important to consumers such as technology, health care (including pharmaceucals), energy,
and retail goods and services.
The FTC uses a three-ered approach to merger enforcement:
• Idenfy Potenally Ancompeve Mergers: As described above, a Merger Screening Commiee—a
commiee that includes parcipants from both the Bureaus of Compeon and Economics—convenes
regularly to consider which maers require further acon.
• Prevent Ancompeve Mergers: The most eecve and cost-ecient strategy for protecng consumers
from acquisions that may substanally lessen compeon is to prevent the harm from occurring. The
FTC exercises authority under Secon 13(b) of the Federal Trade Commission Act to enjoin ancompeve
mergers pending an adjudicave proceeding. Likewise, when the Commission idenes likely ancompe-
ve consummated mergers, it iniates an administrave proceeding to adjudicate the alleged law violaon
and restore compeon. It also brings cases in federal court to secure permanent injuncve relief.
• Educate Public About Ancompeve Transacons: To enhance the FTC’s ability to deter future ancom-
peve mergers and acquisions, the agency strives to increase public awareness of the benets of com-
peon and the factors the FTC considers as it determines whether to take legal acon. To this end, the
Commission promotes transparency by releasing guidelines and policy statements, and making public facts
underlying enforcement acons to provide companies with key informaon to evaluate whether similar
transacons may also violate the law. In specic maers, the agency may also issue public statements,
including analyses to aid public comment, complaints, and closing statements, to explain the disposion of
the case.
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Merger and Joint Venture Compliance
The Merger and Joint Venture Compliance program designs and implements Commission merger consent
orders and monitors compliance with order provisions. Sta also monitors and takes acon to address viola-
ons of HSR ling requirements.
• Implementaon of Agreements and Orders: Merger Compliance sta works with enforcement sta, the
merging pares, and buyers to monitor the faithful and mely implementaon of merger order provisions
and ensure that they are sucient to retain or restore compeon in the relevant markets.
• Monitor Compliance: Merger Compliance closely monitors compliance with order provisions and, where
necessary, recommend that fallback order provisions be invoked, such as trustee-managed divesture or
the divesture of larger asset packages. Where violaons of order provisions occur, sta may recommend
civil penalty acons. Civil penalty acons entail invesgaon and, where necessary, federal court ligaon.
In addion to structural remedies, sta also monitor compliance with behavioral order provisions such as
bans on the disseminaon of compevely sensive informaon or requirements to seek approval for, or
give noce before, compleng specied future mergers or acquisions.
• Review Peons to Modify Orders: From me to me, pares under order submit peons seeking modi-
caon or terminaon of all or part of their orders, oen due to new market dynamics or other changes
in circumstances. The FTC’s Merger Compliance sta reviews these peons to assess their impact on
compeon and makes recommendaons for Commission acon accordingly.
• HSR Act Compliance: Merger Compliance also invesgates and takes acon where rms have failed to
meet their ling obligaons under the HSR Act. In instances where a violaon has occurred, sta may
recommend civil penalty acon, which must be led in federal court.
Nonmerger Enforcement
Antrust enforcement supports free and open markets by prevenng business pracces that undermine fair
compeon.
The FTC challenges a wide variety of unfair methods of compeon pracces generally fall into three broad
categories: horizontal restraints, vercal restraints, and unilateral conduct. Idenfying and proving these types
of violaons requires legal and economic analysis and thorough invesgaon.
• Horizontal Restraints: The horizontal restraints component of nonmerger enforcement looks at ancom-
peve agreements, both tacit and explicit, between competors. Horizontal restraints, such as price-x-
ing, bid-rigging, market allocaon, or invitaon to collude can violate the law. The mission of this program
is to deter, detect, invesgate, and remedy ancompeve collusion or its facilitaon.
• Vercal Restraints: Restraints on the distribuon of goods or services to customers can facilitate horizontal
collusion or restrict channels of distribuon in ways that allow a rms to exclude new competors. Under
certain circumstances, potenally unlawful vercal restraints may include agreements restricng prices or
other terms of resale, price discriminaon, kickbacks, or agreements restricng the sale or purchase and
distribuon of goods from rms other than the pares to the agreement.
• Single-Firm Violaons: A rm with market power is prohibited from using ancompeve taccs to ex-
clude new competors that could challenge its power and promote fair compeon. While the possession
of market power does not violate the antrust laws, obtaining, increasing, or maintaining market power
by unfair means is unlawful. The Commission’s enforcement eorts challenging single-rm violaons aim
to prevent or remedy instances in which rms unlawfully gain or maintain market power through ancom-
peve conduct or unfair methods of compeon.
• Educate Public about Ancompeve Conduct: The FTC uses its law enforcement tools to deter an-
compeve conduct and provide clarity to market parcipants on the type of conduct that constutes
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an antrust law violaon. However, the Commission also releases guidelines and policy statements, and
makes public facts underlying enforcement acons to provide companies with the informaon needed to
evaluate the likelihood that similar conduct may also violate the law. In specic maers, the agency may
also issue public statements, including analyses to aid public comment, complaints, and closing state-
ments, to explain the disposion of the case. The agency also provides comments to federal, state, and
local government agencies, as well as amicus curiae briefs, advisory opinions, and legal and economic
analyses to help inform others about emerging issues relang to ancompeve conduct.
Nonmerger Compliance
As in its Merger Enforcement Program, the Commission obtains orders in its Nonmerger Enforcement Program
to stop harmful conduct and prevent its recurrence. Craing appropriate orders and monitoring adherence to
order terms requires close consultaon between enforcement and compliance sta. When appropriate, the
Commission may also obtain equitable monetary remedies in federal court, such as disgorgement of ill-goen
gains, in order to deprive wrongdoers from capitalizing on illegal conduct.
• Implementaon of Agreements and Orders: Nonmerger Compliance sta works with enforcement sta
to monitor the pares’ faithful and mely implementaon of order provisions and ensure that they are
sucient to deter ancompeve conduct.
• Monitor Compliance: To monitor compliance, sta reviews periodic compliance reports required by the
orders, conduct follow-up interviews with the reporng pares, monitor relevant media, maintain contacts
with the original complainants and other industry parcipants, and conduct invesgaons of suspected
order violaons as needed. Where violaons of order provisions occur, sta may recommend civil penalty
acons. Civil penalty acons entail invesgaon and, where necessary, federal court ligaon.
• Review Peons to Modify Orders: From me to me, pares under order submit peons seeking modi-
caon or terminaon of all or part of their orders, oen due to new market dynamics or other changes
in circumstances. The FTC’s Nonmerger Compliance sta reviews these peons to assess whether the
original order connues to serve the public interest and makes recommendaons for Commission acon
accordingly.
