The main body is a comment from 52 national and state consumer advocacy groups in response to the FTC’s proposed rule to address unfair and deceptive practices relating to fees, i.e. to regulate junk fees. The proposed rule would ensure that sellers disclose all mandatory fees up front, facilitating easier price comparison for consumers, and prohibit bait-and-switch pricing tactics. Furthermore, businesses will not be able to misrepresent fees or be vague about their purpose. The FTC’s proposed rule would create a fair marketplace for honest businesses and consumers.
The comments support the FTC’s proposed rule and urges the Commission to strengthen several provisions in the proposed rule to prevent companies from using alternative deceptive pricing tactics to get around the rule. In particular, the coalition supports stronger rules around price disclosures for optional fees, prohibiting default selection for optional purchases, and using the well-established “reasonable consumer standard” to enforce the rule: if a reasonable consumer would expect something to be included in the purchase, it should be.
Appendix A is a listing of the coalition’s suggested edits
Appendix B is a collection of over 1000 consumer stories on junk fees collected by Consumer Reports