FY 2012 and 2013

Performance Plan
Tables 2 FY 2012 and 2013 Performance Plan

Budgeted Resources by Objective

($ in thousands)

Strategic Goal 1: Prevent fraud, deception, and unfair 

business practices in the marketplace

FY 2012 

FTE

FY 2012 

Amount

FY 2013 

FTE

FY 2013 

Amount

Objective 1.1: Identify fraud, deception, and unfair practices 

that cause the greatest consumer injury 92 $34,719 92 $34,909

Objective 1.2: Stop fraud, deception, unfairness and other 

unlawful practices through law enforcement 443 $110,687 447 $106,118

Objective 1.3: Prevent consumer injury through education 50 $15,086 50 $14,277

Objective 1.4: Enhance consumer welfare through research, 

reports, rulemaking, and advocacy 45 $11,360 45 $10,760

Objective 1.5: Protect 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 8 $3,900 8 $3,453

Total 638 $175,752 642 $169,517

Strategic Goal 2: Prevent anticompetitive mergers and other 

anticompetitive business practices in the marketplace

FY 2012 

FTE

FY 2012 

Amount

FY 2013 

FTE

FY 2013 

Amount

Objective 2.1: Take actions against anticompetitive mergers 

and practices that may cause significant consumer injury 481 $119,395 487 $115,152

Objective 2.2: Prevent consumer injury through education 26 $6,521 26 $6,204

Objective 2.3: Enhance consumer welfare through research, 

reports, and advocacy 19 $4,723 19 $4,501

Objective 2.4: Protect 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 12 $5,172 12 $4,626

Total 538 $135,811 544 $130,483

Protect Consumers

Maintain Competition
Tables 3 FY 2012 and 2013 Performance Plan

Objectives by FTE

($ in thousands)

Protect Consumers

Maintain Competition

Fiscal Year 2012 Fiscal Year 2013

Objective Number Total 

FTE

Objective Number Total 

1 2 3 4 5 1 2 3 4 5 FTE

Financial Practices 4 88 4 6 0 102 5 90 4 6 0 105

Privacy and Identity Protection 6 34 2 9 0 51 6 34 2 9 0 51

Marketing Practices 5 87 2 3 0 97 5 88 2 3 0 98

Advertising Practices 5 45 1 6 0 57 5 45 1 6 0 57

Enforcement 3 50 1 1 0 55 3 50 1 1 0 55

Planning and Information 39 8 3 0 0 50 39 8 3 0 0 50

Consumer and Business Education 0 0 20 1 0 21 0 0 20 1 0 21

Economic and Consumer 

Policy Analysis 1 1 1 3 0 6 0 1 1 3 0 5

Management 5 15 3 4 0 27 5 15 3 4 0 27

Support 24 115 13 12 8 172 24 116 13 12 8 173

Total 92 443 50 45 8 638 92 447 50 45 8 642

Fiscal Year 2012 Fiscal Year 2013

Objective Number Total 

FTE

Objective Number Total 

1 2 3 4 1 2 3 4 FTE

Premerger Notification 16 2 1 0 19 19 2 1 0 22

Merger and Joint Venture Enforcement 184 8 4 1 197 185 8 4 1 198

Merger and Joint Venture Compliance 9 1 1 0 11 8 1 1 0 10

Nonmerger Enforcement 127 5 3 1 136 128 5 3 1 137

Nonmerger Compliance 2 0 0 0 2 3 0 0 0 3

Antitrust Policy Analysis 3 1 3 0 7 3 1 3 0 7

Other Direct 16 2 2 0 20 16 2 2 0 20

Support 124 7 5 10 146 125 7 5 10 147

Total 481 26 19 12 538 487 26 19 12 544
Tables 4 FY 2012 and 2013 Performance Plan

Annual Performance Measures: Fiscal Years 2010 to 2013

FY 2010

Actual

FY 2011 

Actual

FY 2012 

Target

FY 2013 

Target

Strategic Goal 1 - Protect Consumers: Prevent fraud, deception, and unfair business practices in the 

marketplace.

Objective 1.1: Identify fraud, deception, and unfair practices that cause the greatest consumer 

injury:

Measure 1.1.1: Complaints collected 

and entered into the Consumer Sentinel 

Network database.

3.1 million 4.0 million 3.0 million* 3.0 million*

Key Measure 1.1.2: The percentage of the 

FTC’s consumer protection law enforcement actions that are the subject of consumer complaints to the FTC.

95.9% 80.4% 70%*

Measure 1.1.3: The rate of customer satisfaction with the FTC’s Consumer Response 

Center.

(a) For the website, 

exceeded average citizen 

satisfaction rate as published in the American 

Customer Satisfaction 

Index E-Government 

Satisfaction Index

(a) For the website, exceed 

average citizen satisfaction rate as published in 

the American Customer 

Satisfaction Index 

E-Government Satisfaction 

Index

(b) For the 

call center, 

met standards for 

call centers 

developed 

by the 

Citizen 

Service 

Levels 

Interagency 

Committee

(b) For the 

call center, 

exceeded 

standards 

for call 

centers developed by 

the Citizen 

Service 

Levels 

Interagency 

Committee

(b) For the call center, meet 

or exceed standards for 

call centers developed by 

the Citizen Service Levels 

Interagency Committee

Objective 1.2–Stop fraud, deception, unfairness, and other unlawful practices through law 

enforcement:

Key Measure 1.2.1: The percentage of all 

cases filed by the FTC that were successfully resolved through litigation, a settlement, 

or issuance of a default judgment.

99.2% 100% 80 to 90%*

Measure 1.2.2: The FTC’s effectiveness in 

stopping prohibited business practices in 

three high priority areas over the next five 

years.

N/A

Statistically significant 

decrease in the prevalence 

of the practice

Measure 1.2.3.: The percentage of redress 

cases in which the FTC distributes redress 

dollars designated for distribution to 

consumers within 6 months.

96% 100% 90%

* This target was increased as part of the FY 2012 Strategic Plan Addendum
Tables 5 FY 2012 and 2013 Performance Plan

FY 2010

Actual

FY 2011 

Actual

FY 2012 

Target

FY 2013 

Target

Measure 1.2.4: Investigations or cases 

in which the FTC obtains foreign-based 

evidence or engaged in mutual assistance 

that contributes to FTC law enforcement 

actions or in which we cooperate with 

foreign agencies and/or multilateral 

organizations.

39 53 30

Objective 1.3–Prevent consumer injury through education:

Measure 1.3.1: Consumer protection messages accessed online or in print. 43.9 million 41.4 million 50 million

Key Measure 1.3.2: Customer satisfaction 

rate with an FTC consumer education 

website or microsite.

