Strategic Plan for Fiscal years 2009 to 2014Federal Trade CommissionFTC_c86ff34b-c8f9-4e38-b66a-d31eec3022feThe FTC is headed by a Commission composed of five members who are nominated by the President and confirmed by the Senate, and who serve staggered seven-year terms. The President chooses one Commissioner to act as Chairman. No more than three Commissioners can be of the same political party. As of May 2009, the Chairman is Jon Leibowitz. The other Commissioners are Pamela Jones Harbour, William E. Kovacic, and J. Thomas Rosch. One Commissioner seat is vacant. The FTC has two major law enforcement bureaus, Consumer Protection and Competition, supported by the Bureau of Economics, regional offices, and mission support offices. The agency enforces laws that prohibit business practices that are anticompetitive, deceptive, or unfair. It also promotes informed consumer choice and public understanding of the competitive process. The work of the FTC helps protect consumers and preserve competition in the United States and, increasingly, the world.Jon LeibowitzChairmanPamela Jones HarbourCommissioner William E. KovacicCommissioner J. Thomas RoschCommissionerBureau of CompetitionThe Commission gratefully recognizes the significant contributions of the following individuals in the preparation of this plan: Marian Bruno, Jeanine Balbach, Holly Frost, Nathan Hawthorne, Stefano SciolliBureau of Consumer ProtectionThe Commission gratefully recognizes the significant contributions of the following individuals in the preparation of this plan: Eileen Harrington, Daniel Kaufman, Jonathan Soileau, Beth WigginsBureau of EconomicsThe Commission gratefully recognizes the significant contributions of the following individuals in the preparation of this plan: Pauline Ippolito, Liz CallisonOffice of the Executive Director The Commission gratefully recognizes the significant contributions of the following individuals in the preparation of this plan: Charles Schneider, Steven Fisher, James Baker, Darlene Cossette, Karen Leydon, Randy Maples, Jeff Nakrin, Mark Oemler, Lori Walsh-Van WeyOffice of International AffairsThe Commission gratefully recognizes the significant contributions of the following individual in the preparation of this plan: Russ Damtoft Office of the General CounselThe Commission gratefully recognizes the significant contributions of the following individual in the preparation of this plan: Kathleen JohnsonPolicy PlanningThe Commission gratefully recognizes the significant contributions of the following individuals in the preparation of this plan: Susan DeSanti, James Cooper, Christopher GrengsA U.S. economy characterized by vigorous competition and consumer access to accurate information, yielding a wide range of products at competitive prices and rewarding efficiency, innovation, and consumer choice._ca6f378e-0dbe-11e2-9e46-51410bc9daa5To prevent business practices that are anticompetitive or deceptive or unfair to consumers; to enhance informed consumer choice and public understanding of the competitive process; and to accomplish this without unduly burdening legitimate business activity._ca6f3e64-0dbe-11e2-9e46-51410bc9daa5 Protect ConsumersPrevent fraud, deception, and unfair business practices in the marketplace._ca6f40b2-0dbe-11e2-9e46-51410bc9daa51ConsumersThe FTC has jurisdiction over a wide range of consumer protection issues. To carry out its broad mission, it must make effective use of limited resources by targeting its law enforcement and education efforts for maximum impact and by working closely with federal, state, international, and private sector partners in joint initiatives. In addition, the agency engages in dialogue with a variety of stakeholders to understand market concerns, and engages in and encourages study of and empirical research on consumer protection topics.Fraud, Deception & Unfair PracticesIdentify fraud, deception, and unfair practices that cause the greatest consumer injury._ca6f421a-0dbe-11e2-9e46-51410bc9daa51.1To fulfill its consumer protection goal, the FTC must identify consumer protection problems and trends in the fast-changing, increasingly global marketplace. The agency strives to understand the issues affecting consumers, including any newly emerging methods of fraud or deceit, so that it can target its enforcement, education, and advocacy to those areas where consumers suffer the most harm. The FTC reports this information to other law enforcement authorities and encourages those authorities to assist in its efforts, either independently or jointly. In this way, the FTC can leverage its resources by ensuring multiple “cops on the beat.” To fulfill this objective, the FTC is using new technologies creatively and building on its broad base of private and public sector partners. The agency continues to collect consumer complaint information directly through four principal sources: (1) a toll-free helpline (1-877-FTC HELP); (2) an identity theft hotline (1-877-ID-THEFT); (3) the National Do Not Call Registry (1-888-382-1222); and (4) the online consumer complaint forms that support each of these efforts, as well as online forms dedicated to complaints from members of the U.S. Armed Forces and to cross-border fraud complaints. In addition, the FTC continues to gather consumer complaint information from other sources, including law enforcement agencies, Better Business Bureaus, and private entities. The agency makes this and other information available, through a secure Internet website called the Consumer Sentinel Network, to more than 1,700 law enforcement partner agencies in the United States, Canada, and Australia. In addition, the FTC maintains an electronic mailbox (spam@uce.gov) to which Internet users are encouraged to forward spam. This spam is stored in a searchable database enabling the FTC staff to track trends and identify law enforcement targets when researching potential cases. The agency augments identification of targets from its databases with other strategies for generating enforcement leads, such as ad monitoring, Internet surfs (monitoring the Internet for potentially false or deceptive advertising for a targeted product or service), and direct referrals from government and private sector partners. Performance Measures: *” Complaints and inquiries collected and entered into the Consumer Sentinel Network database. ”* The percentage of the FTC’s consumer protection law enforcement actions that target the subject of consumer complaints to the FTC. ”* The rate of customer satisfaction with the FTC’s Consumer Response Center. The first performance measure will ensure that the agency assimilates a large number of consumer complaints, including complaints about Do Not Call violations. The agency will receive these complaints from a variety of sources, including direct consumer complaints to the FTC and complaints received by the FTC’s partners. In this manner, the FTC will be collecting robust information to inform its law enforcement efforts. The second measure will ensure that FTC law enforcement actions target the subject of concerns identified by consumers. The third measure will ensure that the agency’s Consumer Response Center is providing satisfactory service responding to consumers.Consumer Sentinel NetworkContinue to upgrade and enhance the Consumer Sentinel Network._ca6f44c2-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.1Consumer Complaint DataExpand the pool of entities that make their consumer complaint data available to the law enforcement community through the Consumer Sentinel Network. _ca6f46ac-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.2MonitoringMonitor the marketplace to identify illegal practices that may not be fully captured by the consumer complaint database, for example, through the FTC Internet Lab, spam database, Web surfs, and consumer surveys._ca6f4828-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.3Consumer Complaint InformationMake comprehensive consumer complaint information, as well as the analysis of that information, available to the FTC’s law enforcement partners through the Consumer Sentinel Network._ca6f4ada-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.4Functional ReviewReview current functions and determine what changes or upgrades to the Consumer Sentinel Network would be helpful. ” _ca6f4cce-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.5Law Enforcement & EducationAssess whether the FTC’s law enforcement and education efforts are addressing the leading areas identified by the