Antrust Policy Analysis
Sta conducts antrust policy analysis to provide the Commission and other policymakers with informaon to
assess and formulate compeon policy. Compeon policy analysis includes the design and compleon of
economic, industry, or other research that improves the agency’s understanding of markets and enables the
FTC to idenfy markets and circumstances in which law enforcement acons would make the greatest impact.
Among the types of acvies supported are:
• Economic and Qualitave Studies of Compeon in Markets: The FTC conducts empirical studies, en-
gages in research, and holds workshops and other public events to help the agency beer understand the
benets of compeon in dierent markets and contexts. These acvies also enable the FTC to bring
together industry, economic, and legal experts to assess compeon policy challenges in specic sectors
of the economy.
• Reports and Policy Papers: The FTC issues reports and policy papers discussing the applicaon of antrust
principles to crical markets, such as technology, health care, energy, and retail goods and services.
• Compeon Advocacy: To promote sound compeon policy and share the agency’s signicant experse
in compeon analysis, the FTC sta oen responds to invitaons to comment on the compeve eect
of proposed laws, rules, or regulaons before federal, state, or local governments, as well as self-regulato-
ry bodies.
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Other Direct Funcons
Several other funcons within the compeon mission directly support our primary law enforcement and
compeon policy work, including:
• Recruing: The Bureau of Compeon, in cooperaon with the Human Capital Management Oce, the
Equal Employment Opportunity and Workplace Inclusion Oce, and other oces in the FTC, conducts
interviews at numerous law schools and legal recruing fairs each year to idenfy and select entry-level
aorneys and legal interns. The Bureau also recruits lateral aorneys and other sta members as needs
arise.
• Employee Development and Training: Through its Employee Development and Training Program, the FTC
ensures that aorneys and support personnel receive the training necessary to do their jobs. Hallmarks of
the training program are the Bureau of Compeon Training Council’s seminar series, the summer pro-
gram for law student interns, and the Bureau of Compeon Mentoring Program. Sta also parcipates in
the FTC Agency-Wide Diversity Council.
• Invesgaon, Ligaon Support, and Electronic Filing: Invesgaon and Ligaon Support sta are re-
sponsible for processing and loading all document producons received during the course of invesgaons
and ligaon. This group develops standards for documentary producons and data submissions and uses
appropriate technological soluons to ensure Commission sta have mely access to this informaon.
• Informaon Systems Management: The Bureau of Compeon’s Informaon Systems Management sta
manages the records systems necessary to report on the work of the Promong Compeon Mission. It
also coordinates acvies with the FTC’s Oce of the Chief Informaon Ocer, including the development
of intranet resources for sta.
• Liaison with State Ocials: FTC sta and management coordinate antrust acvies and enforcement
with state Aorneys General, including training, consultaons, and joint invesgaons of potenally
ancompeve mergers and business pracces, to the extent allowed by applicable laws.
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Support
Support consists of management and support acvies within the FTC to foster and help achieve the agency’s
goals of Protecng Consumers and Promong Compeon.
Commissioners
The Commissioners are responsible for ensuring the eecve and ecient execuon of the FTC’s
Congressionally mandated mission. They formulate Commission policy, which guides and directs the sta’s
work; authorize enforcement acons; and allocate the required resources. They also monitor the FTC’s prog-
ress in accomplishing stated goals.
Oce of Policy Planning
The Oce of Policy Planning (OPP) conducts research, oen through the FTC’s Secon 6(b) authority, develops
policy recommendaons, and generates wrien comments and reports on a variety of compeon and con-
sumer protecon issues. OPP sta research and analyze emerging issues relang to compeon in a variety of
industries, including maers relang to workers, health care, and the intersecon of compeon and intel-
lectual property, in order to enrich the Commission’s experse and inform enforcement decisions involving
novel or complex legal issues. OPP sta frequently work directly with case teams on enforcement maers. OPP
advocates for robust compeon and consumer protecon policies in a variety of federal and state venues by
analyzing the compeve ramicaons of certain legislave, regulatory, and other policy approaches, making
recommendaons on how certain policy choices may enhance or impede compeon, gathering evidence to
idenfy compeve problems and evaluate how best to address emerging compeve issues, and providing
legal and economic analysis upon request. Where appropriate, OPP sta coordinates the FTC’s advocacy role
with other governmental enes.
OPP sta frequently obtains public input from businesses, consumer groups, academics, and other outside
sources through a variety of informal and formal means.
Oce of Technology
The Oce of Technology (OT) works across the FTC to support the agency’s core mission to ensure that the
agency can move swily and knowledgeably on a wide range of issues regarding technology across the agency.
OT has the following three mandates:
• Strengthen and support law enforcement invesgaons and acons: OT supports invesgaons into
business pracces and the technologies underlying them, develops appropriate invesgave techniques
and aid in the craing of eecve Civil Invesgave Demands, aids in the review and analysis of data and
documents received in invesgaons, supports the development of case theories and analysis, and aids in
the creaon of eecve remedies. Where appropriate, OT also supports ligaon teams by serving as or
helping to idenfy external expert witnesses.
• Advise and engage with FTC sta and the Commission on policy and research iniaves: OT’s technologi-
cal experse is rounely integrated into non-enforcement agency acons, including 6(b) studies, reports,
requests for informaon, research, policy statements, and policy deliverables. Technologists provide regu-
lar technical assistance for incoming Congressional bills and engage with Congressional sta via briengs in
coordinaon with the Oce of Congressional Relaons. They also provide strategic guidance on technol-
ogy maers through report recommendaons and parcipate in engagement with regulatory counterparts
in partnership with the Oce of Internaonal Aairs.
• Engage the public and relevant experts to understand trends and to advance the Commission’s work:
OT is uniquely suited to proacvely engage with external stakeholders to idenfy emerging technolo-
gies that impact the Commission’s consumer protecon and compeon mandates. Using these nd-
ings, OT advances the Commission’s work through formal workshops, research conferences, briengs,
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and consultaons. OT can also draw on the combined authority of its experse and the stature of the
Commission to engage the public and relevant experts to highlight key trends and encourage best
pracces.
Oce of General Counsel
The General Counsel is the Commission’s chief legal ocer and adviser. The Oce’s major funcons are repre-
senng the Commission in court regarding certain maers and providing legal counsel and policy advice to the
Commission, the operang Bureaus, and other Oces.
• Ligaon: In its ligang capacity, the Oce of General Counsel (OGC) provides fundamental support to
both missions of the agency. OGC defends acons seeking judicial review of Commission orders and trade
regulaon rules, handles both oensive and defensive appeals of Commission acons seeking preliminary
and permanent injuncve relief, prepares pleadings in appellate maers in which the agency is appear-
ing as an amicus, defends the agency in lawsuits and counterclaims brought in district court (including
Freedom of Informaon Act ligaon), works with the Department of Jusce (“DOJ”) Antrust Division
on joint maers, and works with the Oce of the Solicitor General on cases in which the agency has an
interest.
