The U.S. Chamber of Commerce (the “Chamber”) respectfully petitions the Federal Trade Commission (“FTC”), pursuant to the Federal Trade Commission Act (“FTC Act”), 15 U.S.C. §45, and 16 C.F.R. §1.9, to initiate a rulemaking to revise the rule regarding disqualification of Commissioners (16 C.F.R. §4.17). Under the request, the current rule regarding disqualification of Commissioners would be amended (1) to formalize legal consultation with ethics experts in the FTC’s Office of General Counsel and (2) to enhance transparency and improve actual and perceived integrity of agency adjudications by requiring Commissioners, including the Commissioner whose disqualification is sought, to provide the public with a written statement outlining the reasons for declining any recusal decisions. The proposal also recommends that the written statement of the Commissioner subject to the recusal petition become part of the record for the Commissio

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