FTC Procedures Manual 2021

In response to our FOIA requests, an administrative appeal, and repeated follow-up over six months, the FTC finally released its internal Procedures Manual, albeit with redactions. The FTC’s secretive internal procedures became especially important in the wake of revelations that a former Commissioner had cast “zombie votes” for the FTC to rely on following his departure. With its tremendous powers and responsibilities, the FTC should be transparent about how it operates so it can be held accountable—which we plan to do!

Click here for Bloomberg’s Leah Nylen’s twitter thread that recaps the timeline of the Chamber’s FOIA fight.


On November 19, 2021, the Chamber filed a FOIA request with the FTC asking for a copy of their voting procedures.  The FTC responded by releasing a zombie votes document from 1984 and excerpts from the 1994 edition of the “Office of the Secretary Procedures Manual.”

On December 2, 2021, the Chamber filed another FOIA request for the entirety of the updated and current “Office of the Secretary Procedures Manual.”  In response to that request, the FTC provided us with the March 2021 version, which included a number of redactions.