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Recent Projects

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  • Comments to FTC on Proposed Rule on Unfair or Deceptive Fees

    In 2021, Policy Integrity submitted a petition for rulemaking to the Federal Trade Commission (FTC) calling for a ban on the use of drip pricing. After granting the petition, the FTC in 2023 proposed a Trade Regulation Rule on Unfair or Deceptive Fees (Proposed Rule). The Institute for Policy Integrity submitted comments with suggested edits and additions to the regulatory text to ensure that the Proposed Rule fully codifies FTC's stated objectives. Our comments also suggest several actions to strengthen FTC's breakeven and cost-benefit analyses. 

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  • Policy Integrity Work Shapes FTC Ban on Hidden Fees

    In October 2023, the Federal Trade Commission (FTC) released a proposed rule that bans the use of “junk fees” in transactions including hotel reservations, vehicle rentals, and event ticket purchases. The proposed rule references Policy Integrity and our work more than a dozen times, including both our 2021 petition for rulemaking and our 2023 comment letter supporting the FTC’s authority to issue this regulation.

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  • Comments to FTC on Unfair or Deceptive Fees Trade Regulation

    On October 20 2022, the FTC voted to grant the Institute for Policy Integrity’s petition for rulemaking and issue an Advanced Notice of Proposed Rulemaking on Unfair or Deceptive Fees Trade Regulation Rule. Commissioner Christine S. Wilson issued a dissenting statement in which she raised major questions doctrine concerns and asked for precedent that supports FTC's authority to promulgate this rule. We submitted a letter responding to Commissioner Wilson’s concern and providing regulatory antecedents supporting the FTC’s authority. In this letter, Policy Integrity shows that FTC's rule would not be unheralded nor represent a transformative change in the agency's authority, and therefore, it would not implicate the major questions doctrine.

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  • Comments to FTC on Commercial Surveillance and Data Security

    In August, the Federal Trade Commission released an advance notice of proposed rulemaking seeking comment on avenues to regulate commercial surveillance and data security practices that harm consumers. Policy Integrity submitted comments recommending that the FTC regulate “immortal accounts,” a practice by which entities make it difficult or impossible to delete a consumer account in order to retain and profit from the user’s data and continue charging subscriptions. Our comments were based on a report that we recently published establishing the Commission’s authority to regulate this pervasive practice.

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  • Petition for Rulemaking for the Federal Trade Commission to Ban Drip Pricing

    Drip pricing is a strategy used by some sellers to lure in consumers by advertising deceptively low prices, only to reveal hidden mandatory fees after the consumer is on the verge of completing a transaction. We submitted a petition to the Federal Trade Commission formally calling for a new rule banning the use of drip pricing.

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  • Public comments on Green Labels

    Lately, labels on eco-friendly products have proliferated. It seems like almost everything is marked as “green,” “compostable,” “free of” something, or made with renewable materials. But who makes sure all these items are as gentle on the environment as they say they are?

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