Performance Plan
Performance Plan 40 FYs 2014 and 2015

Budgeted Resources by Objective

($ in thousands)

Strategic Goal 1: Protect Consumers FY 2014 

FTE

FY 2014 

Amount

FY 2015 

FTE

FY 2015 

Amount

Objective 1.1: Identify and take actions to address deceptive 

or unfair practices that harm consumers. 508 $133,212 508 $131,275

Objective 1.2: Provide the public with knowledge and tools 

to prevent harm to consumers. 97 25,448 97 25,101

Objective 1.3: Collaborate with domestic and international 

partners to enhance consumer protection. 33 9,837 33 9,503

Total 638 $168,497 638 $165,879

Strategic Goal 2: Maintain Competition FY 2014 

FTE

FY 2014 

Amount

FY 2015 

FTE

FY 2015 

Amount

Objective 2.1: Identify and take actions to address anticompetitive mergers and practices that cause harm to consumers. 480 $113,937 480 $111,983

Objective 2.2: Engage in effective research and stakeholder 

outreach to promote competition, advance its understanding, and create awareness of its benefits to consumers. 45 10,728 45 10,534

Objective 2.3: Collaborate with domestic and international 

partners to preserve and promote competition. 13 4,838 13 4,604

Total 538 $129,503 538 $127,121
Performance Plan 41 FYs 2014 and 2015

Objectives by FTE

($ in thousands)

Fiscal Year 2014 Fiscal Year 2015

Protecting Consumers Objective Number Total 

FTE

Objective Number Total 

1 2 3 1 2 3 FTE

Privacy and Identity Protection 45 11 1 57 45 11 1 57

Financial Practices 75 9 8 92 75 9 8 92

Marketing Practices 85 5 6 96 85 5 6 96

Advertising Practices 50 7 1 58 50 7 1 58

Enforcement 50 3 1 54 50 3 1 54

Planning and Information 48 3 0 51 48 3 0 51

Consumer and Business Education 0 23 0 23 0 23 0 23

Economic and Consumer Policy Analysis 2 4 0 6 2 4 0 6

Management 22 7 0 29 22 7 0 29

Support 131 25 16 172 131 25 16 172

Total 508 97 33 638 508 97 33 638

Fiscal Year 2014 Fiscal Year 2015

Promoting Competition Objective Number Total 

FTE

Objective Number Total 

1 2 3 1 2 3 FTE

Premerger Notification 16 3 0 19 16 3 0 19

Merger and Joint Venture Enforcement 184 12 1 197 184 12 1 197

Merger and Joint Venture Compliance 9 2 0 11 9 2 0 11

Nonmerger Enforcement 126 8 2 136 126 8 2 136

Nonmerger Compliance 2 0 0 2 2 0 0 2

Antitrust Policy Analysis 3 4 0 7 3 4 0 7

Other Direct 16 4 0 20 16 4 0 20

Support 124 12 10 146 124 12 10 146

Total 480 45 13 538 480 45 13 538
This page intentionally left blank.
Performance Plan 43 FYs 2014 and 2015

Agency and Mission Information

Government Performance and Results 

Modernization Act (GPRMA)

The FY 2015 budget request is based on the FTC’s new Strategic Plan for FYs 2014 to 

2018 and is supported by the FY 2014 and FY 2015 Performance Plan included in this 

submission. In FY 2013, the FTC updated and revised its Strategic Plan and sought 

input from Congress, the Office of Management and Budget, and its stakeholders to 

ensure that its strategic goals, objectives, and measures continue to provide relevant 

information that reflects the FTC’s performance. Changes and adjustments to performance measures in FY 2014 due to the new strategic plan are identified. To see the 

FTC’s performance and budget documents, please see http://www.ftc.gov/about-ftc/

performance and http://www.ftc.gov/about-ftc/budgets. 

The President’s Budget identifies the lower-priority program activities, where applicable, as required under the GPRA Modernization Act, 31 U.S.C. 1115(b)(10). The public 

can access this information at: http://www.whitehouse.gov/omb/budget. The FTC 

does not have any lower-priority program activities.

Mission

Working to protect consumers by preventing anticompetitive, deceptive, and unfair 

business practices, enhancing informed consumer choice and public understanding of 

the competitive process, and accomplishing this without unduly burdening legitimate 

business activity.

Vision

A vibrant economy characterized by vigorous competition and consumer access to accurate information.

Overview

The FTC is an independent Executive Branch law enforcement agency with both consumer protection and competition jurisdiction in broad sectors of the economy. The 

agency administers a wide variety of laws and regulations such as the Federal Trade 

Commission Act, Telemarketing Sales Rule, Identity Theft Act, Fair Credit Reporting 

Act, and Clayton Act. In total, the Commission has enforcement or administrative 

responsibilities under more than 70 laws (see http://www.ftc.gov/ogc/stats.shtm for a 
Performance Plan 44 FYs 2014 and 2015

listing). The FTC also enforces rules issued pursuant to the Federal Trade Commission 

Act or other laws, including the Business Opportunity Rule and the Telemarketing Sales 

Rule. 

The FTC regularly reports to Congress, the President, and the public on actions it takes 

to pursue vigorous and effective law enforcement, advance consumers’ interests by 

sharing expertise with domestic and international government agencies, develop policy, 

and educate consumers and businesses. The agency is headquartered in Washington, 

DC and has seven regional offices. 

The agency maintains a website at www.ftc.gov that provides information for consumers and businesses, as well as online forms to file complaints. The website includes a 

Budget and Performance page that contains the agency’s current and prior financial and 

performance reports, as well as information on performance goal definitions and data 

quality. 

Organizational Structure

The FTC has a long tradition of maintaining a competitive marketplace for both consumers and businesses. When the FTC was created in 1914, its purpose was to prevent 

unfair methods of competition in commerce as part of the battle to “bust the trusts.” 

Over the years, the Congress passed additional laws giving the agency greater authority 

over anticompetitive practices. 

Recognizing that unfair and deceptive practices can distort a competitive marketplace 

as much as unfair methods of competition, in 1938 the Congress passed a broad prohibition against “unfair or deceptive acts or practices in or affecting commerce.” Since then, 

the FTC also has been directed to enforce a wide variety of other consumer protection 

laws and regulations.

The FTC is headed by a five-member Commission, nominated by the President and 

confirmed by the Senate, each serving a 7-year term. The President chooses one commissioner to act as Chair. No more than three commissioners may be from the same 

political party. 

The FTC’s mission is carried out by the Bureaus of Consumer Protection, Competition, 

and Economics as well as the Offices of the General Counsel, International Affairs, 

Policy and Planning, the Secretary, the Executive Director, Congressional Relations, 

Public Affairs, Administrative Law Judges, Equal Employment Opportunity, and 

Inspector General.
Performance Plan 45 FYs 2014 and 2015

Data Validation and Verification

The performance results described in this report enable the FTC to administer its programs, gauge their success, and make adjustments necessary to improve program quality for the public. New in FY 2014, the agency will maintain a Data Quality Appendix 

on each of its publicly-reported performance measures and indicators. This appendix 

will be available at http://www.ftc.gov/about-ftc/performance. Additionally, the following steps outline how the agency ensures the performance information it reports is 

complete, reliable and accurate:

• The FTC has adopted a central internal repository for performance data entry, 

reporting and review. The electronic data tool reduces human error, increases 

transparency, and increases review by senior management.

• The agency maintains procedures used to ensure timely reporting of complete, 

accurate, and reliable actual results relative to the key performance measures.

• The agency holds program managers accountable to set meaningful and realistic targets that also challenge the agency to leverage its resources. This includes 

ensuring ongoing monitoring of performance targets so they are updated to reflect 

changes in key factors that impact the agency’s ability to achieve such results. 

Further, when appropriate, program managers are required to explain how they 

will improve performance when targets are not met.

• The agency conducts quarterly performance measurement reviews with management as well as periodic senior management and commission review throughout 

the fiscal year. This process includes substantiating that actual results reported are 

indeed correct whenever those results reveal significant discrepancies or variances 

from the target.

Agency program managers also monitor and maintain automated systems and databases that collect, track, and store performance data, with support provided by 

the FTC’s Office of the Chief Information Officer. In addition to the general controls 

which ensure only authorized staff can access key systems, each application (system) 

incorporates internal validation edits to ensure the accuracy of data contained therein. 

These application edits include checks for reasonableness, consistency, and accuracy. 

Crosschecks between other internal automated systems also provide assurances of data 

accuracy consistency. In addition to internal monitoring of each system, experts outside 

of the business units (e.g., the Bureaus of Consumer Protection and Competition) routinely monitor the data collection. For example, senior economists from the Bureau of 

Economics review statistical data used by the Bureau of Competition to calculate performance results. 
Performance Plan 46 FYs 2014 and 2015

Annual Performance Measures: Targets for Fiscal Years 2014 to 2015

FY 2014 Target FY 2015 Target

Strategic Goal 1 – Protect Consumers

Objective 1.1 – Identify and take actions to address deceptive or unfair practices that harm consumers.

Performance Goal 1.1.1: Percentage of the FTC’s consumer protection law 

enforcement actions that targeted the subject of consumer complaints to the 

FTC.

80.0%

Performance Goal 1.1.2: Rate of customer satisfaction with the FTC’s 

Consumer Response Center.

A) For the website, exceed average citizen 

satisfaction rate as published in the ACSI’s 

E-Government Satisfaction Index.

B) For the call center, meet or exceed standards 

for call centers developed by the Citizen Service 

Levels Interagency Committee.

Key Performance Goal 1.1.3: Total consumer savings compared to the 

amount of FTC resources allocated to consumer protection law enforcement.

Base year to gather 

data TBD

Key Performance Goal 1.1.4: Amount of money the FTC returned to consumers and forwarded to the U.S. Treasury.Base year to gather 

data TBD

Objective 1.2 – Provide the public with knowledge and tools to prevent harm to consumers.

Performance Goal 1.2.1: Rate of consumer satisfaction with FTC consumer 

education websites.