Exceeded average citizen 

satisfaction rate as published in the American 

Customer Satisfaction 

Index E-Government 

Satisfaction Index

Exceed average citizen 

satisfaction rate as published in the American 

Customer Satisfaction 

Index E-Government 

Satisfaction Index

Measure 1.3.3: Organizations requesting 

consumer education publications. 15,375 14,818 12,000* 12,300*

Objective 1.4–Enhance consumer welfare through research, reports, rulemaking, and advocacy

Measure 1.4.1: Workshops and conferences 

convened or cosponsored that address consumer protection problems.11 14 8*

Measure 1.4.2: Advocacy comments and 

amicus briefs on consumer protection 

issues filed with entities including federal 

and state legislatures, agencies, or courts.

6 3 6

Measure 1.4.3: The percentage of respondents finding the FTC’s advocacy comments and amicus briefs “useful.”

100% 100% 75%*

Key Measure 1.4.4: The percentage of 

proposed Administrative Procedure Act 

(APA) rulemakings, conducted solely by 

the FTC, completed in 9 months of receipt 

of final comments in the Final Notice of 

Proposed Rulemaking.

100% 83.3% 75%

Objective 1.5-Protect American consumers in the global marketplace by providing sound policy and 

technical input to foreign governments and international organizations to promote sound consumer 

policy 

Key Measure 1.5.1: Policy advice provided to foreign consumer protection and 

privacy agencies, directly and through 

international organizations, through 

substantive consultations, written submissions, or comments.

64 52 60*

Measure 1.5.2: Technical assistance to 

foreign consumer protection and privacy 

authorities.

23 15 8
Tables 6 FY 2012 and 2013 Performance Plan

FY 2010

Actual

FY 2011 

Actual

FY 2012 

Target

FY 2013 

Target

Strategic Goal 2 - Maintain Competition: Prevent anticompetitive mergers and other anticompetitive 

business practices in the marketplace.

Objective 2.1–Take action against anticompetitive mergers and practices that may cause significant 

consumer injury

Key Measure 2.1.1: Actions to maintain 

competition including litigated victories, 

consent orders, abandoned transaction 

remedies, restructured transactions remedies, or fix-it-first transactions remedies 

in a significant percentage of substantial 

merger and nonmerger investigations.

40% 31.8% 40 to 60%

Measure 2.1.2: Consumer savings of at 

least $500 million through merger actions 

to maintain competition.

$586 

million

$531.5

million $500 million

Measure 2.1.3: Actions against mergers 

likely to harm competition in markets with 

at least $25 billion in sales. 

$22.5 billion $22.7 billion $25 billion

Measure 2.1.4: Consumer savings of at 

least six times the amount of FTC resources 

allocated to merger program.

1,670% 1,417.3% 1300%*

Measure 2.1.5: Consumer savings of at least 

$80 million through nonmerger actions 

taken to maintain competition.

$508 

million

$444.9

million $450 million*

Measure 2.1.6: Actions against anticompetitive conduct in markets with a total of at 

least $8 billion in annual sales.

$11.7 billion $11.6 billion $12 billion*

Measure 2.1.7: Consumer savings of at least 

four times the amount of FTC resources 

allocated to nonmerger program over a 

five-year period.

2,418% 1,917.7% 2000%*

Measure 2.1.8: 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.

100% 100% 90%

Annual Performance Measures: Fiscal Years 2010 to 2013

* This target was increased as part of the FY 2012 Strategic Plan Addendum
Tables 7 FY 2012 and 2013 Performance Plan

FY 2010

Actual

FY 2011 

Actual

FY 2012 

Target

FY 2013 

Target

Objective 2.2–Prevent consumer injury through education:

Key Measure 2.2.1: Competition resources 

accessed via the FTC’s website. 21.5 million 22.8 million 24 million*

Objective 2.3–Enhance consumer through research, reports, and advocacy:

Key Measure 2.3.1: Workshops, seminars, 

conferences, and hearings convened or 

cosponsored that involve significant 

competition-related issues.

6 4 4

Key Measure 2.3.2: Reports and studies 

issues on key competition related topics. 9 11 8

Key Measure 2.3.3: Advocacy comments 

and amicus briefs on competition issues 

filed with entities including federal and 

state legislatures, agencies or courts.

17 16 10*

Measure 2.3.4: The percentage of respondents finding the FTC’s advocacy comments and amicus briefs “useful.”

100% 100% 75%*

Measure 2.3.5: The volume of traffic on 

www.ftc.gov relating to competition 

research, reports, and advocacy.

2.2 million 1.8 million 1.7 million

Objective 2.4: Protect 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

Key Measure 2.4.1: Policy advice provided 

to foreign competition agencies, directly 

and through international organizations, 

through substantive consultations, written 

submissions, or comments.

76 112 60*

Measure 2.4.2: Technical assistance provided to foreign competition authorities. 60 27 10
Tables 8 FY 2012 and 2013 Performance Plan

FY 2010

Actual

FY 2011 

Actual

FY 2012 

Target

FY 2013 

Target

Strategic Goal 3 - Advance Performance: Advance the FTC’s performance through organizational, 

individual, and management excellence.

Objective 3.1: Provide effective human resources management

Measure 3.1.1: The extent employees believe their organizational culture promotes 

improvements in processes, products and 

services, and organizational outcomes.

Exceeded the governmentwide results on the 

Federal Human Capital 

Survey’s Results-Oriented 

Performance Culture Index

Exceed the governmentwide results on the 

Federal Human Capital 

Survey’s Results-Oriented 

Performance Culture Index

Key Measure 3.1.2: The extent employees 

think the organization has the talent necessary to achieve organizational goals.

Exceeded the governmentwide results on the Federal 

Human Capital Survey’s 

Talent Management Index

Exceed the governmentwide results on the Federal 

Human Capital Survey’s 

Talent Management Index

Objective 3.2–Provide effective infrastructure and security management

Key Measure 3.2.1: A favorable Continuity 

of Operations (COOP) rating. 85% 75% 75%

Key Measure 3.2.2: Availability of information technology systems. 99.77% 99.82% 99.0% 99.5%

Objective 3.3–Provide effective information resource management:

Key Measure 3.3.1: The percentage of 

Commission-approved documents in 

ongoing and newly initiated public FTC 

proceedings available via the Internet 

within 15 days of becoming part of the 

public record.

93.8% 82% 80%

Objective 3.4:Provide effective financial and acquisition management

Measure 3.4.1: Independent auditor’s 

financial statement audit results. Unqualified Unqualified

Key Measure 3.4.2: The percentage of 

Bureau/Offices that establish and maintain 

an effective, risk-based internal control 

environment.

100% 100%

Measure 3.4.3: Performance against the 

Small Business Administration’s government-wide small business procurement 

goals.

58.9% 46.3% 23%

Annual Performance Measures: Fiscal Years 2010 to 2013
Tables 9 FY 2012 and 2013 Performance Plan

Annual Performance Measures: Historical

FY 2007 

Actual

FY 2008

Actual

FY 2009 

Actual

Protect Consumers

Goal 1: Prevent fraud, deception, and unfair business practices in the marketplace.

