The undersigned civil rights, consumer rights, faith-based, criminal justice, and reentry organizations respectfully submitted the following comments in response to the Federal Trade Commission’s (FTC) Advance Notice of Proposed Rulemaking (“ANPR”) regarding unfair or deceptive fees, R207011.1
These comments discuss junk fees affecting justice-involved people. The organizations urge the Commission to identify and confront the unfair and deceptive fees that are all too common in the correctional services sector of the economy, and to keep the needs of this often-overlooked population in mind when analyzing the information collected as part of this proceeding.
Comments were devoted to junk fees imposed in the following private correctional services contexts because they represent some of the most egregious and widespread examples of these fees: (1) money-transfer services; (2) release cards; and (3) various technology services increasingly prevalent in correctional institutions—including technologies incarcerated people use to communicate with their loved ones.
Fees associated with several other services in this sector are briefly discussed—namely, commercial bail, post-arrest/pretrial diversion programs, private probation, and electronic monitoring—which the groups recommend the FTC further investigate.
Finally, the comments explain how oligopolistic dynamics characterize the corrections market more broadly, which further fosters junk fees.