Exceed average citizen satisfaction rate as published in the E-Government Satisfaction Index.

Key Performance Goal 1.2.2: Number of federal, state, local, international, 

and private partnerships to maximize the reach of consumer and business 

education campaigns.

11,250 11,500

Performance Goal 1.2.3: Number of workshops and conferences the FTC 

convened that address consumer protection problems. 12

Performance Goal 1.2.4: Number of consumer protection reports the FTC 

released. 10

Objective 1.3 – Collaborate with domestic and international partners to enhance consumer protection.

Performance Goal 1.3.1: Number of investigations or cases in which the FTC 

and other U.S. federal, state and local government agencies shared evidence 

or information that contributed to FTC law enforcement actions or enhance 

consumer protection.

Base year to gather 

data TBD

Key Performance Goal 1.3.2: Number of investigations or cases in which 

the FTC obtained foreign-based evidence or information or engaged in 

other mutual assistance that contributed to FTC law enforcement actions, 

or in which the FTC cooperated with foreign agencies and/or multilateral 

organizations on enforcement matters.

40

Performance Goal 1.3.3: Number of instances of policy advice or technical 

assistance provided to foreign consumer protection and private agencies, 

directly and through international organizations, through seminars, substantive consultations, written submissions, or comments, and direct work with 

foreign agency officials who visit the FTC.

60

Performance Goal 1.3.4: Percentage of consumer protection advocacy matters filed with entities including federal and state legislatures, agencies, or 

courts that were successful in whole or in part.

55.0%
Performance Plan 47 FYs 2014 and 2015

FY 2014 Target FY 2015 Target

Strategic Goal 2 – Maintain Competition

Objective 2.1 – Identify and take actions to address anticompetitive mergers and practices that harm consumers.

Key Performance Goal 2.1.1: Percentage of actions to maintain competition in substantial merger and nonmerger investigations. 40.0% to 60.0%

Performance Goal 2.1.2: Consumer savings through merger actions taken to maintain 

competition. $900.0 million

Key Performance Goal 2.1.3: Total consumer savings compared to the amount of FTC 

resources allocated to the merger program. 1,300.0%

Performance Goal 2.1.4: Consumer savings through nonmerger actions taken to maintain competition. $440.0 million $80.0 million

Key Performance Goal 2.1.5: Total consumer savings compared to the amount of FTC 

resources allocated to the nonmerger program. 1,850.0% 400.0%

Objective 2.2 – Engage in effective research and stakeholder outreach to promote competition, advance its understanding, 

and create awareness of its benefits to consumers.

Performance Goal 2.2.1: Number of workshops, seminars, conferences, and hearings 

convened or co-sponsored that involve significant competition-related issues. 4

Performance Goal 2.2.2: Number of reports and studies the FTC issued on key competition-related topics. 8

Performance Goal 2.2.3: Percentage of competition advocacy matters filed with entities 

including federal and state legislatures, agencies, or courts that were successful, in 

whole or in part.

55.0%

Objective 2.3 – Collaborate with domestic and international partners to preserve and promote competition.

Key Performance Goal 2.3.1: Percentage of FTC cases involving at least one substantive 

contact with a foreign antitrust authority in which the agencies followed consistent 

analytical approaches and reached compatible outcomes.

95.0%

Performance Goal 2.3.2: Number of instances in which the FTC provided policy advice 

or technical assistance to foreign competition agencies or government, directly and 

through international organizations, through seminars, long-term advisors and staff 

exchanges, substantive consultations, written submissions, or comments, and with 

foreign officials when they visited the FTC.

120

Annual Performance Measures: Targets for Fiscal Years 2014 to 2015
Performance Plan 48 FYs 2014 and 2015

FY 2014 Target FY 2015 Target

Strategic Goal 3 – Advance Organizational Performance

Objective 3.1 – Optimize resource management and infrastructure.

Performance Goal 3.1.1: A favorable Continuity of Operations (COOP) rating. 75.0%

Performance Goal 3.1.2: Availability of information technology systems. 99.5%

Performance Goal 3.1.3: Achieving a favorable (unqualified) audit opinion from the 

agency’s independent financial statement auditors.

Unqualified opinion on the financial 

statements.

Performance Goal 3.1.4: Average number of days for the FTC to release information in 

response to a simple FOIA request. 6 days

Objective 3.2 – Cultivate a high-performing, diverse, and engaged workforce.

Performance Goal 3.2.1: FTC achieves a high ranking in the “Best Places to Work in the 

Federal Government.”

Within the top 10 of mid-size 

agencies

Key Performance Goal 3.2.2: The extent employees believe the FTC has the talent necessary to achieve organizational goals.Exceed the government-wide results 

on the Federal Human Capital 

Survey’s Talent Management Index.

Performance Goal 3.2.3: The extent employees believe the FTC encourages an environment that is open, diverse, and inclusive.Exceed the government-wide results 

on the Federal Human Capital 

Survey’s Talent Management Index.

Annual Performance Measures: Targets for Fiscal Years 2014 to 2015
Performance Plan 49 FYs 2014 and 2015

Annual Performance Measures: Historical

For additional performance information, please see the reports available 

at http://www.ftc.gov/about-ftc/performance.

FY 2010 Actual FY 2011 Actual FY 2012 Actual FY 2013 Actual

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 5.8 million 5.7 million

Key Measure 1.1.2: The percentage of the FTC’s 

consumer protection law enforcement actions that 

target the subject of consumer complaints to the 

FTC.†

95.9% 80.4% 90.6% 90.9%

Measure 1.1.3: The rate of customer satisfaction with 

the FTC’s Consumer Response Center.*

(A) 75.0% (A) 75.0% (A) 75.0% (A) 76.0%

(B) 76.0% (B) 77.0% (B) 78.0% (B) 80.0%

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% 100.0% 100.0% 98.6%

Measure 1.2.2: The FTC’s effectiveness in stopping 

prohibited business practices in three high priority 

areas over fiscal years 2009 - 2013. Not applicable On track

Statistically 

significant 

decrease in one 

of the three 

high-priority 

areas

Measure 1.2.3.: The percentage of redress cases in 

which the FTC distributes redress dollars designated for distribution to consumers within 6 months.96.0% of cases 100.0% of cases 95.0% of cases 94.7% of cases

Measure 1.2.4: Investigations or cases in which the 

FTC obtains foreign-based evidence or engages 

in mutual assistance that contributes to FTC law 

enforcement actions or in which we cooperate with 

foreign agencies and/or multilateral organizations.

39 53 56 61

*Target (A): For the website, exceed average citizen satisfaction rate as published in the ACSI’s E-Government Satisfaction Index. 

For Target (B): For the call center, meet or exceed standards for call centers developed by the Citizen Service Levels Interagency 

Committee.

†

Performance targets updated as of FY 2012 in the FTC’s Strategic Plan Addendum at http://www.ftc.gov/sites/default/files/

documents/reports_annual/strategic-plan/spfy09fy14add.pdf.
Performance Plan 50 FYs 2014 and 2015

†

Performance targets updated as of FY 2012 in the FTC’s Strategic Plan Addendum at http://www.ftc.gov/sites/default/files/

documents/reports_annual/strategic-plan/spfy09fy14add.pdf.

FY 2010 Actual FY 2011 Actual FY 2012 Actual FY 2013 Actual

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 39.4 million 43.6 million

Key Measure 1.3.2: Customer satisfaction rate with 

an FTC consumer education website or microsite. 77.0% 81.0% 81.0% 80.0%

Measure 1.3.3: Organizations requesting consumer 

education publications.† 15,372 14,818 11,298 11,236

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 14 12

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 8 12

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

“useful.”†

100.0% 100.0% N/A (no responses 

received)

100.0%

Key Measure 1.4.4: 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.

100.0% 83.3%

N/A

(no APA 

rulemakings 

conducted)

N/A

(no APA 

rulemakings 

conducted)

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 65 61

Measure 1.5.2: Technical assistance to foreign 

consumer protection and privacy authorities. 23 15 18 13

Annual Performance Measures: Historical
Performance Plan 51 FYs 2014 and 2015

FY 2010 Actual FY 2011 Actual FY 2012 Actual FY 2013 Actual

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.

40.0% 34.1% 43.1% 42.2%

Measure 2.1.2: Consumer savings of at least 

$500 million through merger actions to maintain 

competition.

$586.0 million $532.2 million $504.9 million $564.2 million

Measure 2.1.3: Actions against mergers likely to 

harm competition in markets with a total of at least 

$25 billion in sales. 

$22.5 billion $22.7 billion $20.2 billion $21.0 billion

Measure 2.1.4: Consumer savings of at least six 

times the amount of FTC resources allocated to 

merger program.†

1,670.0% 1,419.0% 1,492.4% 1,382.2%

Measure 2.1.5: Consumer savings of at least $80 million through nonmerger actions taken to maintain 

competition.†

$508.0 million $444.9 million $439.8 million $449.8 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 $11.7 billion $13.1 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.†

2,418.0% 1,917.7% 1,831.7% 2,296.0%

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.

100.0% 100.0% 100.0% 100.0%

Annual Performance Measures: Historical

†

Performance targets updated as of FY 2012 in the FTC’s Strategic Plan Addendum at http://www.ftc.gov/sites/default/files/

documents/reports_annual/strategic-plan/spfy09fy14add.pdf.
Performance Plan 52 FYs 2014 and 2015

FY 2010 Actual FY 2011 Actual FY 2012 Actual FY 2013 Actual

Objective 2.2: Prevent consumer injury through education:

Key Measure 2.2.1: Competition resources accessed 

via the FTC’s website.† 21.5 million 22.6 million 23.2 million 44.1 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 3 4

Key Measure 2.3.2: Reports and studies issues on 

key competition-related topics. 9 11 9 14

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 18 19

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

“useful.”†

100.0% 100.0% 83.3% 100.0%

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 3.4 million 3.9 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.†

76 112 146 100

Measure 2.4.2: Technical assistance provided to 

foreign competition authorities. 60 27 27 34

Annual Performance Measures: Historical

†

Performance targets updated as of FY 2012 in the FTC’s Strategic Plan Addendum at http://www.ftc.gov/sites/default/files/

documents/reports_annual/strategic-plan/spfy09fy14add.pdf.
Performance Plan 53 FYs 2014 and 2015

FY 2010 Actual FY 2011 Actual FY 2012 Actual FY 2013 Actual

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.