Objective 1.1–Identify fraud, deception, and unfair practices that cause the greatest consumer injury

Measure 1.1.1: Collect and enter complaints and inquiries 

entered into the consumer database. 1,100,000 3,050,000 3,300,000

Measure 1.1.2: The percentage of the agency’s consumer protection law enforcement actions that are responsive to complaint 

information gathered by the agency.

76% 71% 79%

Objective 1.2–Stop fraud, deception, unfairness, and other unlawful practices through law 

enforcement

Measure 1.2.1: Stop economic injury to consumers each year 

through law enforcement.

$519 

million

$474 

million

$505 

million

Measure 1.2.2: Stop fraudulent, deceptive, unfair, and other unlawful practices by obtaining orders or conducting other direct 

interventions with businesses resulting in a change in business 

conduct.

137 132 _ _ _

Objective 1.3–Prevent consumer injury through education

Measure 1.3.1: Track consumer protection messages accessed 

online or in print. 47 million 49.2 million

43.1 

million

Measure 1.3.2: Track consumer protection messages related to 

identity theft, accessed online or in print.

9.6 

million

11.4 

million

10.1 

million

Measure 1.3.3: Track consumer protection messages in Spanish, 

accessed online or in print.

2.2 

million

2.0 

million

1.8 

million

Measure 1.3.4: Track (a) the number of times print media publish articles that refer to FTC consumer protection activities and 

(b) the circulation of media that publish those articles.

(a) 3,066 

articles 

(b) 863 

million 

circulation

(a) 3,100 

articles

(b) 791 

million 

circulation

(a) 2,484 

articles

(b) 702 

million 

circulation

Objective 1.4–Enhance consumer welfare through research, reports, advocacy, and international 

cooperation and exchange

Measure 1.4.1: Convene or participate substantially in workshops and conferences on novel or challenging consumer 

protection problems or issues.

10 16 9

Measure 1.4.2: Issue reports on novel or challenging consumer 

protection problems or issues. 8 12 14

Measure 1.4.3: File public and advocacy comments with other 

federal and state government agencies. 7 6 2

Measure 1.4.4: Cooperate with foreign government agencies on 

enforcement matters with cross-border components. 23 46 39

Measure 1.4.5: Provide consumer protection related policy or 

technical input to foreign government agencies or international 

organizations.

34 88 81
Tables 10 FY 2012 and 2013 Performance Plan

FY 2007

Actual

FY 2008 

Actual

FY 2009 

Actual

Maintain Competition

Goal 2: Prevent anticompetitive mergers and other anticompetitive business practices in the 

marketplace.

Objective 2.1–Identify anticompetitive mergers and practices that cause the greatest consumer 

injury

Measure 2.1.1: Achieve positive outcomes in matters in which 

HSR requests for additional information are issued. 100% 100% 100%

Measure 2.1.2: Percentage of significant nonmerger investigations that result in a positive outcome. 100% 100% 100%

Measure 2.1.3: Track the number of enforcement actions for the 

total mission, for the (a) merger and (b) nonmerger actions.

a) 22 

b) 11

a) 21 

b) 4

a) 19 

b) 7

Measure 2.1.4 Report the number of (a) second requests, (b) 

reportable transactions for which premerger notifications were 

received, (c) HSR investigations that resulted in enforcement 

action, (d) transactions in which antitrust issues were resolved 

through voluntary abandonment or restructuring because of 

FTC concerns, and (e) investigations closed because the evidence indicated that a competitive problem was unlikely.

a) 31

b) 

2,108

c) 20 

d) 5 

e) 11

a) 21

b)1,656 

c) 12 

d) 2 

e) 7

a) 15

b) 684

c) 13

d) 1 

e) 3

Measure 2.1.5: Track the number of significant nonmerger 

investigations closed each year, (a) with enforcement action and 

(b) without enforcement action.

a) 11 

b) 17

a) 4 

b) 14

a) 7

b) 27

Objective 2.2–Stop anticompetitive mergers and business practices through law enforcement

Measure 2.2.1: Positive result of cases brought by FTC due to 

alleged violations. 100% 96% 96%

Measure 2.2.2: Achieve savings for consumers through merger 

enforcement.

$805 

million

$360 

million

$791 

million

Measure 2.2.3: Take action against mergers likely to harm competition in markets with a total of at least $125 billion in sales 

over a five-year period; $25 billion in sales each year.

$ 42.6 

million

$14.9 

million

$22.3 

million

Measure 2.2.4: Achieve savings for consumers through nonmerger enforcement.$75 

million

$28 

million

$188 

million

Measure 2.2.5: Take action against anticompetitive conduct in 

markets with a total of at least $40 billion in annual sales over 

five-year period; $8 billion each year.

$2.6 

billion

$0.4 

billion

$14.6 

billion

Measure 2.2.6 Save consumers at least six times the amount of 

agency resources allocated to merger activity. 2,500% 1,121% 2,132%

Measure 2.2.7: Save consumers at least four times the amount of 

agency resources allocated to nonmerger enforcement activity. 424% 164% 1,035%

Annual Performance Measures: Historical
Tables 11 FY 2012 and 2013 Performance Plan

FY 2007

Actual

FY 2008 

Actual

FY 2009 

Actual

Objective 2.3–Prevent consumer injury through education

Measure 2.3.1: Quantify number of hits on antitrust information 

on FTC website.

15.7 

million

12.5 

million

11.9 

million

Measure 2.3.2: Track (a) the number of times print media publish articles that refer to FTC competition activities and (b) the 

circulation of the media that publish those articles.

(a) 2,982 

articles

(b) 635 

million 

(a) 1,858 

articles

(b) 397 

million

(a) 1,569 

articles

(b) 360 

million

Objective 2.4–Enhance consumer welfare through research, reports, advocacy, and international 

cooperation and exchange

Measure 2.4.1: Convene or participate substantially in workshops, conferences, seminars, and hearings involving significant 

competition-related issues.

7 5 8

Measure 2.4.2: Issue studies, reports, and working or issues 

papers on significant competition-related issues. 18 7 20

Measure 2.4.3: Make advocacy filings with other federal and 

state government agencies urging them to assess the competitive ramifications and costs and benefits to consumers of their 

policies.

11 12 10

Measure 2.4.4: Issue advisory opinions to persons seeking 

agency review of proposed business actions. 2 1 1

Measure 2.4.5: File amicus briefs with courts addressing competition-related issues. 4 1 2

Measure 2.4.6: Track the volume of traffic on ftc.gov relating 

to competition research, reports, advocacy, and international 

cooperation and exchange.

1.1 

million

1.2 

million

1.6 

million

Measure 2.4.7: Track the number of (a) cases on which the FTC 

cooperated with a foreign competition authority, (b) consultations with or comments to foreign competition authorities, (c) 

written submissions on international fora, (d) international 

events attended, and (e) leadership positions held by FTC staff 

in international competition organizations.

