FR 2021-00214

The Federal Trade Commission (FTC) is proposing to extend its current authorization for information collection concerning its administrative activities by another three years. This proposal aligns with the requirements of the Paperwork Reduction Act of 1995. The document invites public comment on this extension and highlights the necessity to collect information for a range of FTC undertakings, such as managing consumer reporting systems and evaluating program efficacy. Stakeholders are encouraged to submit their feedback by March 12, 2021, with a preference for online submissions due to possible delays in physical mail handling.

Significance and Key Issues

While the document aims to streamline the administrative processes of the FTC, it presents several key issues that warrant further discussion. First, there is a lack of clarity regarding the specific information intended to be collected from respondents. This ambiguity might lead to confusion or reluctance among stakeholders who are uncertain about what will be required of them.

Additionally, the estimated labor costs related to the FTC's evaluation activities appear unevenly justified. The calculation of high annual labor costs, particularly involving state and federal agency employees, lacks detailed rationale, making it unclear why such significant resources are projected necessary. Similarly, the assumption of executives and attorneys commanding $145/hour requires further explanation to substantiate this cost estimate. This assumption could lead to inflated projections, impacting the perceived financial burden of these activities.

The reporting activities as described seem relatively straightforward and voluntary; however, the projected annual burden hours for consumers stand at an unexpectedly high 452,131 hours. This projection invites scrutiny as it appears inconsistent with the stated simplicity of the process.

Public Impact and Stakeholder Implications

For the general public, this document presents an opportunity to engage with the regulatory processes of the FTC. Public involvement may lead to enhancements in the clarity and utility of information collection practices, ultimately benefiting consumers and fostering transparency. However, without clear communication regarding what information will be gathered and how it will be used, individuals may be hesitant to participate or voice concerns.

Specific stakeholders, such as businesses, former FTC employees seeking ethical clearance, and FTC staff, could be impacted in various ways. Businesses might experience an increased administrative workload and expenses associated with compliance, especially if engagement with FTC processes requires substantial time or resources. Former FTC employees may be concerned about how the ethical clearance process is managed and any potential delays it could impose on their professional transitions.

Moreover, the document could benefit from an enhanced focus on privacy safeguards, particularly since it mentions collecting consumer reports regarding potentially sensitive issues like identity theft. Addressing these concerns comprehensively could improve public trust and ensure that appropriate data protection measures are in place.

With these considerations in mind, stakeholders need to weigh in on the proposed extension of FTC's information collection, advocating for clarity, accountability, and consumer protection in the processes outlined. This feedback may have substantial implications for shaping the FTC's practices in a way that balances administrative needs with a commitment to minimizing the burden on respondents.

The Federal Trade Commission (FTC) document outlines various financial references relating to their administrative activities and information collection requirements. These financial estimates are essential to understand the costs associated with the activities the FTC undertakes.

Estimated Annual Labor Costs

The document provides several estimates for annual labor costs related to different aspects of the FTC's responsibilities:

• The "Estimated Annual Labor Costs" is stated as $26,890. However, the document does not offer detailed justification for this amount in the context of the activities discussed, which may leave the audience seeking further clarity on what specific activities lead to this estimated cost.

• For responding to requests for advice from outside parties, the estimated labor cost is based on an average wage of $145/hour for executives and attorneys. The total annual cost burden in this regard is calculated as $15,950. This estimate is based on 110 burden hours. The rationale behind the $145/hour wage rate is not comprehensively explained, which might suggest a degree of inflation in labor cost projections.

• The FTC also mentions that for survey participants, which primarily include staff from state and federal agencies, the labor cost is estimated at $100/hour. This estimation reflects the expected expenditure per response, which totals to $25 in labor cost for each 15-minute survey. Over the year, this results in cumulative labor costs of approximately $500. However, the document does not provide detailed justification for why the annual costs and labor estimates are structured this way, particularly for staff participating in survey activities.

• Additional labor costs are anticipated concerning compliance interviews after merger divestitures. Here, the document estimates a total annual labor cost of $10,440, based on an average wage of $145/hour. These costs relate to the time executives and attorneys spend preparing for and participating in interviews regarding divested assets.

Associated Burden Hours

The financial allocations also connect to the estimated burden hours for the activities:

• The FTC expects to receive 55 requests annually for ethical clearance involving a total of 110 burden hours per year. Yet, the document doesn't provide detailed analysis for these burden hours and how they contribute to the estimated labor costs.

• For consumer reporting activities like fraud or identity theft violations, the FTC estimates that it will gather information from approximately 7,750,841 respondents, leading to a total burden of 452,131 hours per year. The process is said to be simple and voluntary, raising questions about why these burden hours appear significantly high.

General Observations

The document contains dense language and provides figures without detailed explanations or breakdowns, particularly concerning wage estimates and total labor costs. This might hinder comprehensive understanding for a general audience and raise questions about potential inaccuracies in cost predictions. Additionally, privacy concerns and data protection measures, especially around sensitive information, appear underexplored, as such protection could pose additional unexplained costs or requirements for ensuring confidentiality.