68.0% 66.0% 66.0% 64.0%

Key Measure 3.1.2: The extent employees think the 

organization has the talent necessary to achieve 

organizational goals.

72.0% 70.0% 70.0% 69.0%

Objective 3.2: Provide effective infrastructure and security management

Key Measure 3.2.1: A favorable Continuity of 

Operations (COOP) rating. 85.0% 75.0% 90.0% 85.0%

Key Measure 3.2.2: Availability of information 

technology systems. 99.77% 99.82% 99.86% 100.00%

Objective 3.3: Provide effective information resource management:

Key Measure 3.3.1: The percentage of Commissionapproved documents in the FTC’s ongoing and 

newly initiated proceedings available via the 

Internet within 15 days of becoming part of the 

public record.

93.8% 82.0% 80.2% 80.6%

Objective 3.4: Provide effective financial and acquisition management

Measure 3.4.1: Independent auditor’s financial statement audit results. Unqualified Unqualified Unqualified Unqualified

Key Measure 3.4.2: The percentage of Bureaus/

Offices that establish and maintain an effective, riskbased internal control environment.100.0% 100.0% 100.0% 100.0%

Measure 3.4.3: Performance against the Small 

Business Administration’s government-wide small 

business procurement goals.

58.9% 46.3% 57.7% 49.5%

Annual Performance Measures: Historical
This page intentionally left blank.
Performance Plan 55 FYs 2014 and 2015

Strategic Goal 1: Protect Consumers

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 to achieve 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 

emerging issues. The FTC also conducts research on a variety of consumer protection 

topics. 

Evaluations and Research

The FTC continuously evaluates the effectiveness of its efforts to protect consumers. The 

agency’s research and analysis of important and emerging consumer protection issues 

enhances agency decision making and enables the agency to better protect consumers. This work is done through the Bureau of Consumer Protection and the Bureau of 

Economics. These efforts include:

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

made available by the agency is used by its staff and law enforcement partners. 

• Evaluating whether enforcement activities are tracking the areas of greatest concern and whether there are new practices or technologies that require additional 

law enforcement.

• Evaluating the effectiveness of the FTC’s enforcement efforts in those areas in 

which a baseline measure can be determined.

• Measuring the number of education messages disseminated each year and assessing the number and range of public and private sector organizations that partner 

with the FTC on outreach.

• Reviewing the focus of FTC education efforts, determining whether the agency 

needs to reach new audiences in light of changes in demographics, advertising, 

and marketing practices, and identifying strategies or partnerships that will allow 

the FTC to reach those audiences. 

• Evaluating whether the advice and comments the FTC provides to local, state, 

and federal agencies on consumer protection policies have been considered and 

adopted. 
Performance Plan 56 FYs 2014 and 2015

Goal Leader: Director, Bureau of Consumer Protection; Director, Bureau of 

Economics 

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 on those areas where consumers suffer the most harm. The FTC leverages its 

resources by sharing information with, and encouraging other law enforcement authorities to assist it in its efforts, by acting either independently or jointly.

To help ensure that its enforcement, education and advocacy efforts are well-targeted, 

the Bureau of Consumer Protection works with the Bureau of Economics in evaluating 

economic harm to consumers as cases and programs are developed. 

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)

4. the online consumer complaint forms that support items 1-3, 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 national surveys, 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.

The agency makes consumer complaint data and other information available to other 

law enforcers through the secure website of the Consumer Sentinel Network. 

The FTC recognizes that consumers cannot always identify whether unfair or deceptive 

practices have occurred. For example, consumers cannot evaluate for themselves the 

truthfulness of an environmental marketing claim, such as “made with recycled content.” The agency, therefore, identifies targets by augmenting its complaint databases 

Objective 1.1 Identify and take actions to address deceptive or 

unfair practices that harm consumers.
Performance Plan 57 FYs 2014 and 2015

with other enforcement leads, such as ad monitoring, Internet “surfs” (monitoring the 

Internet for potentially false or deceptive advertising for a targeted product or service), 

evaluation of mobile practices, and direct referrals from government and private sector 

partners. 

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 a 

number of statutes and rules proscribing specific unlawful practices. The FTC’s Bureau 

of Consumer Protection, with the support of the Bureau of Economics, investigates 

cases and initiates civil enforcement actions, primarily by filing actions in federal court, 

when there is reason to believe that entities have violated these laws and rules. The 

FTC’s enforcement actions seek injunctions and other relief. The FTC also brings enforcement actions via administrative proceedings.

Strategies

• Target law enforcement efforts on violations that create the greatest amount of 

consumer harm by reviewing complaints, monitoring practices in the marketplace, and evaluating industry and other information. 

• Stop injury through aggressive law enforcement that focuses on preventing fraud 

and harmful financial practices, protecting consumer privacy, policing national 

advertising and new technologies, and suing entities that violate federal court and 

administrative orders obtained by the FTC.

FY 2014—2015 Next Steps and Future Actions

• 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.

• Evaluate whether enforcement activities are tracking the areas of greatest concern 

and whether there are new practices or technologies that require additional law 

enforcement.

• Evaluate the effectiveness of the FTC’s enforcement efforts in those areas in which 

a baseline measure can be determined.

Performance Goals

1.1.1 Percentage of the FTC’s consumer protection law enforcement actions that targeted 

the subject of consumer complaints to the FTC.

1.1.2 Rate of customer satisfaction with the FTC’s Consumer Response Center.

1.1.3 Total consumer savings compared to the amount of FTC resources allocated to 

consumer protection law enforcement.
Performance Plan 58 FYs 2014 and 2015

1.1.4 Amount of money the FTC returned to consumers and forwarded to the U.S. 

Treasury.

The first measure will ensure that FTC law enforcement actions target the subject of 

concerns identified by consumers. The second measure will ensure that the agency’s 

Consumer Response Center is providing satisfactory service responding to consumers. 

The Consumer Response Center is often consumers’ first contact with the FTC, and if 

consumers do not have a satisfactory experience, they may be less likely to file complaints. The third measure tracks how much money the FTC saves consumers each year 

through law enforcement. The FTC has found that typically when it files a complaint 

in federal district court and obtains a court order, the defendants stop their practices. If 

they fail to comply with an order, they are subject to contempt or civil penalty proceedings. By stopping these practices, the agency directly prevents further consumer losses 

caused by these defendants. The fourth measure will track the FTC’s effectiveness in 

returning money to consumers who were defrauded or forwarding money to the U.S. 

Treasury (e.g., if redress is impracticable).

Other Indicators that support performance goals and objectives

Complaints collected and entered into the Consumer Sentinel Network database.

• The indicator ensures 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.

FY 2013: 5.7 million complaints

FY 2012: 5.8 million complaints

FY 2011: 4.0 million complaints

The percent of redress cases in which the FTC distributes redress dollars designated for 

distribution to consumers within 6 months.

• The indicator will ensure that the FTC returns redress dollars to injured 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.

FY 2013: 95 percent

FY 2012: 95 percent

FY 2011: 100 percent
Performance Plan 59 FYs 2014 and 2015

Objective 1.2 Provide the public with knowledge and tools to 

prevent harm to consumers.

Goal Leader(s): Director, Bureau of Consumer Protection; Director, Bureau of 

Economics

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 

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. In 

addition, the FTC will continue to educate consumers about how to avoid identity theft 

and provide information to those who have become victims of identity theft. The FTC 

also will continue to publicize its consumer complaint and identity theft websites and 

toll-free numbers in an ongoing effort to increase public awareness of its activities and 

inform the public of ways to contact the FTC to obtain information or file a complaint.

The FTC has a unique mandate to undertake certain forms of research based on 

Section 6 of the FTC Act. Under this authority, the FTC gathers, analyzes, and makes 

public certain information that serves the public interest. The FTC also convenes conferences and workshops through which experts and other experienced and knowledgeable 

parties identify cutting-edge consumer protection issues and discuss ways to address 

those issues. The FTC recognizes that stakeholders other than government are at times 

better placed to address certain consumer protection issues. The agency, therefore, 

encourages self-regulatory efforts and partners with the private sector to disseminate 

consumer education content developed by the agency.

Strategies

• Focus consumer and business education efforts on areas where fraud, deception, 

unfair practices, and information gaps cause the greatest injury. Target particular 

demographic groups with messages about marketplace issues that impact their 

health, safety, and economic well-being, both online and off. Integrate mobile 

technologies into education and outreach initiatives through multimedia and 

interactive content.

• Monitor the marketplace and technological developments to identify emerging 

consumer protection issues, hold workshops or conferences to examine these 

issues, and, where appropriate, issue reports analyzing the issues to provide the 

public with knowledge and tools to prevent consumer harm.
Performance Plan 60 FYs 2014 and 2015

FY 2014—2015 Next Steps and Future Actions

• Measure the number of education messages disseminated each year and assess the 

number and range of public and private sector organizations that partner with the 

FTC on outreach.

• Review the focus of FTC education efforts, determine whether the agency needs to 

reach new audiences in light of changes in demographics, advertising, and marketing practices, and identify strategies or partnerships that will allow the FTC to 

reach those audiences.

Performance Goals

1.2.1 Rate of consumer satisfaction with FTC consumer education websites.

1.2.2 Number of federal, state, local, international, and private partnerships to maximize 

the reach of consumer and business education campaigns.

1.2.3 Number of workshops and conferences the FTC convened that address consumer 

protection problems.

1.2.4 Number of consumer protection reports the FTC released.

The first measure will ensure that the agency’s consumer education websites are effective and helpful for consumers. The second measure will ensure the FTC maximizes its 

reach to consumers and businesses by partnering with other groups and providing free 

bulk quantities of education materials via an online order system. These other groups 

often distribute the education materials directly to their constituents. The measure 

therefore helps determine the extent to which FTC’s education tools reach consumers. 