consumer complaint information gathered by the agency._ca6f4ef4-0dbe-11e2-9e46-51410bc9daa5Strategy 1.1.6Information UsageAssess the extent to which the consumer complaint and other information made available by the agency is used by staff and its law enforcement partners._ca6f51d8-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.1.1FTC StaffFTC Law Enforcement PartnersThe FTC mines the complaint data and other information it collects to identify and target the most serious cases of fraud and deception and respond quickly to emerging problems. The agency also makes this information available to its law enforcement partners. Information sharing helps the agency coordinate its efforts to fight the many serious problems facing consumers. It also helps the agency leverage law enforcement resources, as other agencies who have access to the complaint data can take appropriate action to address consumer problems. Consumer Sentinel NetworkAssess security and integrity protections for the Consumer Sentinel Network and proposed enhancements to the database and evaluate the policies in place. _ca6f589a-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.1.2Law EnforcementStop fraud, deception, unfairness, and other unlawful practices through law enforcement. _ca6f5a8e-0dbe-11e2-9e46-51410bc9daa51.2The FTC protects consumers by enforcing Section 5 of the FTC Act, which prohibits unfair or deceptive acts or practices in or affecting commerce, as well as by enforcing an increasing number of statutes and rules proscribing specific unlawful practices. The agency initiates civil cases, primarily by filing actions in federal court, which allege that defendants have violated these laws and rules and seek injunctions and other relief. The Commission also conducts administrative proceedings. Performance Measures: *” The percentage of all cases filed by the FTC that were successfully resolved through litigation, a settlement, or issuance of a default judgment. ”* The FTC’s effectiveness in stopping prohibited business practices in three high priority areas over the next five years. ”* The percentage of redress cases in which the FTC distributes redress dollars designated for distribution to consumers within 6 months. ”* Investigations or cases in which the FTC obtains foreign-based evidence or engages in other mutual assistance that contributes to FTC law enforcement actions or in which we cooperate with foreign agencies and/or multilateral organizations. The first measure will ensure that the FTC successfully resolves cases, though it aims to file large, difficult, or precedent-setting cases when appropriate, including cases that raise challenging and legal and factual issues. The second measure will ensure the agency’s success in changing business practices within priority areas and demonstrate the change through research methods. The high priority areas will be identified by Bureau management in consultation with Commissioners. The third measure will ensure that the FTC returns redress dollars to consumers as quickly as possible. Dollars are considered “designated for distribution” when the FTC is in receipt of all funds, legal issues are resolved, and a usable claimant list is ready. The last measure helps gauge law enforcement efforts from an international perspective, including continuing to use and further develop new powers authorized under the “Undertaking Spam, Spyware, And Fraud Enforcement With Enforcers beyond Borders Act of 2006” (“Safe Web”) to achieve the objective. Consumer InjuryStop injury to consumers through aggressive law enforcement. _ca6f5d9a-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.1ConsumersAdvertising & Marketing PracticesHalt advertising and marketing practices that are most injurious to consumers or that prey on specific groups of vulnerable consumers. _ca6f5f84-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.2AdvertisersMarketersConsumer PrivacyChallenge practices that threaten consumer privacy._ca6f62d6-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.3Consumer Credit Statutes & RulesEnforce consumer credit statutes and rules to protect consumers from deceptive lending practices, illegal credit practices, and unfair and deceptive mortgage loan practices._ca6f65ba-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.4Order EnforcementCreate and implement a comprehensive order-enforcement program that targets those individuals and corporations that violate federal court and administrative orders obtained by the FTC. _ca6f67cc-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.5Criminal ProsecutionPromote the criminal prosecution of the most egregious fraud violators through coordination and cooperation with criminal law enforcement authorities._ca6f6984-0dbe-11e2-9e46-51410bc9daa5Strategy 1.2.6Enforcement ActivitiesEvaluate whether enforcement activities are tracking the areas of greatest concern and injury to consumers and whether there are new practices or technologies that require additional consumer protection law enforcement._ca6f6c86-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.2.1EducationPrevent consumer injury through education._ca6f6eb6-0dbe-11e2-9e46-51410bc9daa51.3Consumer and business education serves as the first line of defense against fraud, deception, and unfair practices. Most FTC law enforcement initiatives include a consumer and/or business education component aimed at preventing consumer injury and unlawful business practices, and mitigating financial losses. From time to time, the agency conducts pre-emptive consumer and business education campaigns to raise awareness of new or emerging marketplace issues that have the potential to cause harm. The agency creatively uses new technologies and private and public partnerships to reach new and under-served audiences, particularly those who may not seek information directly from the FTC. The FTC will continue to publicize its consumer complaint and identity theft website addresses and toll-free numbers in an ongoing effort to increase public awareness of its activities and inform the public of the ways to contact the FTC to obtain information or file a complaint. Performance Measures: ”* Consumer protection messages accessed online or in print. ”* Customer satisfaction rate with an FTC consumer education website or microsite. ”* Organizations requesting consumer education publications. Consumer and business education are crucial tools in preventing and reducing consumer harm efficiently and effectively. The first performance measure will help ensure that the agency is engaging in a sufficient amount of educational activity and that the educational materials are aimed at new trends and at particularly vulnerable populations. The second measure will ensure that the agency’s consumer education websites are effective and helpful for consumers. The third measure will ensure that the FTC is publicizing its activities in the best way possible and that the agency has a wide array of partners to leverage resources. FocusFocus consumer and business education efforts on areas where fraud, deception, unfair practices, and information gaps cause the greatest injury. ” _ca6f708c-0dbe-11e2-9e46-51410bc9daa5Strategy 1.3.1LeverageLeverage resources (by working with federal, state, local, international, and private sector partners) to maximize the reach of consumer and business education campaigns._ca6f73b6-0dbe-11e2-9e46-51410bc9daa5Strategy 1.3.2Federal Education Partners State Education PartnersLocal Education Partners International Education PartnersPrivate Sector Education PartnersTargetingTarget particular demographic groups with messages about marketplace issues that impact their health, safety, and economic well-being._ca6f7654-0dbe-11e2-9e46-51410bc9daa5Strategy 1.3.3Education MessagesMeasure the number of education messages disseminated each year relating to high profile or emerging issues, such as mortgage rescue foreclosure scams, where consumer and business education can help alleviate consumer injury._ca6f7870-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.1Media MixAssess whether the appropriate mix of media is being used to communicate consumer education messages and whether the FTC is making the most efficient use of available media and technology._ca6f7b9a-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.2Outreach PartnersAssess the range of public and private sector organizations that partner with the FTC on outreach._ca6f7dde-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.3New