(a) 61

(b) 70 

(c) 19 

(d) 48

(e) 8

(a) 79

(b) 89 

(c) 30 

(d) 68 

(e) 9

(a) 87

(b) 56

(c) 19

(d)125

(e) 10

Protect Consumers 13 FY 2012 and 2013 Performance Plan

Strategic Goal 1: Protect Consumers

Prevent fraud, deception, and unfair business

practices in the marketplace

Objective 1.1: Identify fraud, deception, and unfair practices

that cause the greatest consumer injury

The 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 industry concerns, and engages in and encourages study of, and empirical research on, consumer protection topics.

To fulfill its goal of protecting consumers, 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 state and federal law enforcement agencies, Better Business Bureaus, and private entities. Further, the FTC maintains an 

electronic mailbox (spam@uce.gov) to which Internet users are encouraged to 

forward spam.
Protect Consumers 14 FY 2012 and 2013 Performance Plan

The agency makes consumer complaint data and other information available to 

other law enforcers through the secure website of the Consumer Sentinel Network, 

which is currently accessible to more than 2,000 law enforcement partner agencies 

worldwide. 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. 

Strategies

• Continue to upgrade and enhance the Consumer Sentinel Network.

• Expand the pool of entities that make their consumer complaint data available to the law enforcement community through the Consumer Sentinel 

Network. 

• Monitor the marketplace to identify illegal practices that may not be fully 

captured by the consumer complaint database, for example, through the FTC 

Internet Lab, Internet surfs, and consumer surveys.

• Make 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.

• Review current functions and determine what changes or upgrades to the 

Consumer Sentinel Network would be helpful. 

• Assess whether the FTC’s law enforcement and education efforts are addressing the leading areas identified by the consumer complaint information 

gathered by the agency. 

FY 2012 and FY 2013 Implementation Plan 

• Continue to upgrade and enhance the Consumer Sentinel Network to meet 

the increasing volume of consumer complaints, larger number of users, and 

increased demands on access to pertinent data, and maintain it as the premier 

consumer protection law enforcement complaint database.

• Recruit state, local, federal, and foreign law enforcement agencies to join the 

Consumer Sentinel Network and contribute complaint data, and train them to 

take full advantage of its features. 

• Improve the capacity to receive and integrate complaints from U.S. and 

foreign sources and facilitate the exchange of that data with law enforcement 

officials in the U.S. and other countries. 
Protect Consumers 15 FY 2012 and 2013 Performance Plan

• Encourage consumers to report fraud, identity theft, financial and Do Not 

Call Registry complaints by increasing public awareness of the complaint 

process. 

• Analyze the complaint data to identify enforcement targets and provide pertinent information to public and private sector partners. 

• Ensure the quality, security, and integrity of the Consumer Sentinel Network. 

• Coordinate with enforcement partners and other sources of case generation 

leads, and conduct test shopping, Internet surfs, and consumer surveys.

• Monitor national advertising in print, television, radio, and online to identify 

illegal practices that may not be captured fully by the complaint database. 

• Identify novel or challenging consumer protection problems. 

• Identify fraud targeting seniors through Consumer Sentinel Network complaints, reviewing “FTC Fraud Survey data,” and developing relationships 

with key organizations.

Performance Measures

• The number of complaints 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 collect 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.

Evaluations

• Assess the extent to which the consumer complaint and other information 

made available by the agency is used by its staff and law enforcement partners. The FTC reviews the complaint data and other information it collects to 

identify and target the most serious cases of fraud and deception and respond 
Protect Consumers 16 FY 2012 and 2013 Performance Plan

Objective 1.2: Stop fraud, deception, unfairness, and other 

unlawful practices through law enforcement

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.

• Assess security and integrity protections for the Consumer Sentinel Network 

and proposed enhancements to the database and evaluate the policies in 

place. 

The 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 brings enforcement actions via 

administrative proceedings.

Strategies

• Stop injury to consumers through aggressive law enforcement.

• Enforce consumer credit statutes and rules to protect consumers from deceptive lending practices, illegal credit practices, and unfair and deceptive mortgage loan practices.

• Challenge practices that threaten consumer privacy.

• Halt advertising and marketing practices that are most injurious to consumers or that prey on specific groups of vulnerable consumers.

• Target those individuals and corporations that violate federal court and administrative orders obtained by the FTC.

• Promote the criminal prosecution of the most egregious fraud violators 

through coordination with criminal law enforcement authorities. 
Protect Consumers 17 FY 2012 and 2013 Performance Plan

FY 2012 and 2013 Implementation Plan

• Target law enforcement toward violations that create the greatest risks to 

consumer health, safety, and economic well-being by reviewing complaints, 

evaluating practices in the marketplace, and monitoring industry data and 

other information.

• Focus on fraud causing serious consumer injury, including business opportunities and “get rich quick” investment schemes, prepaid phone cards, deceptive health insurance or medical discount programs, economic downturn and 

stimulus fraud, unfair and deceptive educational services and products, sham 

charities and charitable solicitations, and spam. 

• Stop financial fraud by targeting foreclosure “rescue” and loan modification 

scams; enforcing the debt relief services amendments to the Telemarketing 

Sales Rule; and targeting payday lenders, credit repair outfits, and other nontraditional creditors that are violating statutes the FTC enforces.

• Target unfair and deceptive mortgage advertising, servicing, and lending 

practices.

• Fight deceptive and abusive debt collection practices.

• Combat fraud affecting the poor and under-served communities, such as 

those offering income opportunities through jobs, investment, government 

grants, and other scams.

• Combat harmful practices by automobile dealers.

• Pursue enforcement action in cases in which companies have misrepresented 

their policies about the use of personal information they collect from consumers or failed to take appropriate steps to protect the security of personal 

information.

• Use law enforcement to promote better data security practices through enforcement of the Gramm-Leach-Bliley Act, the Fair Credit Reporting Act, and 

Section 5 of the FTC Act. 

• Administer and enforce the National Do Not Call Registry and associated 

rules. 

• Protect consumers from online and mobile threats, such asmobile spam, deceptive and unfair apps, and malware distributed through social networks.

• Promote compliance with consumer protection laws in the online and mobile 

marketplace. 
Protect Consumers 18 FY 2012 and 2013 Performance Plan

• Reduce deceptive marketing through “negative options” imposing unauthorized charges.

• Target deceptive advertising affecting consumers’ health and safety, focusing 

on disease prevention and treatment claims; claims aimed at baby boomers, 

seniors, and the uninsured; and claims exploiting emerging health threats.

• Pursue enforcement action involving deceptive environmental and energy 

claims .

• Target the “gatekeepers” and facilitators that make fraud possible.

• Aggressively combat fraud against Latino consumers through the FTC’s 

Hispanic Outreach and Law Enforcement Initiative, and pursue additional 

outreach to African-American consumers.