The third measure ensures that enforcement and education efforts are augmented by 

encouraging discussions among all interested parties, through careful study of novel 

or challenging consumer protection problems. The fourth measure will ensure the FTC 

releases a variety of informative reports to the public that help promote the understanding and awareness of consumer protection issues. 

Other Indicators that support performance goals and objectives

Consumer protection messages accessed in print.

• The indicator helps ensure that the agency is engaging in a sufficient amount of 

educational activity.

FY 2013: 11.8 million messages

FY 2012: 10.8 million messages

FY 2011: 16.2 million messages
Performance Plan 61 FYs 2014 and 2015

Social media subscribers and followers.

• The indicator helps gauge the FTC’s online presence, which enables the agency to 

reach more consumers with its educational messages. 

FY 2013: 152,548 subscribers/followers

FY 2012: 75,424 subscribers/followers

Goal Leader(s): Director, Bureau of Consumer Protection; Director, Office of 

International Affairs; Director, Office of Policy Planning 

The FTC works with partners in the United States and internationally to address new 

and emerging consumer protection challenges. The geographic location and other 

demographics may affect the types of fraud that consumers encounter. It is, therefore, 

important for governmental and non-governmental organizations to share information 

and resources to enhance consumer protection. 

The FTC promotes consumer protection domestically through advocacy by filing comments with federal, state, and local government bodies advocating policies that 1) 

promote the interests of consumers and 2) highlight the roles of consumer and empirical research in their decision-making. The agency also files amicus briefs to aid courts’ 

consideration of consumer protection issues.

Because telemarketing and Internet fraud, privacy violations, and data security breaches are increasingly cross-border in scope, the FTC routinely cooperates and collaborates 

with its foreign counterparts to implement broad-based international programs that 

combine cross-border law enforcement, policy, and technical assistance work. The FTC 

actively participates in numerous multinational organizations that engage in enforcement cooperation activities against mass-marketing fraud. The FTC provides technical 

assistance to newer consumer protection agencies and privacy authorities in foreign 

countries to help enhance their ability to achieve sound consumer protection outcomes 

in enforcement and policy-making. The agency also provides policy advice through 

substantive consultations and written comments on areas of mutual concern. This 

multi-faceted approach promotes a global marketplace that provides consumers with 

more consistent and effective protections.

Objective 1.3 Collaborate with domestic and international 

partners to enhance consumer protection.
Performance Plan 62 FYs 2014 and 2015

Strategies

• Leverage resources by working with domestic and international partners in government and the private sector to share information about consumer protection 

issues. 

• Pursue the development of international consumer protection enforcement models or approaches that focus on protecting consumers while maximizing consumer 

choice and economic benefit. 

• Provide technical assistance to countries establishing consumer protection regimes, as well as provide selected foreign officials with an opportunity to work 

alongside FTC attorneys, investigators, and economists to learn about the FTC’s 

approach to consumer protection and to promote further cooperation between the 

countries.

FY 2014—2015 Next Steps and Future Actions

• Engage through the Organization for Economic Cooperation and Development 

(OECD) to promote development of 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. 

• Work with international partners to strengthen cooperation among enforcement 

partners, bilaterally and through multilateral organizations such as the Internal 

Consumer Protection Enforcement Network and the London Action Plan, including through new initiatives with foreign criminal authorities particularly in countries that are increasingly the source of fraud directed at American consumers.

• Engage in enforcement cooperation pursuant to the Asia-Pacific Economic 

Cooperation (APEC) cross-border data privacy rules system.

• Consult with international authorities on developing new approaches to privacy 

and cross-border data transfers through the OECD and other international organizations such as the International Conference of Data Protection and Privacy 

Commissioners and the Global Privacy Enforcement Network.

• Continue to explore the use of enforceable codes of conduct, including voluntary 

industry codes, public-private hybrid arrangements, and international standards 

to protect consumers in cross-border commerce.

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

privacy technical assistance program for newer consumer protection agencies.

• Further develop the International Fellows and staff exchange programs. File comments or otherwise engage in advocacy with state, federal, and foreign govern-
Performance Plan 63 FYs 2014 and 2015

ments that evaluate both the costs and benefits of proposed policies on consumers 

and an awareness of the intersection of competition and consumer protection 

concerns.

• Evaluate whether the advice and comments (e.g., advocacy filings and amicus 

briefs) that the FTC provides to local, state, and federal government entities on 

consumer protection policies have been considered and adopted.

Performance Goals

1.3.1 Number of investigations or cases in which the FTC and other U.S. federal, state 

and local government agencies shared evidence or information that contributed to FTC 

law enforcement actions or enhanced consumer protection.

1.3.2 Number of investigations or cases in which the FTC obtained foreign-based evidence or information or engaged in other mutual assistance that contributed to FTC 

law enforcement actions or in which the FTC cooperated with foreign agencies and/or 

multilateral organizations on enforcement matters.

1.3.3 Number of instances of policy advice or technical assistance provided to foreign 

consumer protection and private agencies, directly and through international organizations, through seminars, substantive consultations, written submissions, or comments, 

and direct work with foreign agency officials who visit the FTC.

1.3.4 Percentage of consumer protection advocacy matters filed with entities including 

federal and state legislatures, agencies, or courts that were successful, in whole or in 

part.

The first measure will ensure the FTC is leveraging resources with domestic partners on 

consumer protection issues to further the goal of protecting consumers from fraud. The 

second measure will ensure that the agency is leveraging resources with foreign agencies and organizations, to increase the effectiveness of the FTC’s enforcement actions. 

The third measure will track policy advice and/or technical assistance the FTC provides 

to foreign consumer and privacy agencies through seminars, substantive consultations, 

written submissions, comments, and visits by foreign officials. The fourth measure will 

evaluate the success of consumer protection advocacies filed by the FTC.
This page intentionally left blank.
Performance Plan 65 FYs 2014 and 2015

Strategic Goal 2: Maintain Competition 

The FTC’s efforts to maintain competition focus on preventing anticompetitive mergers 

and other anticompetitive business practices in the marketplace. This work is critical to 

protect and strengthen free and open markets – the cornerstone of a vibrant economy. 

Vigorous competition results in lower prices, higher quality goods and services, and 

innovation leading to beneficial new products and services. By enforcing the antitrust 

laws, the FTC helps to ensure that markets function well.

As a part of its program to maintain competition, the FTC undertakes competition 

policy research and development activities to improve agency decision making in areas 

such as law enforcement and competition advocacy. The FTC also promotes competition through advocacy and education initiatives. These initiatives deter anticompetitive 

mergers and business practices and reduce business’ costs of compliance with antitrust 

laws. Advocacy encourages governmental actors at the federal, state, and local levels to 

evaluate the effects of their policies on competition and ensure such policies promote 

consumer benefit.

Evaluations and Research

The FTC continuously evaluates the effectiveness of its efforts to maintain and promote 

competition. Research activities allow in-depth studies of industries and ways to better 

analyze certain problems. The FTC applies the knowledge gained through its research 

projects, workshops, and hearings to improve its understanding of significant antitrust 

issues and emerging trends in business practices, technology, and markets in order to 

adapt its law enforcement and other initiatives to the continually evolving marketplace. 

After each major litigation effort, the FTC internally evaluates its litigation performance 

and captures best practices and training needs for future litigation teams. The FTC 

continuously assesses the burden imposed by investigations and seeks ways to reduce 

this burden and make the investigative process more efficient. The FTC’s Bureau of 

Economics conducts retrospective analyses of mergers and other competition issues to 

determine whether the actions taken resulted in over or under regulation. The agency 

also evaluates the policy impact of the FTC’s advocacy initiatives.
Performance Plan 66 FYs 2014 and 2015

Objective 2.1: Identify and take actions to address 

anticompetitive mergers and practices that harm consumers.

Goal Leader: Director, Bureau of Competition; Director, Bureau of Economics 

The FTC takes action to block or remedy anticompetitive mergers and to stop anticompetitive conduct. Anticompetitive mergers and other coordinated or unilateral conduct 

can lessen competition and cause harm to consumers through higher prices, inferior 

service, or diminished innovation. Anticompetitive practices can also harm competition 

and consumers if they make it more difficult for other companies to enter the market. 

Enforcement of the antitrust laws provides substantial benefits to consumers by helping 

to ensure that markets are competitive.

The FTC’s Bureau of Competition, together with the Bureau of Economics, investigates 

proposed and consummated mergers, as well as conduct and agreements that may 

be anticompetitive, and takes enforcement 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, abandoned or restructured transactions or agreements, 

or the cessation of anticompetitive conduct. The FTC strives to maintain strong litigation capabilities and works to ensure that the remedies imposed by its consent orders 

are effective in maintaining competition in the marketplace without undue burden on 

businesses.

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 them before they are consummated. The FTC administers the HSR program 

both for itself and for the Antitrust Division of the Department of Justice (DOJ), 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 do not meet HSR notification requirements, or that were 

not reported in violation of HSR.

In addition, the FTC employs a variety of methods to identify potentially anticompetitive practices and conduct outside the merger context (for example, consumer and 

competitor complaints, referrals from other government agencies, and trade press).

Strategies

• Increase the efficiency of investigatory processes to conduct rigorous, economically sound, and fact-based analysis of mergers and other potentially anticompetitive 

business practices, and enhance enforcement outcomes while minimizing burdens 

on business. 
Performance Plan 67 FYs 2014 and 2015

• Improve the timeliness of investigations and merger review under the HSR 

program. Ensure that administrative litigations and adjudications reach timely 

resolutions.

• Improve negotiation and litigation skills and refine investigative and decisional 

tools through continuous learning. 

• Negotiate merger and nonmerger consent orders and win litigated orders that 

have significant remedial, precedential, and deterrent effects. Increase compliance 

with consent decrees and orders and with HSR reporting obligations.