OGC also counsels sta on the conduct of law enforcement invesgaons, enforces civil invesgave
demands and other compulsory processes, advises sta on issues relang to the discovery of electroni-
cally stored informaon, and frequently assists sta in responding to discovery requests directed to the
FTC or its sta. It assists DOJ in defending cases brought to enjoin or otherwise challenge agency acon,
or to obtain monetary damages against the FTC or its personnel. OGC also furnishes advice and assistance
concerning other ligaon acvies.
• Legal Counsel: In its counseling capacity, OGC provides condenal legal guidance to the Commission on a
wide range of procedural and substanve issues in adjudicave maers, working to ensure that the agen-
cy’s adjudicatory process is ecient and fair. It also advises the Commission and sta on legal and policy
issues, such as agency jurisdicon, statutory authority, administrave procedure, professional responsibil-
ity, and other maers relang directly to the agency’s enforcement goals.
OGC handles a number of maers related to condenality and access to informaon. OGC administers
the agency’s Freedom of Informaon Act (“FOIA”) program, advises on sharing and protecng condenal
informaon submied to the Commission, and administers requests by state, federal, and internaonal
law enforcement agencies for access to non-public documents. OGC assists with briengs of Congressional
commiees and subcommiees, assists in preparing tesmony for Congressional hearings, analyzes
proposed legislaon aecng the agency, and responds to Congressional requests for agency documents.
• Federal Ethics: OGC counsels Commissioners and sta to ensure compliance with the Ethics in
Government Act. Its work protects the agency by helping Commissioners and sta avoid conicts of
interest, determining whether former employees may appear in Commission proceedings, and providing
reports to the Oce of Government Ethics.
• FOIA: The FOIA Unit is comprised of aorneys and Government Informaon Specialists. Oen described
as the law that keeps cizens “in the know” about government acvity, FOIA provides every individual
with the right to access informaon related to the internal workings of the FTC, including access to con-
sumer complaints, invesgave records, and congressional correspondence. Aorneys and Government
Informaon Specialists at the FTC process over a thousand FOIA requests per year and ensure compliance
with FOIA, the Privacy Act, and the Commission Rules of Pracce.
• Opinion and Analysis: OGC assists the Commission in draing opinions and provides all necessary support
for the Commission’s adjudicatory funcons. Sta provides the Commission with an analysis of complex
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131
legal issues and contributes advice and draing assistance on cung-edge topics related to the FTC’s
adjudicatory responsibilies.
• Employment, Labor, and Appropriaons: OGC advises agency sta on personnel, labor-management
relaons, equal employment opportunity, procurement law, and appropriaons law maers. OGC repre-
sents the FTC in legal proceedings before such agencies as the Merit Systems Protecon Board, the Federal
Labor Relaons Authority, the Equal Employment Opportunity Commission, and the General Services
Board of Contract Appeals.
Oce of Internaonal Aairs
The Oce of Internaonal Aairs (OIA) is responsible for the internaonal aspects of the FTC’s mission of pro-
mong compeon and protecng consumers. Addressing internaonal issues is especially crical as markets
have become more global and the number of antrust, consumer protecon, and privacy laws and agencies
connue to grow.
OIA’s work comprises three areas: supporng the FTC’s consumer protecon and compeon case teams with
respect to internaonal issues in invesgaons and cases; building mechanisms for internaonal enforcement
cooperaon; and working with other naons and internaonal organizaons to promote sound compeon
and consumer protecon policies.
• Compeon: OIA assists the FTC’s compeon mission through advice to case teams on internaonal
issues such as access to foreign witnesses and evidence and through its work in various bilateral and
mullateral fora.
• Bilateral Relaonships: Eecve cooperaon with counterpart agencies is a necessity given that many
FTC cases involve pares based outside the United States, evidence located abroad, or maers under
parallel review by foreign compeon agencies. Pursuant to formal cooperaon agreements and a
network of informal arrangements and relaonships, OIA works with FTC sta and foreign agencies
to promote greater internaonal alignment among agencies on fair procedures, sound analysis, and
enforcement.
• Acvies in Mullateral Compeon Fora: The FTC plays a central role in key mullateral fora dedi-
cated to promong eecve compeon policy and compeon law enforcement cooperaon. In the
Internaonal Compeon Network (ICN), the FTC is a key member of the organizaon’s Steering Group
and launched and co-leads the ICN’s project on the interface between compeon, data privacy, and
consumer protecon enforcement and policies. In the ICN, the FTC works to foster the exchange of
learning on policy issues of common concern, and develop sound approaches in the areas of digital
markets, unilateral conduct, mergers, cooperaon, compeon advocacy, and agency eecveness
and helps to set the ICN’s long-term agenda. The FTC is also acve in the Compeon Commiee of
the Organizaon for Economic Cooperaon and Development (OECD), the United Naons Conference
on Trade and Development (UNCTAD), and regional organizaons such as the Asia-Pacic Economic
Cooperaon (APEC). In all these fora, the FTC shares U.S. experience and works with sister agencies to
build consensus on eecve antrust policy. For example, the FTC is playing a key role in developing
the ICN and OECD Compeon Commiee’s work on internaonal enforcement cooperaon.
• Working Within the U.S. Government: The FTC works with U.S. government agencies and in intergov-
ernmental fora to address compeon-related issues that implicate broader U.S. policy interests.
• Consumer Protecon: OIA helps the FTC accomplish its consumer protecon and privacy goals by sup-
porng the FTC’s invesgaons and cases with internaonal aspects, building internaonal enforcement
cooperaon mechanisms, and fostering the development of sound policies that address the rapid changes
in technology and business models arising in the global marketplace. These acvies include:
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• Invesgave and Ligaon Advice and Assistance: OIA supports case teams from BCP and OGC when
internaonal issues arise in FTC invesgaons and cases. OIA’s work spans the range of enforcement-
related acvies including advising on jurisdicon and service of process, obtaining evidence located
abroad, and working with case teams and foreign aorneys to idenfy and secure foreign assets for
consumer redress.
• Internaonal Enforcement Cooperaon: In 2006, Congress gave the FTC powers to combat cross-
border consumer fraud more eecvely through the U.S. SAFE WEB Act, which provides the FTC with
informaon sharing, invesgave assistance, and cross-border enforcement authority. The FTC has
used this authority, along with exisng mechanisms, to pursue cross-border wrongdoers. Congress
has reauthorized the Act in 2012 and again in 2020, The FTC connues to use the Act’s tools, and will
pursue making those tools a permanent part of the FTC’s authority.
