Letter to FTC to Extend Comment Deadline

Re: Request for Extension of Time to File Comments, Federal Trade Commission; Advance Notice of Proposed Rulemaking for Trade Regulation Rule on Commercial Surveillance and Data Security; 87 Fed. Reg. 51273; Docket ID No. 2022-17752 (August 22, 2022)

To Whom It May Concern:

The undersigned organizations request that the Federal Trade Commission (“FTC”) extend the deadline for filing comments on the Advance Notice of Proposed Rulemaking for Trade Regulation Rule on Commercial Surveillance and Data Security (“ANPR”) that was published in the Federal Register on August 22, 2022. The ANPR seeks to develop a record to establish a rule that would fundamentally alter the modern economy. As such, the FTC should base the development of a proposed rule on the highest quality and most complete record possible. Specifically, we request a 60-day extension of the comment deadline from October 21, 2022 to December 20, 2022.

Additional time would permit the undersigned organizations to understand and evaluate more thoroughly the voluminous number of questions and considerations put forth by the FTC. The ANPR seeks information, research, and experiential data about almost all aspects of the modern data-driven economy, and it does so through a procedure the FTC has rarely used for such an expansive and vaguely defined purpose. More time is required for all stakeholders, including the undersigned organizations, to provide the detailed comments and information that the FTC is requesting, including comments on the various economic impacts of a potential regulation, the multiple alternatives available to the FTC, and the significant (and potentially negative) downstream impacts of sweeping regulations on commercial data practices for consumers, businesses, and the American economy.


American Advertising Federation
American Escrow Association
Association of Test Publishers
Association of Washington Business
Business Roundtable
Consumer Data Industry Association
Council for Responsible Nutrition
FMI-Food Marketing Association
Insights Association
National Association of Federally-Insured Credit Unions
National Business Coalition on E-Commerce & Privacy
Privacy for America
Real Estate Service Providers Council
Retail Industry Leaders Association
Security Industry Association
Software & Information Industry Association
The 4As
U.S. Chamber of Commerce