• Increase the transparency of the decision-making process, including assessing 

whether revisions to enforcement guidelines are required.

FY 2014—2015 Next Steps and Future Actions

To implement these strategies, in FY 2014 and FY 2015, 

• Continue to develop its training programs with the goal of increasing the antitrust expertise and investigative, negotiation, and litigation skills of its attorneys 

through continuous learning and identification of “best practices.” The Bureau of 

Competition recently established a Training Council to oversee and coordinate its 

training offerings to ensure that courses are timely and relevant for staff. 

• Continue to focus on improving the investigatory process, including through the 

use of improved technological tools to help manage and coordinate investigations. 

• As in prior years, continue ongoing assessment of premerger notification filing 

requirements with the goal of efficiency and reduced burden on filing persons and 

the antitrust agencies.

Performance Goals

2.1.1 Percentage of actions taken to maintain competition in substantial merger and 

nonmerger investigations.

2.1.2 Consumer savings through merger actions taken to maintain competition.

2.1.3 Total consumer savings compared to the amount of FTC resources allocated to the 

merger program.

2.1.4 Consumer savings through nonmerger actions taken to maintain competition.

2.1.5 Total consumer savings compared to the amount of FTC resources allocated to the 

nonmerger program.
Performance Plan 68 FYs 2014 and 2015

The first performance measure will ensure that the agency is using its resources wisely 

in bringing appropriate investigations and cases and is crafting and pursuing effective resolution, whether through litigation or settlement. Success on this performance 

measure indicates that the FTC is effectively screening HSR reported mergers and other 

merger and conduct investigations to identify those that raise significant antitrust issues 

and warrant further investigation and possible enforcement action, while at the same 

time permitting mergers or conduct that are neutral or beneficial to consumers to proceed unimpeded. The other four measures ensure that the agency is challenging mergers and conduct that may cause substantial consumer injury through targeting of the 

agency’s resources effectively and efficiently. The second and fourth measures indicate 

the consumer benefits attributable to the FTC’s enforcement actions. The third and fifth 

measures indicate the efficiency with the enforcement actions are undertaken.

Other Indicators that support performance goals and objectives

• Average total sales for the current plus previous four fiscal years in the affected 

markets in which the Commission took merger enforcement action.

FY 2013: $21.0 million

FY 2012: $20.2 million

FY 2011: $22.7 million

• Average total sales for the current plus previous four fiscal years in the affected 

markets in which the Commission took anticompetitive conduct enforcement 

action.

FY 2013: $13.1 million

FY 2012: $11.7 million

FY 2011: $11.6 million

These two other indicators reflect effective and efficient use of FTC resources by measuring the size of the relevant product markets involved in the agency’s competition 

enforcement actions. At the same time, the use of FTC resources in bringing competition enforcement actions in smaller markets to help clarify or develop competition law 

principles can be, through their deterrent and educational effects, effective means for 

maintaining and promoting competition in broader markets.
Performance Plan 69 FYs 2014 and 2015

Objective 2.2 Engage in effective research and stakeholder 

outreach to promote competition, advance its understanding, 

and create awareness of its benefits to consumers.

Goal Leader(s): Director, Bureau of Competition; Director, Office of Policy Planning

The FTC has a unique mandate to undertake certain forms of research based on Section 

6 of the FTC Act and the historical report-writing activity of its predecessor entity, the 

Bureau of Corporations. Under this authority, the FTC gathers, analyzes, and makes 

public certain information concerning the nature of competition as it affects U.S. commerce. The FTC uses this authority to enhance consumer welfare by holding public 

hearings, convening conferences and workshops, conducting economic studies on 

competition issues of significant public importance, and issuing reports of its findings. 

The agency uses the information internally to refine the theoretical economic framework 

for analyzing competition issues and understanding industry practices, and to help 

the FTC respond effectively to changing marketplace conditions. This information also 

contributes to a better understanding of business practices and their competitive and 

economic implications, providing guidance to the business sector, the legal community, 

other enforcement authorities, the judiciary, and governmental decision makers and 

policymakers at the federal, state, and local levels. 

The FTC also promotes competition through advocacy, information, and education. In 

its advocacy work, the FTC files comments with federal, state, and local government 

bodies advocating policies that promote the interests of consumers and highlights the 

role of consumer and empirical research in their decision making. The FTC also files 

amicus (“friend of the court”) briefs to aid courts’ consideration of competition issues. 

Educating consumers and businesses about competition law and policy also promotes 

competition. Informing businesses and their legal advisers about potential antitrust 

violations deters anticompetitive mergers and anticompetitive business practices 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 can also encourage cooperation 

with FTC investigations and strengthen enforcement actions.

Strategies

• Improve the agency’s understanding of various practices and developments in 

the marketplace by conducting public hearings, conferences, and workshops that 

bring together interested parties and conducting economic research on these issues. Utilize the information gathered to inform the agency’s enforcement agenda. 

Improve the dissemination of material gathered through hearings, conferences, 

and workshops.
Performance Plan 70 FYs 2014 and 2015

• Target advocacy activities to encourage state and federal government policymakers to evaluate the competitive implications of their existing and proposed policies, emphasizing the impact on consumers of policies that unnecessarily restrict 

competition.

• Increase transparency of the agency’s decision-making by ensuring that the content of complaints, press releases, and analyses to aid public comment 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 improve the public’s understanding of the FTC’s enforcement 

policies.

FY 2014—2015 Next Steps and Future Actions

• Seek out appropriate topics and organize public conferences, workshops, and 

hearings to enhance the FTC’s understanding of various practices and developments in the marketplace. 

• Encourage the participation and broader perspective of businesses and consumer 

groups in these conferences, workshops, and hearings, and continue to disseminate the materials relating to these events, including transcripts, written submissions, and reports.

• Seek opportunities to file comments or otherwise engage in advocacy with local, 

state, and federal government policymakers to encourage them to adopt policies 

that maximize competition and consumer welfare by evaluating both the costs 

and the benefits of their policies for consumers.

• Look for opportunities to expand the use of 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 decision making and to have its 

staff participate in and speak at appropriate seminars and conferences.

Performance Goals

2.2.1 Number of workshops, seminars, conferences, and hearings convened or co-sponsored that involve significant competition-related issues.

2.2.2 Number of reports and studies the FTC issued on key competition-related topics.

2.2.3 Percentage of competition advocacy matters filed with entities including federal 

and state legislatures, agencies, or courts that were successful, in whole or in part.

The first measure will ensure that consumer benefits are enhanced through activities 

such as workshops, seminars, conferences, and hearings convened or cosponsored that 
Performance Plan 71 FYs 2014 and 2015

involve significant competition-related issues. The second measure will track research, 

reports, and studies that enhance consumers’ knowledge of competition issues. The 

third measure will evaluate the success of competition advocacies filed by the FTC.

Goal Leader: Director, Office of International Affairs; Director, Bureau of 

Competition

The FTC continues to build cooperative relationships with foreign and domestic antitrust agencies to ensure close collaboration on cases and convergence toward sound 

competition policies. 

On the domestic front, the FTC seeks to collaborate with other agencies and the state 

attorneys general to obtain the best results and maximize the use of limited resources in 

the enforcement of the U.S. antitrust laws.

With its foreign partners, the FTC seeks more effective, coordinated reviews of multijurisdictional mergers, and works towards achieving consistent outcomes in cross-border cases of potential 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.

Cooperation with competition agencies of other jurisdictions is a key component of 

an effective FTC competition enforcement program. With over 120 antitrust enforcers 

worldwide, it is critical that we work together to ensure that the international competition law system functions coherently and effectively. To accomplish this, the FTC builds 

strong bilateral relations with foreign counterparts and takes a lead role in multilateral 

fora to promote case enforcement cooperation and convergence toward sound competition policies. 

The FTC provides technical assistance to newer competition agencies in foreign countries to enhance their ability to achieve sound competition outcomes in enforcement 

and policy-making. This technical assistance helps protect U.S. interests by encouraging 

systems that apply standards to transactions and conduct affecting the global marketplace that are consistent with U.S. and worldwide best practices. The agency also provides policy advice through substantive consultations and written comments on issues 

of mutual concern.

Objective 2.3: Collaborate with domestic and international 

partners to preserve and promote competition.
Performance Plan 72 FYs 2014 and 2015

Strategies

• Work more extensively within the U.S. government inter-agency process and 

with other domestic government entities to support the FTC’s efforts to promote 

market-based competition and policy convergence.

• Broaden and deepen our cooperation with foreign competition agencies on antitrust matters that are subject to concurrent review to improve the effectiveness of 

investigations and promote consistent outcomes.

• Promote policy convergence toward sound and effective antitrust enforcement 

internationally by working with a greater number of foreign competition agencies, 

including bilaterally through substantive consultations, written comments, and 

the provision of technical advice, and, multilaterally, by taking leadership roles in 

multilateral and regional organizations. Provide technical assistance to countries 

that are establishing competition regimes. Provide selected foreign officials with 

an opportunity to work alongside FTC attorneys, economists, and investigators to 

enhance their capacity to develop and implement sound competition policy and 

enforcement.

FY 2014—2015 Next Steps and Future Actions 

• Maintain the FTC’s leadership role in the International Competition Network 

(ICN), including through participating in the Steering Group and in the ICN’s 

work on agency effectiveness, unilateral conduct, merger procedures, investigative process, and the online curriculum project.

• Enhance our participation in other key multilateral and regional fora, including 

the OECD, UNCTAD, and APEC.

• Advance cooperation and convergence with foreign competition agencies by 

improving cooperation in merger matters and on single firm conduct policy and 

enforcement, including by developing new tools for cooperation and leadership 

on multilateral initiatives to promote cooperation and convergence.

• Strengthen relations with the Chinese and Indian competition agencies through 

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

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

issues, including as members of the Trans Pacific Partnership and Trans-atlantic 

Trade and Investment Partnership negotiating teams.

• Further develop the FTC technical assistance program.