The FTC also works closely with a range of foreign consumer protecon, privacy, telecommunicaons
and criminal enforcement authories on adversing, telemarkeng, internet fraud, and privacy and
data security invesgaons and cases. The FTC is a leader in the Internaonal Consumer Protecon
and Enforcement Network (ICPEN), a global network of more than 65 consumer protecon authories
that aims to protect consumers from fraudulent, decepve, and unfair commercial pracces around
the world by encouraging global cooperaon among law enforcement agencies. The FTC also man-
ages econsumer.gov, ICPEN’s online cross-border complaint site, now available in nine languages. The
agency also serves on the governing commiee of the Global Privacy Enforcement Network (GPEN),
a network of nearly 70 privacy enforcement authories from 50 jurisdicons. It also parcipates ac-
vely in the Global Anfraud Enforcement Network (GAEN), which brings together civil and criminal
law enforcers, and the Unsolicited Communicaons Enforcement Network (UCE-NET), which includes
consumer protecon, telecommunicaons, and data protecon authories charged with enforcing laws
against spam, robocalls, and other unwanted communicaons. The agency works closely with regional
consumer protecon networks in Asia, Africa, and Lan America. The agency also has entered into
several memoranda of understanding on enforcement cooperaon with foreign consumer protecon
and privacy counterparts.
• Promong Sound Consumer Protecon Policies: OIA advocates for vigorous enforcement of the
key rules that protect consumers through its policy work in internaonal organizaons such as the
Organisaon for Economic Cooperaon and Development (OECD) and the United Naons Conference
on Trade and Development (UNCTAD). Complemenng this work, the FTC this year reinvigorated its
informal dialogue on key consumer issues with the European Commission. The FTC also works closely,
in collaboraon with the Department of Commerce, on mechanisms that protect consumer privacy and
facilitate cross-border data ows, such as the Asia-Pacic Economic Cooperaon (APEC) Cross Border
Privacy Rules system.
• Internaonal Training Assistance:
• Cross-Cung Technical Assistance: The FTC provides technical assistance to developing compe-
on, consumer protecon, and data privacy regimes in order to support the FTC’s enforcement and
policy objecves and broader U.S. goals. It also shares sta invesgave and analycal experse and
experience with colleagues in more advanced jurisdicons as they address more complex issues. Our
program supports improved cross-border enforcement and policy development and ulmately benets
American consumers and businesses.
• Internaonal Sta Exchanges: Following a hiatus brought on by the pandemic, the FTC will recom-
mence its Internaonal Fellows and Interns program, which has enabled foreign compeon, consum-
er protecon, and privacy agency sta to work alongside their FTC counterparts, and its sta exchange
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions
133
program. These programs implement the U.S. SAFE WEB Act’s authorizaon of exchanges with
foreign antrust and consumer protecon agencies. Over the past fourteen years, the FTC has hosted
131 Internaonal Fellows and Interns from 41 jurisdicons, including Argenna, Australia, Austria,
Barbados, Brazil, Canada, Chile, China, Colombia, Ecuador, Egypt, El Salvador, the European Union,
France, the Gambia, Honduras, Hungary, India, Israel, Japan, Kazakhstan, Kenya, Lithuania, Maurius,
Mexico, Nigeria, Pakistan, Peru, Philippines, Poland, Saudi Arabia, Singapore, South Africa, South Korea,
Switzerland, Tanzania, Turkey, Ukraine, the United Kingdom, Vietnam, and Zambia. In addion, FTC
sta have parcipated in outbound exchanges with the compeon agencies of Canada, the European
Union, Mexico, and the United Kingdom.
Oce of the Secretary
The Oce of the Secretary supports the Commission by implemenng, processing, and advising the
Commission and its sta on Commission vong and other decision-making procedures.
The Oce creates ocial records of all Commission deliberaons and acons taken. The Oce also re-
views, and the Secretary signs or otherwise validates, all ocial documents approved or authorized by the
Commission. In addion, the Oce forwards all Commission Noces to the Federal Register, aer signature
by the Secretary or the General Counsel, and manages the contract covering Federal Register publicaon
expenditures.
The Oce also maintains the agency Operang Manual and prepares and forwards responses to most
Congressional and White House correspondence raising constuent issues. In addion, the Oce creates
and preserves electronic copies of all relevant acons and documents in the Commission’s internal document
management system. The Secretary is also the legal custodian of Commission legal and public records, and is
responsible for publishing the FTC Decisions Volumes, including more than 150 volumes covering the period
from 1914 to 2018, which have recently been placed on the Commission website at www.ftc.gov.
Oce of Administrave Law Judges
The Oce of Administrave Law Judges performs the inial adjudicave fact-nding in Commission adminis-
trave complaint proceedings, guided by statutes, precedent, and rules of pracce. The Administrave Law
Judge holds pre-hearing conferences, resolves discovery, evidenary, and procedural disputes, and conducts
full adversarial evidenary hearings. The judge’s Inial Decision sets out relevant and material ndings of fact
with record citaon, explains the legal standard, and applies the law to the facts.
The Oce of Administrave Law Judges is also charged with conducng certain rulemaking proceedings for the
Commission. Aer a hearing on the record, the judge conducng the proceeding recommends a decision to
the Commission based on ndings of fact and conclusions of law.
Oce of the Execuve Director
The Oce of the Execuve Director serves as the managerial and administrave arm of the Federal Trade
Commission, with responsibility for the overall operaon of the agency. The Oce of the Execuve Director
works closely with the Bureaus on strategic planning and assessing the management and resource implicaons
of any proposed acon. The following Oces are located in the Oce of the Execuve Director:
• Financial Management Oce: The Financial Management Oce (FMO) is responsible for overseeing
the FTC’s budget formulaon and execuon processes, all procurement acvies, payment of invoices,
development and maintenance of nancial policies, ongoing assessment and monitoring of internal
controls, implemenng and maintaining nancial systems, accounng and reporng of nancial transac-
ons, and oversight of the FTC’s travel management, strategic planning, enterprise risk management, and
performance management acvies. FMO sta collaborate with Congress, the Oce of Management and
Budget (OMB), the Department of the Treasury, and other federal agencies to accomplish government-
wide goals.
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions134
Key FMO acvies include:
• Advising senior management on budget development, juscaon, execuon, and review; working
with OMB and Congressional sta to obtain appropriaons and subsequent apporonment authority;
distribung enacted and Commission-approved resources to agency organizaons and projects; and
tracking agency resources.
• Conducng nancial oversight and analysis to support the recording of nancial transacons in the
accounng system; paying invoices for purchases and services performed for the FTC; reconciling the
agency’s general ledger; reporng assets managed by the FTC, including accounts receivable from court
orders, judgments, and receiverships; and reconciling balances with those maintained by Treasury and
OMB.