AudiencesDetermine whether the FTC needs to reach new audiences, in light of any changes in demographics, advertising, and marketing practices, and what strategies or partnerships may allow the FTC to reach those audiences._ca6f7fb4-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.4Education FocusReview the focus of FTC education efforts and adjust them based on changing consumer and business needs._ca6f82e8-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.5Special PopulationsContinue to assess and address the consumer information needs of the Hispanic, African American, and elderly populations._ca6f850e-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.3.6Hispanics African Americans The ElderlyResearch, Reports, Rulemaking & AdvocacyEnhance consumer protection through research, reports, rulemaking, and advocacy._ca6f86d0-0dbe-11e2-9e46-51410bc9daa51.4The FTC uses a variety of strategies in addition to law enforcement and education to enhance consumer protection. The agency convenes and co-sponsors conferences and workshops through which experts and other experienced and knowledgeable parties identify novel or challenging consumer protection issues and discuss ways to address those issues. The FTC also issues reports that analyze consumer protection problems and provide recommendations to address them. Further, the FTC files comments with federal and state government bodies advocating policies that promote the interests of consumers and highlight the role of consumer and empirical research in their decision making. The agency testifies before Congress on consumer protection issues. The FTC also files amicus briefs to aid courts’ considerations of consumer protection issues. Performance Measures: ”* Workshops and conferences convened or cosponsored that address consumer protection problems. ”* Advocacy comments and amicus briefs on consumer protection issues filed with entities including federal and state legislatures, agencies, or courts. ”* The percentage of respondents finding the FTC’s advocacy comments and amicus briefs “useful.” (Note that “usefulness” is assessed by the recipient; the target percentage recognizes that comments critiquing a recipient’s proposed action may not be assessed positively.) ”* The percentage of proposed Administrative Procedure Act (APA) rulemakings, conducted solely by the FTC, completed within 9 months of receipt of final comments in the Final Notice of Proposed Rulemaking. Public policy that enhances consumer protection is based on a thorough understanding of complex issues, which arises from dialogue, study, and empirical research. Such policy also appreciates that stakeholders other than government, such as industry associations or private standard-setting organizations, are at times better placed to address certain consumer protection issues. These performance measures will help ensure that the agency augments its enforcement and education efforts by encouraging discussions among all interested parties, through careful study of and empirical research on novel or challenging consumer protection problems, by urging adoption of policies and legal principles that promote consumers’ interest, and by conducting rulemaking as appropriate. These activities will help guide the FTC’s consumer protection policy decisions, as well as those of other state, federal, and international policymakers.Workshops & ConferencesFocus workshops and conferences on emerging or challenging consumer protection problems, especially those related to new technologies and financial concerns. _ca6f89fa-0dbe-11e2-9e46-51410bc9daa5Strategy 1.4.1ReportsIssue reports mandated by law and other reports that articulate concrete measures that the public and private sectors could take to address consumer protection problems, particularly those related to new technologies or financial concerns._ca6f8c34-0dbe-11e2-9e46-51410bc9daa5Strategy 1.4.2RulesUpdate, rescind, or promulgate trade regulation rules and other agency rules in response to regulatory reviews, Congressional mandates, and emerging consumer protection issues. ” _ca6f8e1e-0dbe-11e2-9e46-51410bc9daa5Strategy 1.4.3AdvocayTarget advocacy activities to encourage state, federal, and foreign government policymakers to evaluate both the costs and benefits of their policies for consumers, emphasizing the impact on consumers of policies that unnecessarily affect the dissemination of truthful, non-misleading information to consumers._ca6f9166-0dbe-11e2-9e46-51410bc9daa5Strategy 1.4.4State Government PolicymakersFederal Government PolicymakersForeign Government PolicymakersLetters & Public CommentsUse letters and public comments to urge state, federal, and foreign government policymakers to consider consumer research and other empirical data in their decisions regarding the costs and benefits of their policies for consumers._ca6f93aa-0dbe-11e2-9e46-51410bc9daa5Strategy 1.4.5State Government PolicymakersFederal Government PolicymakersForeign Government PolicymakersComments & EngagementEvaluate whether the FTC is filing comments or otherwise engaging in advocacy with state, federal, and foreign government bodies on consumer protection policies that will have a significant impact on consumers. _ca6f95a8-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.4.1State Government Bodies Federal Government Bodies Foreign Government BodiesEvaluation, Monitoring & AdvocacyAssess whether industry gives weight to the FTC’s evaluation, monitoring, and advocacy._ca6f98f0-0dbe-11e2-9e46-51410bc9daa5Evaluation 1.4.2IndustryGlobal MarketplaceProtect American consumers in the global marketplace by providing sound policy and technical input to foreign governments and international organizations to promote sound consumer policy._ca6f9b84-0dbe-11e2-9e46-51410bc9daa51.5American ConsumersThe FTC increasingly works around the globe to address new and emerging consumer protection and privacy challenges and concerns. A myriad of issues – spam, phishing, spyware, telemarketing fraud, identity theft, data security, and privacy – cross national borders. The resulting challenges require the FTC to cooperate with counterparts in foreign agencies and international organizations. Performance Measures: ”* Policy advice provided to foreign consumer protection and privacy agencies, directly and through international organizations, through substantive consultations, written submissions, or comments *” Technical assistance to foreign consumer protection and privacy authorities. These measures address the scope of our contact with international counterparts and help determine if our efforts are sufficiently broad-based.Consumer Protection ModelPursue the development of an international consumer protection model that focuses on protecting consumers while maximizing economic benefit and consumer choice._ca6f9da0-0dbe-11e2-9e46-51410bc9daa5Strategy 1.5.1Cutting-Edge IssuesFocus on understanding cutting-edge issues in technology and globalization that present challenges to American consumer interests._ca6fa12e-0dbe-11e2-9e46-51410bc9daa5Strategy 1.5.2PolicyInfluence policy development and implementation by advising multilateral organizations, regional entities, and foreign government agencies through substantive consultations and written comments._ca6fa3a4-0dbe-11e2-9e46-51410bc9daa5Strategy 1.5.3Multilateral OrganizationsRegional EntitiesForeign Government AgenciesTechnical AssistanceProvide technical assistance to newer consumer protection agencies to enhance their ability to apply sound consumer protection policies._ca6fa5c0-0dbe-11e2-9e46-51410bc9daa5Strategy 1.5.4Consumer Protection AgenciesAdvice & Comments”Where feasible, evaluate whether the advice and comments that the FTC provides to foreign government agencies and international organizations have been considered by the recipients in their policy development. _ca6fa944-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 1.5.1Foreign Government Agencies International OrganizationsTechnical AssistanceEvaluate completed technical assistance missions to determine, from the perspective of participants and their managers, whether the assistance was deemed valuable._ca6fabd8-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 1.5.2FTC PartnersMaintain CompetitionPrevent anticompetitive mergers and other anticompetitive business practices in the marketplace._ca6fae08-0dbe-11e2-9e46-51410bc9daa52The work of the FTC’s Maintaining Competition Mission is critical to protect and strengthen the free and open markets that are the