• Further develop the International Fellows and staff exchange programs.
Performance Plan 73 FYs 2014 and 2015

Performance Goals

2.3.1 Percentage of FTC cases involving at least one substantive contact with a foreign 

antitrust authority in which the agencies followed consistent analytical approaches and 

reached compatible outcomes. 

2.3.2 Number of instances in which the FTC provided policy advice or technical assistance to foreign competition agencies or governments, directly and through international organizations, through seminars, long-term advisors and staff exchanges, substantive 

consultations, written submissions, or comments, and with foreign officials when they 

visited the FTC.

The first measure will track the number of cases where foreign antitrust authority or 

agency followed consistent analytical approaches and reached compatible outcomes as 

a percentage of the total number of cases the FTC has at least one substantive contact. 

The second measure will track policy advice and technical assistance the FTC provides 

to foreign competition agencies through seminars, long-term advisors and staff exchanges, substantive consultations, written submissions, comments, or hosting of international fellows and interns.
This page intentionally left blank.
Performance Plan 75 FYs 2014 and 2015

Strategic Goal 3: 

Advance Organizational Performance

The FTC believes that advancing organizational performance at all levels creates a 

strong foundation for overall mission success. The agency’s work in Strategic Goal 3 

highlights ongoing efforts to advance organizational performance that enhances the 

agency’s ability to focus on protecting consumers and maintaining competition. 

Goal 3 is inherently collaborative, and primarily encompasses key management areas in 

the FTC: human capital, infrastructure and security, information technology resources, 

finance and acquisition, and equality of opportunity in employment. These efforts 

foster leadership and accountability across the agency and establish a culture of customer service, constituent responsiveness, and effective planning, administration, and 

management. Employees at all levels are expected to show leadership in their areas of 

responsibility by exhibiting a willingness to develop and coach others, a commitment to 

teamwork, and a drive to find innovative solutions.

Evaluations and Research

• The agency rigorously reviews its management functions. 

• The FTC’s financial statements are audited annually, which encompasses a 

thorough overview of the agency’s financial position and various transactions 

throughout the fiscal year.

• The FTC conducts risk assessment reviews of the agency’s programs. These reviews assist management in identifying high-risk areas and implementing appropriate risk management strategies where necessary. In addition, the agency 

performs targeted reviews of internal controls. The areas targeted for review are 

determined by several factors, including risk assessment, management input, prior audits and reviews results and external (regulatory) environment. Management 

evaluates the results from the internal control reviews to determine what processes should be modified to strengthen controls and/or improve efficiency.

• With respect to the information technology and privacy arena, annual FISMA 

reviews are conducted, and the agency reviews and acts on any areas that need 

improvement.

• In the area of human capital, FTC regularly reviews and acts on the results of 

the Office of Personnel Management’s Annual Federal Employee Viewpoint 

Survey. Several areas that OPM periodically examines include a Human Capital 
Performance Plan 76 FYs 2014 and 2015

Management Evaluation, a Delegated Examining Unit Examination, and 

Performance Assessments of General Schedule and Senior Executive Service 

Performance Management Systems. The Equal Employment Opportunity 

Commission may also perform technical assistance visits or program reviews.

In addition, the FTC looks to outside groups, such as the Office of the Inspector General, 

for independent reviews of its activities.

Goal Leader(s): Executive Director, Office of the Executive Director; General Counsel, 

Office of the General Counsel

The creation, modernization, and maintenance of physical, financial and information resources and infrastructure not only provides for a safe, secure, and efficient workplace 

but also helps the agency to achieve its mission and respond to, and anticipate, future 

agency needs. 

These efforts span several FTC offices and functions. For example, the agency’s 

Continuity of Operations Plan (COOP) ensures that the agency can respond to, and 

recover from, an emergency situation effectively. The FTC is also committed to effective 

and efficient management of information resources, and is transitioning to managing 

most information resources electronically, for example, by developing and implementing a web-based system for public filings in all FTC administrative litigation proceedings. This transition will enable staff to perform their work more efficiently, facilitate 

public access, and protect sensitive information from inappropriate access. 

Ensuring the FTC has an effective and secure information technology infrastructure is essential to meeting the Commission’s strategic goals. The Office of the Chief 

Information Officer delivers value by identifying and providing a host of critical high 

quality, low-risk IT services that are agile enough to meet Commission business needs. 

The FTC believes in the importance of accountability and transparency, as shown 

through resource stewardship and financial oversight activities. The 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 financial management laws and regulations. 

This transparency is also evident in the FTC’s work to improve Internet access to public 

agency documents. With respect to public documents newly approved or authorized 

by the Commission, the FTC will continue to post text-searchable electronic versions on 

Objective 3.1: Optimize resource 

management and infrastructure.
Performance Plan 77 FYs 2014 and 2015

the public FTC website in conjunction with applicable news releases. As resource levels 

permit, the Commission will also continue to post public documents generated prior to 

the establishment of the FTC’s website in 1996.

Strategies

• Improvement of the effectiveness and efficiency of financial management operations. Over the next five years, the FTC plans to fully integrate procurement and 

core financial systems. This complete financial management system will strengthen the agency’s internal controls, improve efficiency of the procurement process, 

and provide agency staff with timely information regarding budget execution and 

the availability of funds.

• Improvement of agency IT services by building redundancy into the FTC’s IT infrastructure to support vital services, creating virtual computing environments to 

consolidate the management and utilization of IT resources, and investing in new 

technologies to further support the FTC’s mission.

• Transition to electronic information resource management by: 1) Developing 

an agency-wide information governance policy. The policy will cover file structures for organizing information, mandatory and optional metadata (searchable 

information about the document), document naming conventions, access restrictions, and retention rules and triggers. 2) Implementing an Electronic Content 

Management (ECM) system which staff will use to draft, collaborate on, and finalize work, including consumer protection and competition case filings. The ECM 

system will enable us to maintain agency records in a secure electronic format for 

the required retention period and to transfer permanent agency records to NARA.

• Reduction of the agency’s energy consumption and promotion of recycling of 

materials and equipment. Improvements that yield the greatest benefit relative to 

cost will be incorporated into the development of a new performance indicator. 

FY 2014—2015 Next Steps and Future Actions 

• Evaluate COOP rating and determine support requirements. 

• Continue partnership with GSA and OMB in executing the previously coordinated relocation of FTC staff from the 1800 M Street and 601 New Jersey Avenue 

buildings to Constitution Center in Washington, DC. 

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

and locating contractor staff off-site. 

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

records. 
Performance Plan 78 FYs 2014 and 2015

• 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. 

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

special emphasis on managing information electronically throughout its lifecycle. 

• Enhance the reporting capabilities within the integrated financial system to provide more accurate, reliable, and timely financial information to agency decision 

makers.

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

• In FY 2014 and FY 2015, introduce new systems and applications that will enhance 

the FTC user experience and further provide tools to achieve FTC’s strategic goals 

and meet government-wide IT mandates.

• In FY 2014, launch a new e-Discovery support system that will allow the 

Commission to streamline its e-Discovery processes and meet requirements set by 

the Federal Rules of Civil Procedure.

• Also in FY 2014, upgrade the agency’s mobile device platform and remote access 

telework portal and in FY 2015 will begin developing a mobile computing platform, all of which will improve employees’ ability to access FTC’s network and 

data from any location.

• In FY 2015, begin the deployment of a Single-Sign-On solution to support the 

implementation of HSPD-12 and further protect FTC data and systems from unauthorized access.

• Develop and deploy non-public filings and electronic service enhancements to the 

web-based system for public filings in FTC administrative litigation proceedings 

to make the proceedings fully electronic to the greatest extent possible. 

• Continue to develop an agency-wide information governance policy to support efficient management of electronic information with appropriate access restrictions.
Performance Plan 79 FYs 2014 and 2015

• Implement an Electronic Content Management system that staff will use to 

do their work and that will enable FTC to maintain and transfer records to the 

National Archives and Records Administration in a secure electronic format.

Performance Goals

3.1.1 A favorable Continuity of Operations (COOP) rating.

3.1.2 Availability of information technology systems.

3.1.3 Achieving a favorable (unqualified) audit opinion from the agency’s independent 

financial statement auditors.

3.1.4 Average number of days for the FTC to release information in response to a simple 

FOIA request. 

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. The second measure will address the availability of 31 mission-critical IT systems, 

such as email, telecommunications, Internet access, and mobile devices. Network availability addresses the reliability of the FTC computer and communications systems. 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 and compliance with applicable laws 

and regulations. The fourth measure will track the agency’s response time in processing 

a simple FOIA request for access to public records.

Goal Leader: Executive Director, Office of the Executive Director; Director, Bureau 

of Consumer Protection; Director, Bureau of Competition; Director, Bureau of 

Economics; General Counsel, Office of General Counsel

This objective encompasses leadership and knowledge management, a results-oriented 

performance culture, talent management, and job satisfaction. The FTC uses an integrated approach to link human capital programs and policies to agency mission, goals, 

and strategies and to provide continuous improvement in efficiency and effectiveness. 

The objective captures the FTC’s work and ensures the presence of the right talent in the 

right positions at the right time to meet the challenges of the 21st century. It also captures efforts to tap into the rich resources of the global community and ensure fairness 

in the workplace. By attracting, developing, motivating, and retaining a high performObjective 3.2: Cultivate a high-performing, diverse, 

and engaged workforce.
Performance Plan 80 FYs 2014 and 2015

ing, diverse, inclusive, and engaged workforce, the FTC advances organizational performance. By having a workforce that looks like and draws from the consumers it protects, 

the FTC strengthens its ability to meet its mission. 

The FTC uses the Federal Employee Viewpoint Survey administered by OPM to measure success in this objective. The survey focuses on employees’ perceptions of critical 

areas of their work life and workforce management, and measures factors that influence 

whether employees want to join, stay, and help their agency meet its mission.

In addition, the FTC uses Management Directive 715 (MD-715), which is submitted by 

the agency to the U.S. Equal Employment Opportunity Commission on an annual basis. 