• Reporng the agency’s nancial informaon to Treasury; preparing the consolidated nancial state-
ments; and producing the annual Agency Financial Report.
• Managing the FTC’s acquision acvies of goods and services on behalf of the Bureaus and Oces;
providing guidance and assistance with all aspects of the requision process, including statements of
work, requests for proposal, contract preparaon, award, and administraon; and training the agency’s
Contracng Ocer Representaves.
• Managing the FTC’s enterprise risk management and internal control program by connuously idenfy-
ing and documenng risk related to achieving the agency’s strategic goals and assessing the adequacy
of nancial and operaonal internal controls, idenfying needed improvements, taking corresponding
correcve acons, and reporng annually on the condion of the agency’s internal controls.
• Managing the FTC’s Oracle-based nancial system through an integrated nancial system that includes
accounng, travel management, and acquision lifecycle systems.
• Issuing the FTC’s nancial policies to implement laws and high-level government-wide requirements
and policies (e.g., OMB Bullens and Circulars).
• Managing and administering the federal purchase and travel card programs.
• Managing all components of the agency’s E-Travel system; supporng the Bureaus and Oces with all
travel requirements, including planning, funding, booking, tracking, and approving travel; and ensuring
compliance with the Federal Travel Regulaons.
• The Chief Financial Ocer serves as the agency’s Performance Improvement Ocer, responsible for
oversight of all performance management acvies, including development of the FTC’s Strategic Plan,
tracking of the agency’s performance metrics, and producing the FTC’s Annual Performance Plan/
Annual Performance Report.
• Human Capital Management Oce: The Human Capital Management Oce (HCMO) develops and imple-
ments human capital programs and policies to align with and support the FTC’s human capital strategic
objecves. HCMO provides direcon, technical advice, and policy guidance to FTC Bureaus, Oces, and
leadership on a broad range of talent management and workforce issues, including workforce planning,
posion management and classicaon, stang and placement, background invesgaons, performance
management, workforce development, execuve resources, compensaon and leave, employee and labor
relaons, special emphasis programs, and employee benets services and programs.
HCMO consults with the FTC workforce and collaborates with other federal agencies, such as the Oce
of Personnel Management (OPM) and OMB, to develop progressive programs and soluons for emerging
human capital maers in support of government-wide human capital iniaves. HCMO supports the FTC’s
mission by:
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions
135
• Providing human capital services, strategies, and guidance to FTC Bureaus and Oces to recruit, hire,
develop, engage, retain, or transion a diverse, highly skilled, and high-performing workforce.
• Leading Training Council acvies to assess the competencies necessary and create core curriculums
for crical FTC occupaons.
• Establishing and administering policies, programs, and services related to employee and labor relaons
issues, including case support.
• Dedicang eorts to make the FTC a posive place to work through its human capital programs and
management iniaves.
• Oce of the Chief Administrave Services Ocer: The Oce of the Chief Administrave Services Ocer
(OCASO) provides a broad range of administrave and informaon management services to the agency. In
carrying out its support work, OCASO:
• Acquires and manages oce space, including infrastructure renovaons and repairs;
• Provides building and grounds management and oversees maintenance and custodial contracts;
• Manages physical security, emergency preparedness, connuity of operaons, health, and safety
programs;
• Provides logiscal support and coordinaon for all types of FTC events;
• Manages agency-wide support funcons, including mail services, prinng and copying, couriers, sup-
plies, transit subsidies, parking, and furniture warehousing;
• Provides library research, reference, and subscripon services.
• Oce of the Chief Informaon Ocer: The Oce of the Chief Informaon Ocer (OCIO) is responsible
for providing the FTC with a robust, reliable, secure, rapidly scalable, and interoperable infrastructure;
providing connecvity and compung capabilies; and allowing FTC sta and mission partners to access,
share, and act on needed informaon electronically. OCIO develops, modernizes, and enhances mission
crical IT applicaons and systems, business services, and related oce automaon tools and maintains a
robust cybersecurity program that includes the FTC’s disaster recovery and connuity of operaons ef-
forts. Some key acvies performed by OCIO include:
• Providing mission crical informaon systems and services to facilitate ligaon, forensic invesga-
ons, enforcement, and economic analysis acvies;
• Ensuring availability of informaon technology systems through maintenance of a stable, modernized
in-house technology infrastructure, including life-cycle management and technology enhancements
and provisioning of secure cloud-based services in support of eciency and improved operaons;
• Enhancing agency producvity through customer support services, including equipment installaon
and repair; training and support in the use of informaon technology resources; and support of crical
informaon systems and applicaons;
• Securing FTC data and informaon technology systems against current and emerging cybersecurity
threats using sophiscated technologies and informaon assurance acvies, providing increased
security and compliance without hindering mission success and employee performance.
• Horseracing Integrity and Safety Authority Oversight: The Oce of the Execuve Director also leads the
FTC’s oversight of the Horseracing Integrity and Safety Authority (“Authority”). The Horseracing Integrity
and Safety Act of 2020 (“HISA” or “the Act”) recognizes the Authority as a self-regulatory nonprot
organizaon charged with developing and enforcing rules relang to racetrack safety, an-doping, and
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions136
medicaon control. In December 2022, Congress amended HISA to expand the Commission’s oversight
role over the Authority. The FTC has taken several measures to build this important oversight program,
most importantly by focusing on transparency in the Authority’s operaons, rules, and budget.
Oce of Congressional Relaons
The Oce of Congressional Relaons serves as the liaison between the FTC and Congress. It works closely with
congressional commiees and members’ oces, and keeps the Commission apprised of acvity on Capitol Hill
aecng compeon, consumer protecon, and the agency. It also coordinates the preparaon of congressio-
nal tesmony and responses to congressional inquiries about FTC acons, policies, and programs.
The Oce of Congressional Relaons:
• Develops, coordinates, and executes legislave advocacy for the FTC.
• Receives and helps coordinate responses to members’ inquiries on behalf of constuents.
• Plans and implements liaison acvies with Congress, including briengs by FTC sta, meengs be-
tween members of Congress and Commissioners, and constuent educaon events.
• Monitors hearings, legislaon, and other congressional acvity aecng or of interest to the FTC.
• Coordinates the review by FTC sta of relevant legislaon and provides feedback and technical assis-
tance on bills to congressional oces.
• Prepares agency witnesses to tesfy before Congress.
• Keeps congressional sta informed of major Commission acons.
• Assists nominees for FTC Commissioner posions through the conrmaon process.