cornerstone of a vibrant economy. Aggressive competition among sellers in an open marketplace gives consumers the benefit of lower prices, higher quality products and services, maximum choice, and innovation leading to beneficial new products and services. The FTC’s goal is to promote vigorous competition by using the antitrust laws to prevent anticompetitive mergers and stop business practices that diminish competition, such as agreements among competitors about prices or other aspects of competition (referred to as nonmerger enforcement), while at the same time minimizing the burdens on legitimate competitive activities. The FTC also engages in a dialogue with state, federal, and international policymakers to advocate on behalf of free and open markets and to urge these other policymakers to restrict competition as little as possible when pursuing other regulatory goals. In addition, the agency engages in dialogue with a variety of stakeholders to understand market concerns, and engages in and encourages study of and empirical research on competition topics. The FTC also files amicus curiae briefs in cases presenting important competition issues that urge courts to adopt rules that benefit consumers by promoting competition. And finally, the agency enters into agreements with foreign competition authorities to facilitate the exchange of information about investigations.Mergers & PracticesTake action against anticompetitive mergers and practices that may cause significant consumer injury._ca6fb18c-0dbe-11e2-9e46-51410bc9daa52.1The FTC takes action to block or remedy anticompetitive mergers and to stop anticompetitive conduct. This antitrust enforcement provides substantial benefits to consumers by preventing anticompetitive mergers and other coordinated or unilateral conduct that are likely to lessen competition and innovation and cause consumers to pay higher prices or obtain lower quality goods and services than they otherwise would. The FTC investigates proposed and consummated mergers, as well as anticompetitive conduct and agreements, and takes action when it has reason to believe that mergers or conduct will likely harm consumers. The FTC’s enforcement actions result in litigation, consent orders, and abandoned or restructured transactions or agreements. The FTC strives to maintain strong litigation capabilities and works to ensure that the remedies imposed by its consent orders are effective in maintaining competition in the marketplace. The Hart-Scott-Rodino (HSR) Premerger Notification Act provides the FTC an effective starting point for identifying anticompetitive mergers and taking action to block or remedy these mergers before they are consummated. The FTC administers the HSR program both for itself and for the Department of Justice’s (DOJ) Antitrust Division, which shares authority to challenge anticompetitive mergers. The FTC also uses trade press articles, consumer and competitor complaints, and other means to identify potentially anticompetitive mergers that were not required to be reported under HSR, or that were not reported in violation of HSR. On the nonmerger side, there is no comparable statutorily mandated program to help identify anticompetitive business practices. The FTC must instead employ a variety of methods to identify potentially anticompetitive practices (for example, consumer and competitor complaints, referrals from other government agencies, and monitoring the trade press). Performance Measures: *” Actions to maintain competition, including litigated victories, consent orders, abandoned transaction remedies, restructured transaction remedies, or fix-it-first transaction remedies in a significant percentage of substantial merger and nonmerger investigations. - “Actions” include consents, abandoned transactions, and final litigated victories. Not included in “actions” would be filed Preliminary Injunctions or Permanent Injunctions, administrative litigations still pending, transactions abandoned before the investigation is reached or the second request/compulsory process stage, or nonmerger consents where staff logged less than 150 hours. - “Significant percentage” refers to the 40%-60% target (which is shown on the Performance Measure table that begins on page 40.) - “Substantial investigation” includes, for merger investigations, second request and compulsory process investigation. For nonmerger investigations, this refers to investigations where staff logged more than 150 hours. *” Consumer savings of at least $500 million through merger actions to maintain competition. * Actions against mergers likely to harm competition in markets with a total of at least $25 billion in sales. * Consumer savings of at least six times the amount of FTC resources allocated to merger program. * Consumer savings of at least $80 million through nonmerger actions taken to maintain competition. * Actions against anticompetitive conduct in markets with a total of at least $8 billion in annual sales. * Consumer savings of at least four times the amount of FTC resources allocated to nonmerger program. *” The percentage of cases in which the FTC had at least one substantive contact with a foreign antitrust authority in which the agencies followed consistent analytical approaches and reached compatible outcomes. These measures evaluate agency performance in several ways: the percentage of substantial investigations that have positive results (i.e., litigated victories, consent orders, or abandoned, fix-it-first, or restructured transactions), the volume of commerce affected (benefitted) by merger and nonmerger actions to maintain competition, the estimated dollar savings to consumers resulting from merger and nonmerger actions, and the estimated dollar savings to consumers per dollar of enforcement resources. In the absence of casespecific information, the dollar savings to consumers is conservatively estimated as one percent of the volume of commerce in the affected markets (for two years in merger cases and for one year in nonmerger cases). It is not intended as a precise estimate of consumer savings, but, rather, as an indication of general magnitude. A more precise estimate based on case-specific information will be used whenever possible. The use of a volume of sales performance measure does not mean that the FTC will only investigate and take enforcement action in markets with large sales volumes. The FTC will continue to investigate and take enforcement action as necessary in all markets where considerable consumer harm is likely. The benchmarks for the estimated dollar savings to consumers per dollar of enforcement resources for merger and nonmerger actions are based on historical experience, reflecting the different mix of cases and the different investigative and enforcement processes. These measures will help guide the agency in challenging conduct that causes substantial consumer injury through targeting of its resources effectively and efficiently. These measures evaluate appropriate investigation, case selection, and resolution, whether through litigation or settlement, as well as the crafting of sufficient and effective remedies.OrdersContinue to benefit consumers by challenging anticompetitive mergers and other nonmerger anticompetitive conduct, negotiating consent orders, and winning litigated orders._ca6fb42a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.1HSR FilingsContinue to make efficient use of the initial 30-day period after HSR filings (or 15 days for a cash tender offer) to determine whether a more detailed investigation is needed to assess whether a merger is likely to harm competition, and to avoid unnecessary extended investigations, including prompt inter-agency clearance and timely review. _ca6fb696-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.2When appropriate, issue requests for additional information under HSR to determine whether a merger is likely to be anticompetitive. ” Press Articles, Consumer & Competitor ComplaintsUse trade press articles, consumer and competitor complaints, and other means to identify potentially anticompetitive mergers that were not required to be reported under HSR, or that were not reported in violation of HSR, and potentially anticompetitive nonmerger business practices. ” _ca6fba60-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.3ConsumersCompetitorsPressCompulsory ProcessWhen appropriate, use compulsory process in merger and nonmerger investigations to obtain additional information needed to make an informed judgment