MD-715 is a tool for agencies to use to ensure that all workers are competing on a fair 

and level playing field and have the opportunity to achieve their fullest potential.

Strategies

• One of the key strategies to achieving this objective entails using integrated workforce planning to identify and fulfill current and future human capital needs to 

carry out the agency’s mission and implementing programs and processes to enable us to recruit, develop, and retain a highly qualified and diverse workforce. 

• The FTC strives to create an agency-wide performance culture that focuses on 

individual and organizational accountability toward achieving the FTC’s programmatic goals and priorities. The agency also seeks to achieve this objective by 

providing quality training and outreach to staff. 

FY 2014—2015 Next Steps and Future Actions

• 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. For example, we will modernize 

our time-keeping and attendance system to more fully automate related processes 

(working closely with our shared service provider, the Interior Business Center). 

• Identify and provide diversity and inclusion training to employees.
Performance Plan 81 FYs 2014 and 2015

Performance Goals

3.2.1 FTC achieves a high ranking in the “Best Places to Work in the Federal 

Government.”

3.2.2 The extent employees believe the FTC has the talent necessary to achieve organizational goals.

3.2.3 The extent employees believe the FTC encourages an environment that is open, 

diverse, and inclusive.

The FTC recognizes that its employees are its greatest asset and places great emphasis 

on the importance of human resources management to the successful accomplishment 

of its mission. The FTC seeks employee feedback on the extent they believe the organization culture promotes improvement in processes, products and services, and outcomes and the extent the FTC has the right talent in the right positions at the right time 

to carry out the mission. The Best Places to Work measure is a tool for ensuring that 

employee satisfaction is a top priority for managers and leaders. The FTC is not only are 

measured on overall employee satisfaction, as tracks by the other two measures, but are 

scored in 10 workplace categories, such as effective leadership, employee skills/mission 

match, pay, teamwork and work/life balance. The Federal Employee Viewpoint Survey 

includes a Diversity and Inclusion index that consolidates many of the questions in the 

survey.
This page intentionally left blank.
Performance Plan 83 FYs 2014 and 2015

Additional Information

List of External Performance Goals Added for FY 2014 – FY 2018

• 1.1.3 Total consumer savings compared to the amount of FTC resources allocated 

to consumer protection law enforcement. 

• 1.1.4 Amount of money the FTC returned to consumers and forwarded to the U.S. 

Treasury. 

• 1.2.2 Number of federal, state, local, international, and private partnerships to 

maximize the reach of consumer and business education campaigns. 

• 1.2.4 Number of consumer protection reports the FTC released. 

• 1.3.1 Number of investigations or cases in which the FTC and other U.S. federal, 

state and local government agencies shared evidence or information that contributed to FTC law enforcement actions or enhance consumer protection.

• 1.3.2 Number of investigations or cases in which the FTC obtained foreign-based 

evidence or information or engaged in mutual assistance that contributed to FTC 

law enforcement actions or in which the FTC cooperated with foreign agencies 

and/or multilateral organizations on enforcement matters. 

• 1.3.3 Number of instances of policy advice or technical assistance provided to foreign consumer protection and private agencies, directly and through international 

organizations, through seminars, substantive consultations, written submissions, 

or comments, and direct work with foreign agency officials who visit the FTC. 

(Note: Policy advice and technical assistance provided was combined into a single 

performance goal in FY14.)

• 1.3.4 Percentage of consumer protection advocacy matters filed with entities 

including federal and state legislatures, agencies, or courts that were successful in 

whole or in part. 

• 2.2.3 Percentage of competition advocacy matters filed with entities including 

federal and state legislatures, agencies, or courts that were successful in whole or 

in part. 

• 2.3.2 Number of instances in which the FTC provided policy advice or technical 

assistance to foreign competition agencies or government, directly and through 

international organizations, through seminars, long-term advisors and staff ex-
Performance Plan 84 FYs 2014 and 2015

changes, substantive consultations, written submissions, or comments, and with 

foreign officials when they visited the FTC. (Note: Policy advice and technical 

assistance provided was combined into a single performance goal in FY14.)

• 3.1.4 Average number of days for the FTC to release information in response to a 

simple FOIA request.

• 3.2.1 FTC achieves a high ranking in the “Best Places to Work in the Federal 

Government.”

• 3.2.3 The extent employees believe the FTC encourages an environment that is 

open, diverse, and inclusive.

List of External Performance Goals Dropped in the Development of the FY 2014 – FY 

2018 Strategic Plan

• 1.1.1 Complaints collected and entered into the Consumer Sentinel Network database. (Note: Indicator tracked internally beginning in FY14.)

• 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. 

• 1.2.2 The FTC’s effectiveness in stopping prohibited business practices in three 

high priority areas over the next five years. 

• 1.2.3 The percent of redress cases in which the FTC distributes redress dollars designated for distribution to consumers within 6 months. (Note: Indicator tracked 

internally beginning in FY14.)

• 1.3.1 Consumer protection messages accessed online or in print. (Note: Indicator 

tracked internally beginning in FY14.)

• 1.3.3 Organizations requesting consumer education publications. 

• 1.4.2 Advocacy comments and amicus briefs on consumer protection issues filed 

with entities including federal and state legislatures, agencies, or courts. 

• 1.4.3 The percentage of respondents finding the FTC’s advocacy comments and 

amicus briefs “useful.” 

• 1.4.4 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. 

• 1.5.1 Policy advice provided to foreign consumer protection and privacy agencies, 

directly and through international organizations, through substantive consulta-
Performance Plan 85 FYs 2014 and 2015

tions, written submissions, or comments. (Note: Merged with measure 1.5.2 in 

FY14.)

• 1.5.2 Technical assistance to foreign consumer protection and privacy authorities. 

(Note: Merged with measure 1.5.1 in FY14.)

• 2.1.3 Actions against mergers likely to harm competition in markets with a total of 

at least $25 billion in sales. (Note: Indicator tracked internally beginning in FY14.)

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

billion in annual sales. (Note: Indicator tracked internally beginning in FY14.)

• 2.2.1 Competition resources accessed via the FTC’s website.

• 2.3.3 Advocacy comments and amicus briefs on consumer protection issues filed 

with entities including federal and state legislatures, agencies, or courts. 

• 2.3.4 The percentage of respondents finding the FTC’s advocacy comments and 

amicus briefs “useful.” 

• 2.3.5 The volume of traffic on www.ftc.gov relating to competition research, reports, and advocacy. 

• 2.4.1 Policy advice provided to foreign competition agencies, directly and through 

international organizations, through substantive consultations, written submissions, or comments. (Note: Merged with measure 2.4.2 in FY14.)

• 2.4.2 Technical assistance to foreign competition authorities. (Note: Merged with 

measure 2.4.1 in FY14.)

• 3.1.1 The extent employees believe their organizational culture promotes improvement in processes, products and services, and organizational outcomes. 

• 3.3.1 The percentage of Commission approved documents in the FTC’s ongoing 

and newly initiated proceedings available via the Internet within 15 days of becoming part of the public record. 

• 3.4.2 The percentage of Bureaus/Offices that establish and maintain an effective, 

risk-based internal control environment. 

• 3.4.3 Performance against the Small Business Administration’s government-wide 

small business procurement goals. 
Performance Plan 86 FYs 2014 and 2015

FTC’s management priorities are incorporated into Goal 3, Advance Organizational 

Performance. Objective 3.2: Cultivate a high-performing, diverse, and engaged workforce, focuses broadly on human capital development goals. A key priority is to be one 

of the best places to work in the federal government. As an example of this management priority, the FTC’s Bureau of Consumer Protection and Bureau of Competition 

have focused attention on the continuous development of their employees through their 

mentoring programs. For at least the past five years, BCP and BC have run successful 

formal mentoring programs. The BCP and BC Mentoring Programs, open to all BCP, 

BC, and regional office employees, are designed to contribute to an environment in 

which unique skills and perspectives that each staff member brings are recognized and 

valued; diversity is fostered; and excellence, innovation and risk-taking are promoted. 

The Mentoring Programs provide significant opportunities to build and share organizational knowledge and expertise by capitalizing on the experiences of successful individuals who are committed to the development of a high performance work force. BCP 

and BC also are examining the formal training they provide to their attorneys, and are 

developing training curriculum for their attorneys. Recently, the Office of the Executive 

Director began a similarly-focused formal Mentoring Program that has received very 

positive feedback from participants. The agency has continued these efforts in FY 2014 

and plans to continue them in FY 2015. 

The FTC and the Office of Inspector General (OIG) work collaboratively on addressing 

key management challenges. The following three challenges are based on work conducted by the Office of Inspector General (OIG) and discussions with senior leaders at 

the FTC. Along with a summary of these management challenges are brief assessments 

of the agency’s progress in addressing these challenges.

Management Challenge: Consolidating Satellite Offices into the Constitution Center

During 2014, the Federal Trade Commission (FTC) will consolidate its New Jersey 

Avenue and M Street offices into the newly renovated Constitution Center and the 

FTC Headquarters building. Over 800 employees will be relocated during the process. 

The consolidation effort is being conducted under extremely tight time constraints that 

resulted primarily from decisions and events outside the direct control of the FTC.

The FTC has taken proactive steps to mitigate these risks. These include contracting 

with a vendor to provide professional planning and project management support for 

the consolidation; and moving to a phased approach to achieving full operational capability. Moving forward, considerable effort will be required to manage the many risks 

associated with a move of this complexity within the truncated timeframe. Not only 

does the FTC have to transfer its people and associated support activities, it must also 

Major Management Priorities and Challenges
Performance Plan 87 FYs 2014 and 2015

continue normal operations and complete the consolidation under severe resource and 

time constraints.