Oce of the Chief Privacy Ocer
The Oce of the Chief Privacy Ocer (OCPO) manages the FTC’s internal privacy program and is responsible
for ensuring that the Commission complies with all applicable privacy laws and guidance. OCPO idenes the
privacy risks, controls, and migang soluons when making decisions involving the collecon, use, sharing,
retenon, disclosure, and destrucon of personally idenable informaon. It is also responsible for invesgat-
ing and migang privacy incidents. OCPO accomplishes its support funcon by:
• Protecng personal informaon at the FTC throughout its life cycle, including creaon/collecon, use,
sharing, disclosure, transfer, and disposal/disposion through various means, including, but not limited
to:
o Using Privacy Threshold Analyses to conduct a privacy risk analysis for new informaon collecons;
o Publishing Privacy Impact Assessments to provide transparency regarding informaon collecons
from members of the public;
o Conducng annual connuous monitoring to ensure that privacy and security risks are evaluated
throughout the informaon life cycle; and
o Ulizing a process to ensure privacy risks are addressed when informaon systems are
decommissioned.
• Supporng the FTC mission with an evolving privacy program, including:
o Developing and implemenng a Data Breach Response Plan to respond to privacy events;
o Monitoring and analyzing quantave and qualitave performance measures on the eecveness
of exisng privacy acvies and using that informaon to make needed adjustments; and
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions
137
o Maintaining a list of the agency’s social media accounts, applicaons, and websites to ensure
compliance with federal informaon management laws and guidance.
• Promong a culture of privacy among FTC sta, contractors, and third pares by, among other things:
o Providing privacy awareness trainings for all sta, including in-person privacy training for all new
employees, contractors, and internaonal visitors;
o Providing counsel and guidance to agency ocials and sta on privacy-related issues; and
o Coordinang with agency sta to address privacy-related issues associated with informaon tech-
nology and security, legal, acquisions, budget, and program oces.
Oce of Public Aairs
The Oce of Public Aairs (OPA) informs the news media, as well as the public at large, about the acvies of
the FTC and responds to media inquiries about Commission acons and policy. OPA also manages the agency’s
main website, FTC.gov, and social media accounts, which are crical communicaon tools for the agency.
In serving as liaison between the FTC, the media, and the public, OPA:
• Arranges and frequently stas media appearances for the Chair, Commissioners, and other senior
ocials.
• Ensures that Commission news releases, supporng documents, and consumer and business educaon
materials are disseminated to the media and the public on FTC websites, through use of social media,
and other channels.
• Manages the FTC’s ocial presence on Facebook, Twier, and LinkedIn, including hosng live social
chats, live-tweeng and live-streaming workshops, and other events, and answering public quesons
using social media.
• Produces a daily “News Summary” on FTC acvies consisng of interesng/inuenal tweets, clips
from newspapers, magazines, online publicaons, and television.
• Dras and maintains all social media privacy impact assessments and produces weekly social menons
reports to sta.
• Manages the operaons and development of the FTC’s primary public website, FTC.gov, including
related vendor contracts.
• Establishes governance, standards, and administrave guidance for public-facing web properes man-
aged by oces across the agency.
• Coordinates the development and execuon of the agency’s digital communicaons strategy, including
collecon and analysis of web trac data and customer experience metrics.
• Provides training and support to FTC web content publishers and authors.
• Provides assistance to the media and bloggers covering FTC acvies.
• Promotes and supports major FTC outreach acvies and iniaves and uses new technology, as avail-
able, to advance these eorts.
• Provides Regional FTC oces with media training and outreach support as needed.
• Produces “Weekly Calendar and Sunshine Noces” reports to inform the public and the media of
scheduled “open” Commission acvies.
• Works with internaonal, naonal, and regional media for coverage of Commission acvies.
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions138
• Obtains transcripts and videotapes of broadcast coverage of Commission acvies.
• Coordinates with sta on publicaon of FTC blogs, posts, and occasional guest posts.
Oce of Inspector General
The Inspector General Act of 1978 created independent and objecve units within the federal agencies to
detect fraud, waste, and abuse and promote eciency and eecveness in agency operaons. Each OIG
is responsible for conducng audits, evaluaons, and invesgaons relang to the agency’s programs and
operaons.
The Inspector General Act Amendments of 1988 (5 U.S.C. app.) established an OIG within the FTC in 1989. The
OIG is led by an Inspector General with the funcons, powers, and dues of an agency head or appoinng
authority. The Inspector General must keep the Chair, the Commissioners, and Congress fully and currently
informed about problems and deciencies in the agency’s operaons and programs.
The Inspector General Act contains statutory guarantees of OIG independence, which ensure the objecvity
of the OIG’s work and safeguards against eorts to compromise that objecvity or hinder OIG operaons.
Foremost among these safeguards are the Inspector General’s dual reporng to the agency head and Congress,
and the requirement for agency management to provide mely access to agency personnel and informaon.
The OIG’s independent mission requires that OIG sta be free in fact and appearance from personal, external,
and organizaonal impairments to their independence. The OIG is responsible for the following acvies
within the FTC:
• Audits and Evaluaons: The OIG conducts audits and evaluaons that address the eciency, eecve-
ness, and economy of FTC programs and operaons. OIG reports provide informaon to FTC leadership
that idenfy correcve acons, facilitate program improvements, and improve accountability. Audits
and evaluaons are systemac and independent assessments that provide mely and credible informa-
on for agency managers, policy makers, and others to determine the eciency, eecveness, impact,
and sustainability of agency operaons, programs, and performance.
• Invesgaons: The OIG invesgates allegaons of criminal, civil, and administrave violaons com-
mied by FTC employees and individuals or enes that have contracts with the agency. The OIG also
invesgates crimes against the FTC, including fraudulent identy the complaints and impersonaon
scams of FTC ocials. Complaints and allegaons of wrongdoing generally reach the OIG via the OIG
Hotline—in-person, voicemail, email, and via regular mail— and come from a variety of sources, includ-
ing FTC employees, other government agencies, and the public. When results of OIG invesgaons
uncover criminal acvity or civil violaons, the OIG refers such cases to the Department of Jusce for
consideraon for criminal or civil acon. When invesgaons do not substanate criminal or civil acv-
ity, or when criminal prosecuon or civil remedies have been declined, the OIG reports those maers
to FTC management for appropriate acon.
• Whistleblower Protecon: Federal law prohibits governmental personnel from retaliang against
an employee who acts as a whistleblower by reporng suspected waste, fraud, or abuse to the OIG.
Both the OIG and the U.S. Oce of Special Counsel exercise the authority to invesgate allegaons of
whistleblower retaliaon.
• Management Advisories: The OIG issues periodic Management Advisories to inform management
expediously of ndings of systemic weaknesses or vulnerabilies idened during audits, evaluaons,
invesgaons, or other oversight acvity. Management Advisories typically contain recommendaons
for agency management.