• Address an expected increase in fraud targeting older Americans and those 

affected by the economic downturn.

• Monitor and enforce compliance with federal court and administrative 

orders.

• Train FTC staff to improve investigative and litigation skills through formal 

activities that teach best practices used in government and private industry. 

• Increase the FTC’s capacity to respond rapidly to fast-moving technologybased scams by enhancing the Internet Lab with mobile devices and increasing tech-savvy litigation support. 

• Leverage FTC enforcement resources by recruiting, supporting, and coordinating local, state, federal, and international law enforcement partners for 

initiatives and sweeps. 

• Work with criminal prosecutors and investigators to promote criminal 

prosecution of FTC fraud defendants and those who assist their deceptive 

practices. 

• Distribute redress dollars to consumers in a timely manner.

• Actively cooperate with foreign counterparts on consumer protection matters. 

• Seek an extension of the Undertaking Spam, Spyware, And Fraud 

Enforcement With Enforcers Beyond Borders (U.S. SAFE WEB) Act of 2006, 

which is scheduled to expire in December 2013.
Protect Consumers 19 FY 2012 and 2013 Performance Plan

• Continue to create and sustain international partnerships and networks to 

pursue matters involving foreign defendants, evidence, and assets, using the 

tools provided by the U.S. SAFE WEB Act. 

• Expand the FTC’s partnership with the DOJ Office of Foreign Litigation in 

the Civil Division and DOJ’s Office of International Affairs in the Criminal 

Division to develop evidence for cases with international components and 

pursue foreign assets for consumer redress. 

• Increase the FTC’s forensic accounting capabilities to analyze financial documents and structure monetary settlements.

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, challenging, or precedent-setting cases when appropriate, including cases that raise novel 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 of Consumer Protection 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 U.S. SAFE WEB Act of 2006 to achieve 

the objective.
Protect Consumers 20 FY 2012 and 2013 Performance Plan

Objective 1.3: Prevent consumer injury through education

Evaluations

Evaluate 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.

Consumer 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. The agency 

also 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 underserved 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.

Strategies

• Focus consumer and business education efforts on areas where fraud, deception, unfair practices, and information gaps cause the greatest injury. 

• Leverage resources (by working with federal, state, local, international, and 

private sector partners) to maximize the reach of consumer and business 

education campaigns.

• Target particular demographic groups with messages about marketplace issues that impact their health, safety, and economic well-being.

FY 2012 and FY 2013 Implementation Plan

• Deliver efficiently and effectively educational information in English and 

Spanish to consumers, industry members, and law enforcement partners 

on how to prevent consumer injury, avoid unlawful business practices, and 

enhance consumer welfare. 

• Focus on key strategic areas – financial services, health and safety, identity 

theft, mobile, new technologies, green advertising, negative option market-
Protect Consumers 21 FY 2012 and 2013 Performance Plan

ing, telemarketing fraud, Do Not Call, affiliate marketing, immigration fraud, 

and financial issues/expenses (including funerals).

• Continue education programs to meet the demand for information about 

significant events in the marketplace, such as scams targeting consumers 

affected by the economic downturn, and directing outreach to financially 

distressed consumers. 

• Monitor, review, and provide guidance to parents and children on marketing 

that may affect children and teenagers. 

• Find new and creative ways to reach consumers with information about 

marketplace issues that can cause them financial injury and to reach businesses with information that increases knowledge about consumer risks and 

compliance.

• Build partnerships with industry and advocacy organizations to distribute 

publications and lead more visitors to the FTC’s website (www.ftc.gov) 

and to other issue-oriented websites developed by the FTC such as, www.

DoNotCall.gov, www.OnGuardOnLine.gov, and www.DontServeTeens.gov.

• Build relationships with international organizations to educate consumers 

and businesses about cross-border consumer protection issues. 

• Increase media coverage to broadcast the agency’s education message to a 

broader audience.

• Tailor messages to different groups and populations, including Latino and 

African-American consumers.

• Highlight fraud commonly affecting seniors through consumer education.

• Use different media to enhance outreach (webinars, tutorials, videos, blogs, 

articles, podcasts) and update the FTC’s presence on the web, mobile, and 

other platforms.

• Develop education projects with state and local partner agencies to allow 

states and the FTC to benefit from comparative advantages enjoyed by the 

other and provide consumers with a level of service that neither working 

alone could provide. 

• Educate media and advertising companies on rules-of-the-road for 

advertising. 
Protect Consumers 22 FY 2012 and 2013 Performance Plan

• Conduct outreach to businesses that engage in word-of-mouth, mobile, and 

affiliate marketing, stressing that existing advertising principles (including 

revised Endorsement Guides) apply to new media and methods of marketing.

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. 

Evaluations

• Measure 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.

• Assess 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.

• Assess the range of public and private sector organizations that partner with 

the FTC on outreach.

• Determine 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.

• Review the focus of FTC education efforts and adjust them based on changing 

consumer and business needs.

• Continue to assess and address the consumer information needs of the 

Hispanic, African-American, and elderly populations.
Protect Consumers 23 FY 2012 and 2013 Performance Plan

Objective 1.4: Enhance consumer protection through 

research, reports, rulemaking, and advocacy

The 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 

highlight the role of consumer and empirical research in their decision making and 

promote the interests of consumers. The agency regularly testifies before Congress 

on consumer protection issues. The FTC also files amicus briefs to aid courts’ considerations of consumer protection issues. 

Strategies

• Focus workshops and conferences on emerging or challenging consumer protection problems, especially those related to new technologies and financial 

concerns. 

• Issue reports mandated by law and other reports that articulate concrete 

measures that the public and private sectors can take to address consumer 

protection problems, particularly those related to new technologies or financial concerns.

• Continue to enhance the agency’s Regulatory Review Program and update, 

rescind, or promulgate trade regulation rules and other agency rules in response to regulatory reviews, Congressional mandates, and emerging consumer protection issues.

• Target advocacy activities to encourage state, federal, and foreign government policymakers to evaluate both the costs and benefits of their policies for 

consumers. 

• Use letters and public comments to urge state, federal, and foreign governments to consider consumer research and other empirical data regarding the 

costs and benefits of their policies for consumers.

FY 2012 and 2013 Implementation Plan

• Convene and co-sponsor workshops and conferences and issue reports, 

including those required by law, on emerging or challenging consumer pro-
Protect Consumers 24 FY 2012 and 2013 Performance Plan

tection problems, such as malware and spyware threats to mobile devices and 

face recognition technology.

• Study new technologies to enable the FTC to take a lead role in addressing 

the privacy, security, and other risks of consumer harm associated with the 

technologies. Promote stronger privacy protections through policy initiatives, 

issue a final report on protecting consumer privacy, participate in interagency 

groups, provide technical assistance to Congress on draft legislation, and 

participate in international privacy events, develop international frameworks 

and enforcement cooperation agreements. In rulemakings, evaluate the regulatory effect on industry, consumers, and other parties, invite public comment, coordinate with other agencies, and promulgate rules accordingly. 

