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U.S. PIRG Education Fund on Feb. 7, 2024 submitted comments on a new rule proposed by the Federal Trade Commission to address “Unfair or Deceptive Fees” meaning Junk Fees. (NPRM, R207011.)
OUR KEY POINTS
PIRG for years has believed regulators should ban fees for goods or services that:
- Aren’t transparent because they’re not disclosed up front, or are added along the way (drip-pricing) or are sprung on a consumer at the end of a transaction.
- Aren’t transparent in name or description or, if required by a third party, don’t indicate who that third party is.
- Are optional, unless the consumer affirmatively selects it (opts in rather than opts out.)
- Are buried deep in fine print.
We feel strongly that the price a customer will pay should be disclosed up front in the Total Price, and include a breakdown of the mandatory fees within that Total Price for consumers who want details of fees. But the Total Price should be provided first and with the most prominence. Businesses must not be allowed to confuse consumers with a barrage of numbers.
In disclosing the Total Price and any mandatory or optional fees, companies must:
- Be transparent about whether a fee is mandatory.
- Be transparent about the purpose of the fee.
- Be transparent about who will receive that fee.
Our full comments submission is available here.
Consumer Watchdog, U.S. PIRG Education Fund
Teresa directs the Consumer Watchdog office, which looks out for consumers’ health, safety and financial security. Previously, she worked as a journalist covering consumer issues and personal finance for two decades for Ohio’s largest daily newspaper. She received dozens of state and national journalism awards, including Best Columnist in Ohio, a National Headliner Award for coverage of the 2008-09 financial crisis, and a journalism public service award for exposing improper billing practices by Verizon that affected 15 million customers nationwide. Teresa and her husband live in Greater Cleveland and have two sons. She enjoys biking, house projects and music, and serves on her church missions team and stewardship board.
Senior Director, Federal Consumer Program, U.S. PIRG Education Fund
Ed oversees U.S. PIRG’s federal consumer program, helping to lead national efforts to improve consumer credit reporting laws, identity theft protections, product safety regulations and more. Ed is co-founder and continuing leader of the coalition, Americans For Financial Reform, which fought for the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, including as its centerpiece the Consumer Financial Protection Bureau. He was awarded the Consumer Federation of America's Esther Peterson Consumer Service Award in 2006, Privacy International's Brandeis Award in 2003, and numerous annual "Top Lobbyist" awards from The Hill and other outlets. Ed lives in Virginia, and on weekends he enjoys biking with friends on the many local bicycle trails.