To Whom it May Concern:The U.S. Chamber of Commerce (“Chamber”) appreciates the opportunity to comment to the Federal Trade Commission (“FTC” or “Commission”) regarding its proposed “Rule on Unfair or Deceptive Fees” (“Proposed Rule” or “NPRM”). The NPRM proposes imposing an economy-wide rule to regulate and prohibit so-called “hidden fees” and “misrepresented fees.” The Chamber supports transparency in pricing. Businesses cannot be allowed to misrepresent the total cost of a product or service, or to charge consumers for products or services they did not agree to purchase. Consumers should understand what they are purchasing, and the costs associated with the purchase. However, the Proposed Rule lacks clarity regarding its application, and as written, would be technically impossible for some industries to implement, and has the potential to chill legitimate pricing practices in an attempt to cure consumer frustrations with fees.Several factors underlie the Chamber’s assessment that