• Complete the Children’s Online Privacy Protection Act (COPPA) Rule review 

and the review of the FTC Guides for the Use of Environmental Marketing 

Claims, among others.

• Review public comments regarding the FTC’s Regulatory Review Program 

and make changes as appropriate to improve effectiveness.

• Review Rules/Guides scheduled to be reviewed under the 10-year 

Regulatory Review Program and consider ways to reduce the compliance 

burden while maintaining important protections.

• Analyze federal and state government policies and identify those that impose 

costs on consumers that may exceed their benefits to consumers, especially 

policies that affect the dissemination of truthful, non-misleading information 

to consumers. 

• File comments or otherwise engage in advocacy with state, federal, and 

foreign governments that evaluate both the costs and benefits of proposed 

policies on consumers, with a particular emphasis on the role of consumer 

research and other empirical data in their policy development, and an awareness of the intersection of competition and consumer protection concerns.

• Publicize advocacy comments to increase public awareness of consumer 

protection problems and solutions. 

• File amicus briefs urging adoption of legal principles that promote consumer 

welfare. 

• Present major policy speeches that discuss emerging or challenging consumer 

protection problems and explain the FTC’s approach to them. 
Protect Consumers 25 FY 2012 and 2013 Performance Plan

• Further the FTC’s Congressionally-endorsed efforts to promote industry selfregulation in the marketing of entertainment and food to children.

Performance Measures

• Workshops and conferences convened or co-sponsored 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. 

Evaluations

•	 Evaluate 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.

•	 Assess whether industry gives weight to the FTC’s evaluation, monitoring, and 

advocacy and whether market interests are affected. 
Protect Consumers 26 FY 2012 and 2013 Performance Plan

Objective 1.5: Protect American consumers in the global 

marketplace by providing sound policy and technical input to 

foreign governments and international organizations to promote 

sound consumer policy

The FTC increasingly works around the globe to address new and emerging consumer protection and privacy challenges and concerns. Numerous issues, including 

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. The FTC 

addresses these challenges with a broad-based international program that strives to 

develop a global marketplace that provides consumers with consistent and effective protections and that helps foreign governments and international organizations improve their capacity to develop and implement sound consumer protection 

policies.

Strategies

• Pursue the development of an international consumer protection and privacy 

model that focuses on protecting consumers while maximizing economic 

benefit and consumer choice. 

• Focus on understanding cutting-edge issues in technology and globalization 

that present challenges to American consumer interests. 

• Influence policy development and implementation by advising multilateral 

organizations, regional entities, and foreign government agencies through 

substantive consultations and written comments. 

• Provide technical assistance to newer consumer protection and privacy agencies to enhance their ability to apply sound consumer protection and privacy 

policies.

FY 2012 and 2013 Implementation Plan

• Engage through the Organization for Economic Cooperation and 

Development (OECD) to develop the next generation of policy principles in 

the area of consumer protection and electronic commerce on issues such as 

emerging online and mobile payments systems, digital content products, and 

interactive digital media.
Protect Consumers 27 FY 2012 and 2013 Performance Plan

• Work with international partners to strengthen cooperation among enforcement partners, including through new initiatives with foreign criminal 

authorities.

• Seek to finalize the Asia-Pacific Economic Cooperation (APEC) cross-border 

data privacy rules project.

• Consult with international authorities on developing new approaches to 

privacy and cross-border data transfers through the OECD and other international organizations.

• Continue to build and expand a robust consumer protection and privacy 

technical assistance program for newer consumer protection agencies.

• Further develop the International Fellows, intern, and international staff 

exchange programs. 

 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.

Program Evaluations

• 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. 

• Evaluate completed technical assistance missions to determine, from the 

perspective of participants and their managers, whether the assistance was 

deemed valuable.

Maintain Competition 29 FY 2012 and 2013 Performance Plan

Strategic Goal 2: Maintain Competition 

Prevent anticompetitive mergers and other anticompetitive 

business practices in the marketplace

Objective 2.1: Take action against anticompetitive mergers

and practices that may cause significant consumer injury

The 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 to stop anticompetitive conduct and mergers 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).
Maintain Competition 30 FY 2012 and 2013 Performance Plan

Strategies

• Make efficient use of the initial period after HSR filings to determine whether 

a more detailed investigation is needed to assess whether a merger is likely to 

harm competition.

• Use 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.

• Use and improve existing techniques for identifying potentially anticompetitive business practices, such as monitoring the trade press, responding to and 

following up on case leads by Congressional offices, other Executive Branch 

agencies, state and local governments, and potentially aggrieved parties. 

• When 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.

• Negotiate consent orders and win litigated orders that have significant remedial, precedential, and deterrent effects and ensure that administrative litigation and adjudication reach a timely resolution.

• Continue to seek improvements in both the substantive aspects of remedies, 

as well as the process by which they are derived.

• Monitor and enforce compliance with consent decrees and orders and monitor and enforce compliance with HSR reporting obligations.

FY 2012 and FY 2013 Implementation Plan

• Resolve anticompetitive mergers and practices, where possible, by negotiating consent orders that secure relief with significant remedial, precedential, 

and deterrent effects without the need for litigation.

• Challenge anticompetitive mergers and business practices in federal court or 

through administrative litigation, and obtain relief with significant remedial, 

precedential, and deterrent effects. 

• Continue effective administration of the review of nonmerger practices so 

that the FTC may investigate those that raise potentially significant competitive issues.

• Employ integrated teams of lawyers, economists, and other professionals to 

conduct an economically sound, fact-based analysis of mergers and other 

potentially anticompetitive business practices. 
Maintain Competition 31 FY 2012 and 2013 Performance Plan

• Continue to improve the investigative skills and antitrust analysis training 

programs and continue to improve negotiation and litigation skills and refine 

investigative and decisional tools through continuous learning and identification of “best practices.”

• Retain outside experts and consultants in relevant fields of expertise, as 

needed, when enforcement outcomes would be enhanced by specialized 

supplementary resources. 

• Work 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.

• Expedite the investigatory process including possible revisions to Part 2 of 

the FTC Rules of Practice. 

• Assess whether revisions to the enforcement guidelines are required. 

• Apply the merger process reforms to conduct investigations more efficiently, 

and continue to assess areas where improvements can be implemented in order to enhance enforcement outcomes while minimizing burdens on business. 

• Continue to integrate e-government initiatives into mission activities.

• Apply the results of hearings, conferences, reports, studies, and workshops 

on significant competition issues to FTC case generation, investigation, and 

enforcement practices. 

• Continue to monitor implementation of divestitures and other requirements 

of the FTC’s merger consent orders. Seek civil penalties where appropriate if 

a respondent fails to fulfill its obligations under an order in a timely fashion.