• Top Management Challenges: The Reports Consolidaon Act of 2000 requires that the Inspector
General provide a summary of the OIG’s perspecve on the most serious management and
Fiscal Year 2025 Congressional Budget Justication - Bureau and Ofce Descriptions
139
performance challenges facing the agency—as well as a brief assessment of the agency’s progress in
addressing those challenges.
• Congressional Reports, Requests, and Briengs: In addion to keeping the Chair and Commissioners
informed of the OIG’s work, the Inspector General Act requires the OIG to keep appropriate
Congressional commiees informed of completed audit, evaluaon, and invesgaon work through
semiannual reports to the Congress. These reports summarize the work the OIG has completed and
planned during the reporng period, as well as the status of OIG recommendaons to management.
Separately, the OIG may respond to requests by Congressional commiees, inform on maers referred
to the Department of Jusce for possible prosecuon, and report any challenges encountered in
obtaining mely informaon from management.
• Peer Reviews: The OIG’s audit funcon is subject to triennial external peer reviews conducted under
requirements established by CIGIE, an independent enty within the Execuve Branch comprised of
federal Inspectors General. OIG sta take periodic training in the various OIG disciplines to ensure
that they and the OIG programs adhere to Government Accountability Oce, CIGIE, and other quality
standards for ensuring accuracy, objecvity, and independence.
Oce of Workplace Inclusivity and Opportunity
The Oce of Workplace Inclusivity and Opportunity (OWIO) ensures agency compliance with EEO laws, regula-
ons, and guidance and supports a work environment where every employee has an opportunity to thrive,
free of discriminaon and harassment.
OWIO also manages the FTC’s EEO discriminaon complaint process, including recommending selements
and taking nal acon, as well as making nal decisions on complaints that are consistent with regulaons and
direcves governing the administrave complaint process. OWIO also serves as the principal advisor on the
impact of EEO laws, regulaons, and guidance on agency programs, policies, and pracces.
Addionally, OWIO promotes an inclusive work environment for all employees by maintaining relaonships
with bar associaons and other professional organizaons providing guidance to the FTC Diversity Council
and other FTC employee groupsWith the help of interested FTC sta, OWIO plans and organizes programs and
acvies for commemorave events and special observances throughout the year.
Further, OWIO engages in proacve strategies to idenfy and eliminate barriers to EEO, provides informaon
to FTC management and sta on EEOC regulaons and direcves; implements comprehensive iniaves that
conform to Federal laws, regulaons, and guidance governing EEO; and supports a workplace that provides all
employees equal employment opportunity.
Appendix
Fiscal Year 2025 Congressional Budget Justication - Appendix
143
Proposed Appropriations Language
Salaries and Expenses
For necessary expenses of the Federal Trade Commission, including uniforms or allowances
therefor, as authorized by 5 U.S.C. 5901-5902; services as authorized by 5 U.S.C. 3109; hire of
passenger motor vehicles; and not to exceed $2,000 for ocial recepon and representaon
expenses, $535,000,000, to remain available unl expended: Provided, That not to exceed
$300,000 shall be available for use to contract with a person or persons for collecon services
in accordance with the terms of 31 U.S.C. 3718: Provided further, That, notwithstanding any
other provision of law, fees collected in scal year 2025 for premerger nocaon lings under
the Hart-Sco-Rodino Antrust Improvements Act of 1976 (15 U.S.C. 18a), (and esmated to
be $341,900,000 in scal year 2025) shall be retained and used for necessary expenses in this
appropriaon and shall remain available unl expended: Provided further, That, notwithstand-
ing any other provision of law, fees collected to implement and enforce the Telemarkeng Sales
Rule, promulgated under the Telemarkeng and Consumer Fraud and Abuse Prevenon Act
(15 U.S.C. 6101 et seq.), regardless of the year of collecon (and esmated to be $13,000,000
in scal year 2025), shall be credited to this account, and be retained and used for necessary
expenses in this appropriaon, and shall remain available unl expended: Provided further,
That the sum herein appropriated from the general fund shall be reduced (1) as such oseng
collecons are received during scal year 2025 and (2) to the extent that any remaining general
fund appropriaons can be derived from amounts credited to this account as oseng collec-
ons in previous scal years that are not otherwise appropriated, so as to result in a nal scal
years 2025 appropriaon from the general fund esmated at $180,100,000: Provided further,
That, notwithstanding secon 605 of the Departments of Commerce, Jusce, and State, the
Judiciary, and Related Agencies Appropriaons Act, 1990 (15 U.S.C. 18a note), none of the funds
credited to this account as oseng collecons in previous scal years that were unavailable for
obligaon as of September 30, 2024, shall become available for obligaon except as provided in
the preceding proviso: Provided further, That none of the funds made available to the Federal
Trade Commission may be used to implement subsecon (e)(2)(B) of secon 43 of the Federal
Deposit Insurance Act (12 U.S.C. 1831t).