about the anticompetitive potential of mergers and nonmerger practices._ca6fbd26-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.4Monitoring & EnforcementMonitor and enforce compliance with consent decrees and orders. ” _ca6fc03c-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.5InvestigationsPromptly use compulsory processes in merger and nonmerger investigations. ” _ca6fc578-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.6Investigatory ProcessExpedite the investigatory process including possible revisions to Part 2 of the FTC Rules of Practice._ca6fc88e-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.7CommunicationEnsure effective communications between staff and the Commission about pending investigations._ca6fcaf0-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.8FTC StaffFTC CommissionersEnforcement GuidelinesAssess whether revisions to the enforcement guidelines are required. _ca6fcfaa-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.9HSR ReportingMonitor and enforce compliance with HSR reporting obligations._ca6fd31a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.10Integrated TeamsEmploy integrated teams of lawyers, economists, and other professionals to conduct an economically sound, fact-based analysis of mergers and other potentially anticompetitive business practices. _ca6fd5d6-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.11EconomistsLawyersRetain outside experts and consultants in relevant fields of expertise, as needed, when enforcement outcomes would be enhanced by specialized supplementary resources.Remediation, Precendent & DeterrenceNegotiate merger and nonmerger consent orders and win litigated orders that have significant remedial, precedential, and deterrent effects._ca6fda18-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.12TimelinessEnsure that administrative litigation and adjudication reach a timely resolution._ca6fdd4c-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.13Burdens & ConflictsWork with state or local officials, other federal agencies, and international agencies to maximize resources in taking action against anticompetitive mergers and business practices, and to minimize, to the extent possible, burdens on enforcers and business and duplication of effort, and to avoid conflicting remedies._ca6fe012-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.14EnforcersBusinessesLocal OfficialsFederal AgenciesInternational AgenciesWorkshops, Hearings & ResearchApply information gained through workshops, hearings, and research projects to improve the FTC’s understanding of significant antitrust issues and emerging trends in business practices, technology, and the marketplace. _ca6fe4f4-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.15Merger Process ReformsApply the merger process reforms to conduct investigations more efficiently, in order to enhance enforcement outcomes while minimizing burdens on business._ca6fe832-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.16Skills & ToolsImprove negotiation and litigation skills and refine investigative and decisional tools through continuous learning. _ca6feb48-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.17TimelinessTrack and maintain the timeliness of investigations and merger review under the HSR program._ca6fef58-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.18E-Government InitiativesContinue to integrate e-government initiatives into mission activities. _ca6ff246-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.19Budget & Performance IntegrationImprove the integration of budget and performance by linking goals and objectives to results; develop improved processes for use and analysis of management data._ca6ff4da-0dbe-11e2-9e46-51410bc9daa5Strategy 2.1.20Merger ActionsAssess the scope of the FTC’s annual merger actions to maintain competition, as reflected by the volume of commerce in markets in which the agency took merger actions. ” _ca6ff8ea-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.1Volume of Commerce & Level of Consumer SavingsDetermine whether the total volume of commerce in such markets is likely to reach $25 billion and determine whether the level of consumer savings is likely to reach $500 million. ” _ca6ffbe2-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.2Impact Versus ResourcesCompare the likely impact in these markets to the resources spent on the mission. _ca6ffe76-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.3Nonmerger ActionsAssess the scope of the FTC’s annual nonmerger actions to maintain competition, as reflected by the volume of commerce in markets in which the agency took nonmerger actions. ” _ca7003ee-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.4Volume of Commerce & Level of Consumer SavingsDetermine whether the total volume of commerce in such markets is likely to reach $8 billion and determine whether the level of consumer savings is likely to reach $80 million. ”_ca7006f0-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.5Impact Versus ResourcesCompare the likely impact in these markets to the resources spent on the mission. ” _ca70098e-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.6Deterrence & PrecedenceAssess qualitatively the deterrence value and precedential significance of the enforcement actions brought during each year._ca700e02-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.7LitigationEvaluate litigation performance for lessons that may be applicable to future litigation._ca7011e0-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.8Competition ResearchReview the results of major competition research initiatives to identify their usefulness in guiding FTC decisions and influencing other policymakers’ approaches to competition issues._ca701488-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.9Nonenforcement ImpactsAssess markets where investigations were closed without enforcement action and consider whether competition was harmed in the markets resulting in substantial consumer injury, and use this information to guide and enhance the agency’s future investigations and enforcement actions._ca7018d4-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.10BurdensAssess the burden imposed on merger parties by the HSR merger investigation process, explore ways of reducing that burden without compromising effectiveness of investigations, and explore methods of measuring HSR compliance burden._ca701bf4-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.11Merger PartiesEfficiencyAssess the FTC’s efficiency in conducting antitrust investigations, explore ways to increase efficient use of investigatory resources and reduce burdens on business, and explore whether efficiency in conducting investigations can more meaningfully be measured._ca701ea6-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.1.12Consumer EducationPrevent consumer injury through education._ca70231a-0dbe-11e2-9e46-51410bc9daa52.2ConsumersEducating consumers and businesses about competition law and policy is a critical part of the FTC’s mission. Informing businesses and their legal advisers about potential antitrust violations deters anticompetitive mergers and anticompetitive business practices from being proposed and reduces businesses’ cost of compliance. Educating consumers about their rights and their ability to bring violations to the FTC’s attention reduces the cost of identifying anticompetitive conduct. Providing consumers and businesses with information about how antitrust enforcement benefits the common good also encourages cooperation with the FTC’s investigations and enforcement actions. Performance Measure: *” Competition resources accessed via the FTC’s website. Successful outreach and education efforts, as reflected by the above measure, will help consumers because increased knowledge and understanding of the antitrust laws will help businesses stay in compliance. This measure also helps ensure that the agency engages in consumer, business, and international education that advances the culture of competition.Antitrust IssuesEducate consumers and businesses about antitrust issues through traditional means such as guidelines, advisory opinions, reports, articles in professional or other publications, speeches, and participation in professional organizations._ca702630-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.1ConsumersBusinessesAgency ActionsEducate consumers through detailed information regarding agency actions on the FTC website, and in press