• Improve the integration of budget and performance by linking goals and 

objectives to results; develop improved processes for use and analysis of 

management data.

• Collect data, for management review, regarding the FTC’s efficiency in conducting investigations, such as the amount of time required to complete the 

HSR review process, the number of HSR matters requiring issuance of an 

investigative second request, the number of HSR and significant nonmerger 

investigations that result in enforcement action, the number of hours of staff 

time spent on investigations, and other costs associated with investigations.
Maintain Competition 32 FY 2012 and 2013 Performance Plan

*

External factors may cause the results to fluctuate significantly from year to year. As a result, the agency’s 

performance for these measures will be assessed each year by calculating the average of current year plus the 

previous four years.

Performance Measures

• Actions to maintain competition, including litigated victories, consent orders, 

abandoned, restructured, or fix-it-first transactions in a significant percentage 

of substantial merger and nonmerger investigations.

» Filed Preliminary Injunctions or Permanent Injunctions, administrative 

litigations that are still pending, and abandoned, restructured, and fix-itfirst enforcement actions that occurred without a second request or compulsory process are not included in “actions.”

» “Significant percentage” refers to the 40 to 60 percent target.

» “Substantial investigation” includes, for merger investigations, second 

request, and compulsory process investigations. 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 13 times the amount of FTC resources allocated 

to the merger program. *

• Consumer savings of at least $450 million through nonmerger actions taken 

to maintain competition.*

• Actions against anticompetitive conduct in markets with a total of at least $12 

billion in annual sales.*

• Consumer savings of at least twenty times the amount of FTC resources allocated to the 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 
Maintain Competition 33 FY 2012 and 2013 Performance Plan

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 case-specific 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. 

Evaluations

• Assess 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.

• Determine 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.

• Compare the likely impact in these markets to the resources spent on the 

mission.

• Assess 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.

• Determine whether the total volume of commerce in such markets is likely 

to reach $128 billion and determine whether the level of consumer savings is 

likely to reach $450 million.
Maintain Competition 34 FY 2012 and 2013 Performance Plan

Objective 2.2: Prevent consumer injury through education

• Compare the likely impact in these markets to the resources spent on the 

mission.

• Assess qualitatively the deterrence value and precedential significance of the 

enforcement actions brought during each year.

• Evaluate litigation performance for lessons that may be applicable to future 

litigation.

• Assess 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.

• Assess 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.

• Assess the FTC’s efficiency in conducting antitrust investigations, explore 

ways to increase efficient use of investigatory resources and reduce burdens 

on business including through international cooperation mechanisms, and 

explore whether efficiency in conducting investigations can more meaningfully be measured.

Educating 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 and also encourages cooperation with the FTC’s investigations and enforcement actions.

Strategies

• Educate consumers and businesses about antitrust issues through traditional 

means such as guidelines, advisory opinions, reports, articles in professional 
Maintain Competition 35 FY 2012 and 2013 Performance Plan

or other publications, speeches, and participation in professional organizations as well as through the FTC website, emails, and in press releases.

• Engage in outreach to lay groups and other stakeholders to provide information about the work of the FTC and basic principles of economics and 

competition.

• Engage in outreach to foreign competition agencies to facilitate the agency’s 

efforts to promote convergence toward sound consumer-welfare-based competition enforcement and policy.

FY 2012 and FY 2013 Implementation Plan

• Monitor the content of complaints, press releases, and analyses to aid public 

comment to ensure they 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. 

• Expand 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. 

• Issue guidance to help businesses understand and comply with the application of the antitrust laws in certain areas, such as horizontal mergers, international operations, intellectual property, and health care. 

• Continue to provide Commission and staff advisory opinions on various 

competition issues; continue to provide guidance in response to informal 

requests, particularly concerning HSR matters.

• Publish guidance issued by the FTC, including written releases, texts of 

speeches, Bureau of Economics reports, and other materials that explain the 

FTC’s policies and procedures on the FTC website. 

• Seek the participation of businesses and consumer groups in conferences, 

workshops, and hearings and continue to disseminate the materials relating 

to these events, including transcripts, written submissions, and reports.

• Continue to have Commissioners and staff speak at and participate in seminars, panel discussions, and conferences to explain how the FTC analyzes 

mergers and other business practices. 

• When opportunities arise, engage in outreach to lay groups to provide information about the work of the FTC and basic principles of economics and 

competition.
Maintain Competition 36 FY 2012 and 2013 Performance Plan

Objective 2.3: Enhance consumer benefit through 

research, reports, and advocacy

• Engage in outreach to foreign competition authorities, practitioners, and 

international competition organizations.

• Develop and implement increasingly sophisticated web metric and analytical tools that will allow for a more accurate and representative view of the 

volume of traffic on the FTC’s antitrust related webpages. Monitor the results 

generated by the new web metric applications and, where necessary, make 

adjustments to the corresponding target.

Performance Measure

• Competition resources accessed via the FTC’s website.

Evaluations

• Evaluate what antitrust content on the FTC website generates the largest 

amount of public interest, and why, and use this information in setting future 

priorities.

• Seek input from consumer groups, business groups, bar groups, international 

competition organizations, and other FTC “customers” on the effectiveness of 

FTC educational efforts.

• Evaluate the transparency of FTC merger review policy by assessing the 

extent to which significant changes in such policy are communicated to 

stakeholders. 

In addition to its enforcement authority, the FTC has the unique jurisdiction to 

gather, analyze, and disseminate 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 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 enforce-
Maintain Competition 37 FY 2012 and 2013 Performance Plan

ment 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. 

Strategies

• Conduct public hearings, conferences, and workshops that bring together 

interested parties to enhance understanding of various practices and developments in the marketplace.

• Conduct studies as requested by Congress and other studies as appropriate.

• Conduct 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.

• Target 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.

• File 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.

FY 2012 and FY 2013 Implementation Plan

• Conduct hearings, conferences, and workshops on significant competition 

issues. 

• Continue to support outreach efforts to international bodies and foreign 

agency officials and practitioners to explain U.S. antitrust perspectives on 

competition theories and approaches, participate in dialogue with competition authorities of other countries and international organizations on transnational competition issues that affect American consumers and businesses, 

continue to aid young competition regimes with the development of antitrust 

laws and policies by designing and conducting technical assistance programs.

• File comments or otherwise engage in advocacy with state, federal, and 

foreign government policymakers to encourage them to adopt policies that 
Maintain Competition 38 FY 2012 and 2013 Performance Plan

maximize consumer welfare by evaluating both the costs and the benefits of 

their policies for consumers. 

• Prepare amicus briefs addressing important competition policy issues under 

consideration in court proceedings. 

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.

Evaluations

• Include 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.

• Seek 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.

• Evaluate 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.

• Assess whether the recipients of these comments give weight to the views expressed in these comments in making policy decisions that affect consumers.
Maintain Competition 39 FY 2012 and 2013 Performance Plan

The FTC continues to build cooperative relationships with foreign antitrust agencies to ensure close collaboration on cross-border cases and convergence toward 

sound competition policies and practices. 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. 