Fiscal Year 2025 Congressional Budget Justication - Appendix144
Program and Financing
($ in millions)
Idencaon Code: 29-0100-0-1-376
FY 2023
Actual
FY 2024
Esmate
FY 2025
Esmate
Idencaon Code: 29-0100-0-1-376
Obligaons by Program Acvity:
0001 Protecng Consumers 215 217 262
0002 Promong Compeon 211 213 273
0192 Subtotal, direct program 426 430 535
0799 Total direct obligaons 426 430 535
0803 Reimbursable program 1 4 4
0900 Total new obligaons, unexpired accounts 427 434 539
Budgetary Resources:
Unobligated Balance:
1000 Unobligated balance brought forward, Oct 1 63 67 74
1011 Unobligated balance transfer from other acct [047-0616] --- 3 ---
1021 Recoveries of prior year unpaid obligaons 11 4 5
1070 Unobligated balance (total) 74 74 79
Budget Authority:
Appropriaons, discreonary:
1100 Appropriaon 71 113 180
1130 Appropriaons permanently reduced --- --- ---
1160 Appropriaon, discreonary (total) 71 113 180
Appropriaons, mandatory:
1200 Appropriaon --- --- ---
1230 Appropriaons permanently reduced -11 --- ---
1260 Appropriaon, mandatory (total) -11 --- ---
Spending authority from oseng collecons, discreonary:
1700 Oseng collecons (cash) - HSR 172 304 342
1700 Oseng collecons (cash) - Do Not Call 15 13 13
1700 Oseng collecons (cash) - Reimb 1 4 4
1701 Change in uncollected payments, Federal sources --- --- ---
1702 Oseng collecons (previously unavailable) 172 --- ---
1750 Spending authority from oseng collecons, discreonary (total) 360 321 359
1900 Budget authority (total) 420 434 539
1930 Total budgetary resources available 494 508 618
Memorandum (non-add) entries:
1941 Unexpired unobligated balance, end of year 67 74 79
Change in Obligated Balances:
Unpaid Obligaons:
3000 Unpaid obligaons, brought forward, Oct 1 78 96 187
3010 New obligaons, unexpired accounts 427 434 539
3020 Outlays (gross) -398 -339 -508
3040 Recoveries of prior year unpaid obligaons, unexpired -11 -4 -5
3050 Unpaid obligaons, end of year 96 187 213
Uncollected payments:
3060 Uncollected pymts, Fed sources, brought forward, Oct 1 -2 -2 -2
3070 Change in uncollected paymts, Federal sources, unexpired --- --- ---
3090 Uncollected pymts, Fed sources, end of year -2 -2 -2
Memorandum (non-add) entries:
3100 Obligated balance, start of year 76 94 185
3200 Obligated balance, end of year 94 185 211
Fiscal Year 2025 Congressional Budget Justication - Appendix
145
Idencaon Code: 29-0100-0-1-376
FY 2023
Actual
FY 2024
Esmate
FY 2025
Esmate
Budget Authority and Outlays (net):
Discreonary:
4000 Budget authority, gross 431 434 539
Outlays, gross:
4010 Outlays from new discreonary authority 339 177 251
4011 Outlays from discreonary balances 54 162 257
4020 Outlays, gross (total) 393 339 508
Osets against gross budget authority and outlays:
Oseng collecons (collected) from:
4030 Federal sources -1 -4 -4
4033 Non-Federal sources --- --- ---
4034 Oseng governmental collecons -187 -317 -355
4040 Osets against gross budget authority and outlays (total) -188 -321 -359
Addional osets against gross budget authority only:
4050 Change in uncollected pymts, Fed sources, unexpired --- --- ---
4070 Budget authority, net (discreonary) 243 113 180
4080 Outlays, net (discreonary) 205 18 149
Mandatory:
4090 Budget authority, gross -11 --- ---
Outlays, gross:
4100 Outlays from new mandatory authority --- --- ---
4101 Outlays from mandatory balances 5 --- ---
4110 Outlays, gross (total) 5 --- ---
4160 Budget authority, net (mandatory) -11 --- ---
4170 Outlays, net (mandatory) 5 --- ---
4180 Budget authority, net (total) 232 113 180
4190 Outlays, net (total) 210 18 149
Memorandum (non-add) entries:
5090 Unexpired unavailable balance, SOY: Oseng collecons 173 1 1
5092 Unexpired unavailable balance, EOY: Oseng collecons 1 1 1
Unexpended balance memorandum entries:
5311 Direct unobligated balance, start of year 61 65 ---
5312 Reimbursable unobligated balance, start of year 2 2 ---
5313 Discreonary unobligated balance, start of year 46 67 ---
5314 Mandatory unobligated balance, start of year 17 --- ---
5321 Direct unobligated balance, end of year 65 --- ---
5322 Reimbursable unobligated balance, end of year 2 --- ---
5323 Discreonary unobligated balance, end of year 67 --- ---
5324 Mandatory unobligated balance, end of year --- --- ---
5331 Direct obligated balance, start of year 78 96 ---
5332 Reimbursable obligated balance, start of year -2 -2 ---
5333 Discreonary obligated balance, start of year 74 92 ---
5334 Mandatory obligated balance, start of year 2 3 ---
5341 Direct obligated balance, end of year 96 --- ---
5342 Reimbursable obligated balance, end of year -2 --- ---
5343 Discreonary obligated balance, end of year 92 --- ---
5344 Mandatory obligated balance, end of year 3 --- ---
Fiscal Year 2025 Congressional Budget Justication - Appendix146
Object Classication
($ in millions)
Idencaon Code: 29-0100-0-1-376
FY 2023
Actual
FY 2024
Esmate
FY 2025
Esmate
Direct Obligaons
Personnel Compensaon:
11.1 Full-me permanent 179 216 246
11.3 Other than full-me permanent 8 --- ---
11.5 Other personnel compensaon 5 5 7
11.8 Special personal services payments 1 --- ---
11.9 Total, Personnel Compensaon 193 221 253
12.1 Civilian personnel benets 67 78 89
21.0 Travel and transportaon of persons 2 3 3
22.0 Transportaon of things --- --- ---
23.1 Rental payments to GSA 27 25 26
23.2 Rental payments to others 1 1 1
23.3 Communicaons, ulies, and miscellaneous charges 5 5 5
24.0 Prinng and reproducon 3 3 3
25.1 Advisory and assistance services 104 71 98
25.2 Other services from non-Federal sources 5 5 5
25.3 Other goods and services from Federal sources --- --- ---
25.4 Operaon and maintenance of facilies 2 2 2
25.7 Operaon and maintenance of equipment 15 15 16
26.0 Supplies and materials --- --- 1
31.0 Equipment 1 1 1
32.0 Land and structures 1 --- 32
42.0 Insurance claims and indemnies --- --- ---
44.0 Refunds --- --- ---
99.0 Subtotal, Direct Obligaons 426 430 535
Reimbursable Obligaons
Personnel Compensaon:
11.1 Full-me permanent 1 4 4
99.0 Subtotal, Reimbursable Obligaons 1 4 4
99.9 Total, New Obligaons 427 434 539
Fiscal Year 2025 Congressional Budget Justication - Appendix
147
Personnel Summary
Idencaon Code: 29-0100-0-1-376
FY 2023
Actual
FY 2024
Esmate
FY 2025
Esmate
Direct
1001 Full-me equivalent employment 1,217 1,388 1,443
Reimbursable
2001 Full-me equivalent employment
1
2 1 1
1
Includes 1 FTE reimbursed by other federal agencies
Fiscal Year 2025 Congressional Budget Justication - Appendix148
Inspector General’s Request
Office of Inspector General
UNITED STATES OF AMERICA
Federal Trade Commission
WASHINGTON, D.C. 20580
February 05, 2024
In accordance with the requirements of Section 6(g)(1) of the Inspector General Act of 1978
(as amended), the Federal Trade Commission's Office of the Inspector General (OIG) submits
the following information related to its requested budget for FY 2025:
• OIG requests aggregate funding of $3,067,600 for FY 2025.
• OIG requests $36,300 for all training needs. The requested amount satisfies all training
requirements for the OIG in FY 2025.
• OIG requests $12,270 for support of the Council of Inspectors General on Integrity and
Efficiency (CIGIE). The requested amount satisfies all requirements for the OIG's CIGIE
contribution in FY 2025.
FY 2024 Budget
$ in thousands
FY 2025 Estimate
$ in thousands
Change
$ in thousands
Full Time
Equivalents
Amount
Full Time
Equivalents
Amount
Full Time
Equivalents
Amount
10
$2,619.4
11
$3,067.6
1
$448.2
Andrew Katsaros
Inspector General
Federal Trade Commission