Agency Progress in Addressing this Challenge

The FTC is reducing its footprint by consolidating FTC employees in the DC area from 

three locations to two. The Office of the Executive Director is coordinating this priority initiative and working closely with staff and leadership at all levels throughout the 

agency to ensure a smooth transition. A project integrator is assisting the agency to 

help ensure compliance with Federal statutes and regulations; track and assess costs, 

expenditures, budget, procurements, schedule, performance and risk; and maintain a 

complete record of the project. The Executive Director and the team hold regular meetings with key FTC officials, GSA, Constitution Center building management, and the 

agency’s IG to ensure the project stays on track and within budget. Internal milestones 

are being tracked and success will be measured by the safe and timely transition of 

staff to the new facility and to the agency’s Headquarters building without undue 

interruption to the agency’s work and by keeping the overall cost of the moves at or 

below the budget. In FY 2013, the FTC made significant progress toward preparing the 

Constitution Center space for occupation in FY 2014. Key procurements included furniture, demountable walls and dark fiber (used for high-speed communication).

Management Challenge: Securing the Agency’s Information Systems and Networks 

from Destruction, Data Loss, or Compromise

The ability to protect its information assets is a complex challenge for the FTC. 

Technology is changing at an increasing rate, introducing different vulnerabilities 

as the FTC integrates new technologies (e.g., cloud and mobile computing) into its 

Information Technology (IT) infrastructure. Also, threats are changing and more pervasive, and attacks are intended to disrupt operations. In addition, guidance for federal 

agencies has become more flexible, allowing agencies to tailor information protection 

solutions specific to their needs, but providing less direction as to what those acceptable 

solutions are. To address outstanding security weaknesses while constraining costs, the 

FTC should continue to evolve its information security program toward a risk-based 

governance model that emphasizes enterprise solutions and disciplined change management processes. 

In 2014, the FTC plans to leverage the aforementioned office consolidation to improve 

its IT service offerings and resolve outstanding security vulnerabilities. The FTC recognized that the complexity and challenges introduced by inclusion of significant 

infrastructure upgrades and mitigation of previously identified vulnerabilities in the 

consolidation effort would significantly increase the risk of technical miscues, schedule 

failure and cost over runs. Therefore, as noted above, the FTC recently decided to take 

a phased approach to its data center consolidation. A phased approach will allow for 

orderly, planned, and controlled change within an expanded timeframe. This should reduce the risk of costly errors while ensuring continued resource availability and greater 

assurance that FTC information assets are appropriately protected.
Performance Plan 88 FYs 2014 and 2015

Agency Progress in Addressing this Challenge

The OCIO and the Chief Privacy Officer (CPO) continue to work with FTC system 

owners and managers to ensure that information security and privacy requirements 

are identified, documented, communicated appropriately, and incorporated into the 

design and implementation of each system. System owners and managers are reminded 

that periodic test and evaluation of information security and privacy controls is necessary to ensure effective implementation and operation of those controls. They are also 

reminded that maintaining and, as necessary, updating the corresponding information 

security and privacy documentation (such as system security plans and Privacy Impact 

Assessments) is a pre-requisite to issuance and retention of the system’s authorization 

to operate. OCIO staff, along with the Office of General Counsel staff and the CPO, 

continue to meet with system owners to make sure that contract language addresses 

information security and privacy controls and related FTC practices and procedures, 

including continuous monitoring, so that Contracting Officer Representatives (CORs) 

can manage and assist in evaluating the compliance of contractor-hosted systems and 

services. As the OCIO and the CPO continue to work closely to implement and coordinate privacy controls with information security controls, as required by NIST Special 

Publication 800-53 rev. 4, the FTC will continue to develop and improve its risk-based 

assessments of information security and privacy as new technologies are integrated into 

the FTC infrastructure.

For example, the OCIO has teamed with the Department of Homeland Security to 

obtain the following services:

• Continuous Diagnostics and Mitigation (CDM) Program: Specialized IT diagnostic 

tools along with a dashboard to provide real-time situational security awareness 

to help identify and mitigate flaws.

• Cyber Hygiene Activities: Assess FTC’s Internet accessible systems for known 

vulnerabilities and configuration errors.

• Risk and Vulnerability Assessment: Assessments that combine national threat and 

vulnerability information with data collected and discovered through on-site testing to provide tailored analysis with prioritized remediation recommendations.

Additionally, the OCIO deployed a new intrusion prevention system (IPS) that incorporates automated data loss prevention (DLP). The IPS DLP inspects data packets as 

they move across the network as well as when they exit the network. The IPS DLP can 

identify patterns of personally identifiable information (PII) such as social security and 

credit card numbers.

Furthermore, the OCIO developed the FTC System Development Life Cycle (SDLC) 

methodology that established standard business and technical reviews throughout the 

development of IT solutions to improve:
Performance Plan 89 FYs 2014 and 2015

• Product quality and reduce rework by establishing standard business and technical reviews throughout the development of an IT solution

• Oversight by establishing formal integrated and coordinated reviews

• Performance management of projects through review of project cost and schedule 

alignment with the FTC mission and initiatives

As the IG states, the FTC will consolidate its satellite offices into the newly renovated 

Constitution Center and the FTC Headquarters building. Additionally, the OCIO plans 

to relocate select IT services and applications to the Constitution Center that currently 

are hosted in the New Jersey and Headquarters buildings. This enables the OCIO to 

locate the applications and the services in proximity of the user base and provide for 

future expansion. The OCIO is working with offices within the Office of the Executive 

Director to develop detailed project and acquisition plans to support the consolidation. 

In the area of contingency planning, the OCIO began Business Impact Assessment (BIA) 

activities in FY 2013 to determine FTC essential business functions and processes, and is 

also working to determine the priority of restoration for those functions and processes.

The FTC will continue to strengthen and improve the testing, auditing, and monitoring 

of IT systems and assets.

• In FY 2014, the FTC will rebuild and streamline the development, system integration, and quality assurance test labs using virtualization technology to provide system administrators and developers with more consistently configured 

baselines.

• Also in FY 2014, the FTC will implement and maintain a System Development Life 

Cycle policy and procedure to help plan and implement security within system 

and network components.

• Throughout FY 2014 and FY 2015, the FTC will continue to improve and strengthen its IT Asset Management program to ensure that all FTC IT assets are fully 

accounted for and prevent the unauthorized access to FTC IT assets, data, and 

systems. 

Management Challenge: Ensuring the Protection of Nonpublic Information

An ongoing challenge for the FTC is ensuring the protection of nonpublic information, 

especially given the media attention that FTC competition investigations routinely 

receive. It is critical that the FTC maintain the confidentiality of nonpublic information 

obtained from consumers and businesses in conducting its law enforcement investigations. If the public loses confidence in the FTC’s ability to protect confidential information, it is unlikely they will continue to cooperate, which ultimately would damage the 

FTC’s ability to protect consumers and maintain competition. The FTC may be a source 

of such non-public information because of its interactions with third parties during its 
Performance Plan 90 FYs 2014 and 2015

investigations. The agency also is susceptible to the unauthorized sharing of nonpublic information by insiders. The challenge the FTC faces is to examine whether certain 

long-standing policies and business practices can be revised to ensure that unauthorized sharing of non-public information does not occur.

Although an OIG investigation into the source of non-public information reported in 

the press during the Google investigation failed to reveal any unauthorized disclosures 

by FTC staff, the Agency has committed to taking steps to implement additional safeguards in risk areas identified by the OIG. Policies and business practices are being 

revisited to ensure that Commission staff are keenly aware of their responsibilities to 

safeguard the non-public nature of agency investigations. The effectiveness of these 

changes should be monitored over time and additional actions taken should it be determined that any unauthorized disclosure of nonpublic information has occurred.

Agency Progress in Addressing this Challenge

The FTC takes seriously its obligations to protect nonpublic information. Maintaining 

the confidentiality of nonpublic agency information is critical because obtaining sensitive, nonpublic information from businesses and consumers is the lifeblood of agency 

law enforcement investigations, and those sources would be reluctant to share such 

information in the absence of effective confidentiality safeguards. Unauthorized disclosures would impair the Commission’s ability to protect consumers and maintain 

competition. Accordingly, Commission staff are subject to serious sanctions for unauthorized disclosures of nonpublic information, including criminal prosecution and 

disciplinary action.

The FTC has long had a practice of reminding staff frequently of their ethical and legal 

obligation to keep nonpublic information confidential. The agency is now taking additional steps to guard against unauthorized disclosures. Although staff are aware of 

their responsibility to protect nonpublic information, in FY 2014, the agency will issue 

additional notices and guidance to all staff to reinforce confidentiality requirements. 

Further, the agency will remind staff at each Commission meeting of the importance of 

protecting the confidentiality of discussions at the meeting.

Interactions with the Press. The Office of Public Affairs (OPA) is the primary contact 

point for the media in doing business with the FTC. Staff also speak with the press on a 

broad range of topics. These contacts support the FTC’s initiatives to educate consumers 

about steps they can take to protect themselves and to educate businesses about how to 

comply with the FTC Act and other consumer protection and competition laws. These 

communications also advance statutory and Presidential policies furthering transparency and openness in government.
Performance Plan 91 FYs 2014 and 2015

Commission policies generally allow staff to share only public information with the 

press. The agency will issue new guidance in FY 2014 that reminds staff of this imperative and clarifies that staff must notify OPA of press inquiries about investigations and 

law enforcement matters.

Information provided to third parties. On a limited basis, Commission personnel are permitted to disclose the existence of an investigation to potential witnesses or other third 

parties, but only to the extent necessary to advance the investigation. This practice is 

often essential to the efficient and effective conduct of investigations, including during 

the information-gathering stage and in developing appropriate remedies. For example, 

when the Commission is considering how best to conclude an investigation, it often is 

critical to learn from a variety of third parties about the marketplace, the competitive effects of the conduct under investigation, and the likely effects of any potential remedy. 

To the extent that possible remedies are discussed in such circumstances, staff reminds 

third parties that the information is nonpublic, that no conclusions have been reached, 

and that no inferences should be drawn as to whether violations of law have occurred. 

In FY 2014, the FTC will re-examine how to conduct such communications to minimize 

the risk that confidentiality will be breached, while nonetheless preserving the utility of 

such communications.

The FTC will assess in FY 2014 the effectiveness of both its existing practices to secure 

nonpublic information and these new initiatives.