Strategies

• Pursue the development of an international market-based competition model 

that focuses on the maximization of consumer benefit.

• Influence policy development and implementation through multilateral organizations and bilateral relations. 

• Provide technical assistance to newer competition agencies to enhance their 

ability to apply sound competition policies.

FY 2012 and FY 2013 Implementation Plan

• Maintain the FTC leadership role in the International Competition Network, 

including through participating in substantive groups on unilateral conduct, 

merger procedures, the online curriculum project, and the Steering Group.

• Enhance our participation in other key multilateral and regional fora, including OECD, UNCTAD, and APEC. 

• Advance cooperation and convergence with foreign competition agencies by 

further improving cooperation in merger matters and on single firm conduct 

policy and enforcement, including through leadership on multilateral initiatives to promote cooperation and convergence. 

• Strengthen relations with the Chinese and Indian competition agencies 

through dialogue on legislative initiatives and case cooperation as appropriate, and the provision of technical assistance.

Objective 2.4: Protect 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
Maintain Competition 40 FY 2012 and 2013 Performance Plan

• Work with other US agencies in intergovernmental fora that address competition issues. 

• Maintain and improve the FTC technical assistance program.

• Maintain and improve the International Fellows and exchange programs. 

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.

Program Evaluations

• 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. 

• Evaluate completed technical assistance missions to determine, from the 

perspective of participants and their managers, whether the assistance was 

deemed valuable.
Advance Performance 41 FY 2012 and 2013 Performance Plan

Strategic Goal 3: Advance Performance

Advance the FTC’s performance through organizational, 

individual, and management excellence

Objective 3.1: Provide effective human resources management

The 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.

This objective is aligned with our Human Capital Plan, which 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.
Advance Performance 42 FY 2012 and 2013 Performance Plan

Strategies

• Implement programs and processes that will enable the agency to quickly 

recruit, develop, and retain a qualified, diverse workforce through an integrated workforce plan.

• Use the integrated workforce plan to identify and fulfill current and future 

human resources needs to carry out the mission. 

• Create an agency-wide performance culture focused on individual and organizational accountability toward the achievement of the FTC’s programmatic 

goals and priorities.

• Implement 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.

• Provide human resources management training and outreach to staff.

• Support 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.

FY 2012 and FY 2013 Implementation Plan

• Promote and expand the use of human resources flexibilities throughout the 

FTC. 

• Use innovative ways to reach out to managers, supervisors, and employees 

on human resources issues. 

• Identify and implement business process improvements through effective use 

of technology to facilitate FTC’s human resources. 

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 
Advance Performance 43 FY 2012 and 2013 Performance Plan

Objective 3.2: Provide effective infrastructure

and security management

outcomes and the extent the FTC has the right talent in the right positions at the 

right time to carryout the mission. 

Program Evaluations

• Assess 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. 

• Review current programs and processes, identify what changes would be 

helpful, and implement those changes.

This 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.

Strategies

• Promote staff awareness by regularly participating in COOP testing.

• Continue incorporating best practices and gleaning knowledge from FEMA 

staff.

• Determine, in cooperation with GSA, best space usage alternatives, including 

identifying a new site for staff currently housed at the New Jersey Avenue 

and 1800 M Street buildings in Washington, DC.

• Continue to take advantage of cost-effective IT solutions.
Advance Performance 44 FY 2012 and 2013 Performance Plan

• Increase internal network performance auditing and monitoring.

• Inform and educate customers within the agency about IT systems vulnerabilities and/or unusual network activity.

• Provide annual information security and privacy awareness training and 

outreach to staff.

• Ensure that staff has continued access to current, authoritative reference 

materials in FTC mission areas.

FY 2012 and FY 2013 Implementation Plan

• Evaluate COOP rating and determine support requirements.

• Continue partnership with GSA leasing specialists.

• Research alternatives such as telework participation, job sharing, and housing 

staff off-site.

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.

Program Evaluations

• Assess COOP funding against results, determine further staffing requirements, and determine cost to further maintain the program.

• Collect feedback from GSA Tenant Surveys and from FTC staff.

• Perform periodic reviews of the percentage of utilized space.
Advance Performance 45 FY 2012 and 2013 Performance Plan

Objective 3.3: Provide effective 

information resources management

The 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.

Strategies

• Implement 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).

• Utilize an electronic document management system (EDMS) to house work 

product and official records. 

• Identify and implement business process improvements through effective use 

of technology.

• Develop and implement additional information management policies and 

procedures.

• Provide information and records management training and outreach to staff.

FY 2012 and FY 2013 Implementation Plan

• Promote and expand the use of the EDMS to house work product and official 

records. 

• Identify and implement business process improvements through effective use 

of technology to facilitate the Commission’s decision making processes and 

its management of cases. 

• Promote the use of web-based e-filing of public comments in FTC rulemakings and other proceedings which seek public comments, to facilitate public 

participation and web posting of comments. 

• Promote the use of web-based e-filing in FTC adjudicative proceedings under Part 3 of the Rules of Practice, to facilitate filing by participants in those 

proceedings and web posting of public filings. 
Advance Performance 46 FY 2012 and 2013 Performance Plan

Objective 3.4: Provide effective 

financial and acquisition management

• Provide information and records management training and outreach to staff, 

with special emphasis on managing information electronically throughout its 

lifecycle.

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.

Program Evaluations

• Assess whether particular e-file structures are appropriate for organizing 

various types of information.

• Review the means by which FTC maintains and monitors access restrictions 

to sensitive electronic files.

• Assess training needs.

Resource 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 area 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.
Advance Performance 47 FY 2012 and 2013 Performance Plan

Strategies

• Integrate disparate systems with the agency’s core financial system. 

• Align resources to strategic priorities and outcomes so we will be focused on 

our most important tasks and programs.

• Enhance the internal control environment through developing and maintaining appropriate guidance and training for all staff. 

• Implement the best business solutions to accomplish our goals through 

world-class acquisition and business processes.

• Cooperate with the Office of Inspector General on audits and investigations 

of FTC programs and operations. 

FY 2012 and FY 2013 Implementation Plan

• Enhance the reporting capabilities within the integrated financial system to 

provide timelier, more accurate, and more reliable financial information to 

agency decision makers.

• Document improved processes and policies for financial and acquisition management that promote integrity, transparency, efficiency, and effectiveness.

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.
Advance Performance 48 FY 2012 and 2013 Performance Plan

Program Evaluations

• Assess internal administrative and programmatic operations to address areas 

that need improvement.

• Assess our acquisition procedures to see if federal regulations and standards 

are met and that contracting officer’s representatives (CORs) meet mandatory 

training requirements.

• Review financial and feeder system implementation goals to ensure that user 

needs and federal standards and requirements are met.