releases, reports, articles, and other publications._ca7028f6-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.2ConsumersPressPublishersBusiness InformationEducate businesses through detailed information regarding agency actions on the FTC website, and in press releases, reports, articles, and other publications._ca702d56-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.3BusinessesPressPublishersParticipationSeek the participation of businesses and consumer groups in conferences, workshops, and hearings._ca70308a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.4Businesses Consumer GroupsInformation DisseminationContinue to conduct and disseminate the results of public hearings, conferences, and workshops on practices and developments in the marketplace and the results of economic research on how markets operate. ”_ca703364-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.5Avenues of CommunicationContinue to enhance avenues of communication with consumers and business, such as email and the FTC website. ” _ca70380a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.6ConsumersBusinessesTransparencyEnsure that the content of complaints, press releases, and analyses to aid public comment are “transparent,” that is, that they explain in sufficient detail and with sufficient clarity the evidence and theory of a case, within the constraints of confidentiality requirements. ” _ca703b3e-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.7Public StatementsExpand the use of other public statements to explain why the Commission elected not to take enforcement action in certain matters to further improve the public’s understanding of the FTC’s enforcement policies. ” _ca703e18-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.8Lay Group OutreachEngage in outreach to lay groups such as schools to provide information about the work of the FTC and basic principles of economics and competition._ca7042a0-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.9Lay GroupsForeign OutreachEngage in outreach to foreign competition agencies to facilitate the agency’s efforts to promote convergence toward sound consumer-welfare-based competition enforcement and policy._ca7045de-0dbe-11e2-9e46-51410bc9daa5Strategy 2.2.10Foreign Competition AgenciesWebsiteEvaluate what antitrust content on the FTC website generates the largest amount of public interest, and why, and use this information in setting future priorities._ca7048cc-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.2.1InputSeek input from consumer groups, business groups, bar groups, international competition organizations, and other FTC “customers” on the effectiveness of FTC educational efforts._ca704e6c-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.2.2Consumer GroupsBusiness GroupsBar GroupsInternational Competition OrganizationsTransparencyEvaluate the transparency of FTC merger review policy by assessing the extent to which significant changes in such policy are communicated to stakeholders._ca7051d2-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.2.3Research, Reports & AdvocacyEnhance consumer benefit through research, reports, and advocacy._ca7054ca-0dbe-11e2-9e46-51410bc9daa52.3In addition to its enforcement authority, the FTC has the unique jurisdiction to gather, analyze, and make public certain information concerning the nature of competition as it affects U.S. commerce. The FTC uses that authority to hold public hearings, convene conferences and workshops, conduct economic studies on competition issues of significant public importance, and issue reports of its findings. This authority advances the competition mission in numerous ways. The agency uses the information internally to refine the theoretical 13 framework for analyzing competition issues and the empirical understanding of industry practices, which contributes substantially to an effective response to changing marketplace conditions. The information gained through this authority, combined with the agency’s professional expertise on competition issues, also contributes to a better understanding of business practices and their competitive and economic implications on various entities, including the business sector, the legal community, other enforcement authorities, the judiciary, and governmental decision makers and policymakers at the federal, state, and local levels. In particular, the agency testifies before Congress on competition issues. The FTC uses its expertise to encourage governmental actors at all levels to evaluate both the costs and the benefits of their policies for consumers, and to ensure such policies promote consumer benefit. This advocacy includes formal and informal dialogue with state and federal policymakers and amicus curiae briefs filed with state and federal courts. Performance Measures: *” Workshops, seminars, conferences, and hearings convened or cosponsored that involve significant competition-related issues. ”* Reports and studies issued on key competition-related topics. ”* Advocacy comments and amicus briefs on competition issues filed with entities including federal and state legislatures, agencies or courts. ”* The percentage of respondents finding the FTC’s advocacy comments and amicus briefs “useful.” (Note that “usefulness” is assessed by the recipient; the target percentage recognizes that comments critiquing a recipient’s proposed action may not be assessed positively.) ”* The volume of traffic on www.ftc.gov relating to competition research, reports, and advocacy. These measures will help ensure that the agency is engaging in appropriate types and sufficient levels of research, reports, and advocacy to ensure that they are relevant to consumers, policymakers, business, and the legal community.Hearings, Conferences & WorkshopsConduct public hearings, conferences, and workshops that bring together interested parties to enhance understanding of various practices and developments in the marketplace._ca70595c-0dbe-11e2-9e46-51410bc9daa5Strategy 2.3.1StudiesConduct studies as requested by Congress and other studies as appropriate. _ca705cd6-0dbe-11e2-9e46-51410bc9daa5Strategy 2.3.2CongressEconomic StudiesConduct economic studies of the effects of business actions on competition and consumers in accordance with agency data quality standards, as applicable, to ensure the quality of information that may be disseminated publicly._ca706032-0dbe-11e2-9e46-51410bc9daa5Strategy 2.3.3AdvocacyTarget advocacy activities to encourage state and federal government policymakers to evaluate both the costs and the benefits of their policies for consumers, emphasizing the impact on consumers of policies that unnecessarily restrict competition._ca7064f6-0dbe-11e2-9e46-51410bc9daa5Strategy 2.3.4State Government PolicymakersFederal Government PolicymakersAmicus Curiae BriefsFile amicus curiae briefs with state and federal courts deciding important competition policy issues urging them to adopt legal rules that benefit consumers by promoting competition._ca706a5a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.3.5State Courts Federal CourtsEvaluation FormsInclude evaluation forms with workshop and conference materials to help assess whether the workshops and conferences are an effective means of joining the debate relating to these issues. _ca706dd4-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.3.1InputSeek input from consumer groups, business groups, bar groups, and others on the value of the agency’s research, reports, advocacy submissions, and international activities relating to the competition mission._ca7072b6-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.3.2Consumer Groups Business Groups Bar GroupsComments & AdvocacyEvaluate whether the FTC is filing comments or otherwise engaging in advocacy with state and federal policymakers on competition policies that will have a significant impact on consumers and whether the recipients of these comments have given weight to the views expressed in these comments in making policy decisions that affect consumers._ca707644-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.3.3State PolicymakersFederal PolicymakersGlobal MarketplaceProtect American consumers in the global marketplace by providing sound policy recommendations and technical advice to foreign governments and international organizations to promote sound competition policy._ca707978-0dbe-11e2-9e46-51410bc9daa52.4American consumersThe FTC continues to build cooperative relationships with foreign antitrust agencies to ensure