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FTC clarifies expectations for post-settlement compliance reports

Joe Mont | March 21, 2019

The Federal Trade Commission is laying down the law when it comes to post-settlement compliance reports.

Commission orders—both from negotiated settlements and from litigated matters—routinely require respondents to submit periodic reports on their efforts to comply with the order. “Recent experience, however, has revealed that some Respondents are not taking seriously their obligation to provide detailed and timely reports,” warned Roberta Baruch and Bruce Hoffman, of the FTC’s Bureau of Competition, in a recent blog post on the agency’s site. “This has prompted us to revisit and revise standard order language to make clear what constitutes a complete compliance report.”

“Ensuring compliance with...

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