close collaboration on cross-border cases and convergence toward sound competition policies. The FTC seeks more effective, coordinated reviews of multijurisdictional mergers, and is working towards achieving consistent outcomes in cases of potential unilateral anticompetitive conduct. Participation in multilateral competition organizations provides valuable opportunities to promote international cooperation and convergence and for competition officials to share insights on law enforcement and policy initiatives. Performance Measures: ”* Policy advice provided to foreign competition agencies, directly and through international organizations, through substantive consultations, written submissions, or comments. *” Technical assistance provided to foreign competition authorities. These measures address the scope of our contact with international counterparts and help determine if our efforts are sufficiently broad-based.Competition ModelPursue the development of an international market-based competition model that focuses on the maximization of consumer benefit._ca707e5a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.4.1PolicyInfluence policy development and implementation by advising multilateral organizations, regional entities, and foreign government agencies through substantive consultations and written comments._ca708242-0dbe-11e2-9e46-51410bc9daa5Strategy 2.4.2Multilateral OrganizationsRegional Entities Foreign Government AgenciesTechnical AssistanceProvide technical assistance to newer competition agencies to enhance their ability to apply sound competition policies._ca70858a-0dbe-11e2-9e46-51410bc9daa5Strategy 2.4.3Competition AgenciesAdvice & CommentsWhere feasible, evaluate whether the advice and comments that the FTC provides to foreign government agencies and international organizations have been considered by the recipients in their policy development. ” _ca708abc-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.4.1Technical AssistanceEvaluate completed technical assistance missions to determine, from the perspective of participants and their managers, whether the assistance was deemed valuable._ca708e72-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 2.4.2Advance PerformanceAdvance the FTC’s performance through organizational, individual, and management excellence._ca7091b0-0dbe-11e2-9e46-51410bc9daa53The FTC recognizes that a strong foundation of organizational, individual, and management excellence is a driver of mission success. Goal 3 embodies cross-cutting, ongoing efforts to advance mission performance and enable Goal 1 and Goal 2 to focus on protecting consumers and maintaining competition. Collaborative in nature, this goal captures shared responsibility for agency excellence on behalf of all who rely on the FTC to be an effective guardian of informed consumer choice and free and open markets. The four objectives supporting this goal align with four key functional areas: human resources, infrastructure and security, information resources, and finance and acquisition. In carrying out our strategies, we will undertake a range of efforts— from managing employees effectively to exercising responsible stewardship of taxpayer dollars. Work in these areas is intended to foster a culture of leadership and accountability and to create conditions that enable decision making while establishing a framework of planning, administration, and management. At the individual level, all employees are expected to assume leadership roles in their areas of responsibility by exhibiting a willingness to develop and coach others, a commitment to teamwork and collaboration, and a drive to meet challenges with innovation and urgency. Collectively, these efforts lay the groundwork for achieving organizational, individual, and management excellence.Human ResourcesProvide effective human resources management._ca7096a6-0dbe-11e2-9e46-51410bc9daa53.1This objective is aligned with our Human Capital Plan that encompasses leadership and knowledge management, a results-oriented performance culture, talent management, and job satisfaction. We use an integrated approach that ensures human capital programs and policies are linked to the mission, goals, and strategies, while providing for continuous improvement in efficiency and effectiveness. This objective captures our work ensuring that we have the right talent in the right positions at the right time to meet the challenges of the 21st century by attracting, developing, motivating, and retaining a highly skilled and diverse workforce. Performance Measures: *” The extent employees believe their organizational culture promotes improvement in processes, products and services, and organizational outcomes. ”* The extent employees think the organization has the talent necessary to achieve organizational goals. These performance measures address central aspects of this objective. The FTC recognizes that its employees are its greatest asset and places great emphasis on the importance of human resources management to the successful accomplishment of its mission. The FTC seeks employee feedback on the extent they believe the organization culture promotes improvement in processes, products and services, and outcomes and the extent the FTC has the right talent in the right positions at the right time to carryout the mission. Recruitment, Development & RetentionImplement programs and processes that will enable the agency to quickly recruit, develop, and retain a qualified, diverse workforce through an integrated workforce plan._ca709a52-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.1Integrated Workforce PlanUse the integrated workforce plan to identify and fulfill current and future human resources needs to carry out the mission._ca709db8-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.2Culture & AccountabilityCreate an agency-wide performance culture focused on individual and organizational accountability toward the achievement of the FTC’s programmatic goals and priorities._ca70a40c-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.3Employee SurveyImplement an employee survey to measure employees’ perceptions about conditions that characterize successful organizations, such as leadership quality, performance culture, and talent capacity at the FTC._ca70a7d6-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.4FTC EmployeesTraining & OutreachProvide human resources management training and outreach to staff. ” _ca70ab3c-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.5FTC HR StaffKnowledge & SkillsSupport employees’ efforts to improve their knowledge base and skills in a variety of ways, e.g., by participating in professional activities related to the FTC’s mission._ca70b0b4-0dbe-11e2-9e46-51410bc9daa5Strategy 3.1.6FTC EmployeesHuman Capital Policies, Programs & ProcessesAssess whether the FTC’s human capital policies, programs, and processes are addressing the areas identified by employees gathered by the agency annually through the employee survey. ” _ca70b6fe-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.1.1Programs & ProcessesReview current programs and processes, identify what changes would be helpful, and implement those changes._ca70ba6e-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.1.2Infrastructure & SecurityProvide effective infrastructure and security management._ca70c202-0dbe-11e2-9e46-51410bc9daa53.2This objective encompasses building, modernizing, and maintaining physical and information technology infrastructure to ensure a safe and secure workplace, to achieve mission goals, and to respond to and anticipate both routine and emergency agency requirements. The agency’s Continuity of Operations Plan (COOP) represents a principal initiative under this objective. The Federal Emergency Management Agency (FEMA) conducts annual testing of all federal agency COOP programs. Each federal agency is graded on its responses to the questions and their communication methods by FEMA staff. A second important initiative involves facilities management and space usage. The FTC works with General Services Administration (GSA) to lease space and assesses staff requirements to anticipate needs for outfitting the buildings with adequate work space, conference space and storage space. Finally, managing technical infrastructure and ensuring the availability and reliability of the agency computer and communication facilities represents another important dimension of our work under this initiative. Performance Measures: *” A favorable Continuity of Operations (COOP) rating. ”* Availability of information technology systems. These measures gauge important dimensions of maintaining physical and information technology infrastructure and security. A COOP rating offers insight to agency preparedness across a wide spectrum of issues related to facility and operations management. Network availability addresses the reliability of the FTC computer and communications systems.COOPPromote staff awareness by regularly participating in COOP testing._ca70c5f4-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.1FTC StaffBest PracticesContinue incorporating best practices and gleaning knowledge from FEMA staff._ca70c9be-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.2FEMA StaffSpace UsageAlign with GSA to determine best space usage alternatives, including identifying a new site for staff currently at the Washington, DC, New Jersey Avenue building._ca70cf40-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.3GSATechnologyContinuously take advantage of advances in technologies._ca70d36e-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.4Network Auditing & MonitoringPerform internal network auditing and monitoring._ca70d724-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.5Network VulnerabilitiesWork with customers within the agency to address network vulnerabilities and unusual network activity._ca70dc9c-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.6Security Training & OutreachProvide security training and outreach to staff. _ca70e098-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.7Resource MaterialsEnsure that staff have adequate access to current, authoritative resource materials in FTC mission areas._ca70e426-0dbe-11e2-9e46-51410bc9daa5Strategy 3.2.8FTC StaffCOOP Funding & StaffingAssess COOP funding against results, determine further staffing requirements, and determine cost to further maintain the program._ca70e98a-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.2.1Tenant SurveysCollect feedback from GSA Tenant Surveys and from FTC staff._ca70ed86-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.2.2GSAFTC StaffSpace UtilizationPerform periodic reviews of the percentage of utilized space._ca70f114-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.2.3IRMProvide effective information resources management._ca70f68c-0dbe-11e2-9e46-51410bc9daa53.3The FTC recognizes that sound management of information resources is essential to meeting its strategic goals. The agency manages information in order to enable staff to make thoughtful decisions and perform their work, to facilitate appropriate public access, and to protect sensitive information from inappropriate access and release. The agency is undergoing a multiyear transition to managing information resources in an electronic format as one of the best means of meeting this objective. Performance Measure: *” The percentage of Commission approved documents in ongoing and newly initiated FTC proceedings available via the Internet within 15 days of becoming part of the public record. This performance measure facilitates public awareness of and participation in Commission activities. Timely availability of public documents gauges the depth and scope of our transparency in this area.Records ScheduleImplement a comprehensive retention schedule authorizing maintenance and disposition of agency records in electronic format that has been approved by the National Archives and Records Administration (NARA)._ca70faba-0dbe-11e2-9e46-51410bc9daa5Strategy 3.3.1National Archives and Records Administration (NARA)EDMSUtilize an electronic document management system (EDMS) to house work product and official records._ca7100b4-0dbe-11e2-9e46-51410bc9daa5Strategy 3.3.2Business Process ImprovementsIdentify and implement business process improvements through effective use of technology._ca710672-0dbe-11e2-9e46-51410bc9daa5Strategy 3.3.3Policies & ProceduresDevelop and implement additional information management policies and procedures._ca710a96-0dbe-11e2-9e46-51410bc9daa5Strategy 3.3.4Training & OutreachProvide information and records management training and outreach to staff._ca710e4c-0dbe-11e2-9e46-51410bc9daa5Strategy 3.3.5FTC StaffE-File StructuresAssess whether particular e-file structures are appropriate for organizing various types of information._ca7113f6-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.3.1Sensitive E-FilesReview the means by which FTC maintains and monitors access restrictions to sensitive electronic files. ” _ca711810-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.3.2TrainingAssess training needs._ca711bc6-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.3.3Financial & Acquisition ManagementProvide effective financial and acquisition management._ca71217a-0dbe-11e2-9e46-51410bc9daa53.4Resource stewardship and financial oversight are fundamental to establishing the accountability and transparency through which organization, individual, and management excellence are fostered. Effective financial and acquisition management means that the FTC protects American consumers and maintains competition in a fiscally responsible manner. Doing so remains one of our top priorities. Our work in this arena covers a wide range of administrative and operational efforts such as formulating and executing the agency budget, managing acquisition activities, overseeing the internal control program, managing accounting operations, spearheading audit resolution, and ensuring compliance with various financial management laws and regulations. By promoting consistency and integrity throughout the organization, these initiatives and others like them contribute not only to efficient program delivery, but also to effective and efficient agency administration overall. These efforts are critical to maintaining the management infrastructure needed to carry out our mission. Performance Measures: *” Independent auditor’s financial statement audit results. ”* The percentage of Bureaus/Offices that establish and maintain an effective, risk-based internal control environment. ”* Performance against the Small Business Administration’s government-wide small business procurement goals. Together, these measures address the most important aspects of this objective. The financial statement audit determines whether our financial statements are presented fairly, in all material respects, in conformity with generally accepted accounting principles. The audit also addresses internal controls over financial reporting, and compliance with applicable laws and regulations. The internal control measure demonstrates our commitment throughout the agency to promote integrity, efficiency, effectiveness, and economy. Achieving our small business procurement goal demonstrates that our procurements meet or exceed a major federal acquisition standard.Financial System IntegrationIntegrate disparate legacy systems with the agency’s core financial system._ca7125d0-0dbe-11e2-9e46-51410bc9daa5Strategy 3.4.1Strategic AlignmentAlign resources to strategic priorities and outcomes so we will be focused on our most important tasks and programs._ca7129b8-0dbe-11e2-9e46-51410bc9daa5Strategy 3.4.2Internal ControlsEnhance the internal control environment through developing and maintaining appropriate guidance and training for all staff. _ca712f76-0dbe-11e2-9e46-51410bc9daa5Strategy 3.4.3FTC StaffBusiness SolutionsImplement the best business solutions to accomplish our goals through world-class acquisition and business processes._ca71339a-0dbe-11e2-9e46-51410bc9daa5Strategy 3.4.4Audits & InvestigationsCooperate with the Office of Inspector General on audits and investigations of FTC programs and operations._ca713778-0dbe-11e2-9e46-51410bc9daa5Strategy 3.4.5FTC Office of Inspector General Administrative & Programmatic OperationsAssess internal administrative and programmatic operations to address areas that need improvement._ca713d36-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.4.1Acquisition ProceduresAssess our acquisition procedures to see if federal regulations and standards are met and that COTRs meet mandatory training requirements._ca71418c-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.4.2Financial & Feeder SystemsReview financial and feeder system implementation goals to ensure that user needs and federal standards and requirements are met._ca714574-0dbe-11e2-9e46-51410bc9daa5Program Evaluation 3.4.32008-10-012014-10-302012-10-03http://www.ftc.gov/opp/gpra/spfy09fy14.pdfOwenAmburOwen.Ambur@verizon.net