F E D E R A L T R A D E C O M M I S S I O N 

F I S C A L Y E A R 2 0 2 1 

A G E N C Y 

F I N A N C I A L 

REPORT

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 3

TABLE OF CONTENTS

INTRODUCTION 5

About This Report 6

How This Report Is Organized 7

The FTC At-A-Glance 8

Message from the Chair 9

MANAGEMENT’S DISCUSSION AND ANALYSIS 11

Agency and Mission Information 12

Performance Highlights 17

Management Assurances 30

Forward Looking Information 34

Financial Highlights 35

FINANCIAL SECTION 51

Message from the Chief Financial Officer 52

Inspector General’s Transmittal Letter for Audit Report 53

Report of Independent Auditors 55

Principal Financial Statements 60

Notes to the Financial Statements 66

OTHER INFORMATION 85

Summary of the Top Management and Performance Challenges Identified by the Office of Inspector General 86

Summary of Financial Statement Audit and Management Assurances 88

Payment Integrity 89

Civil Monetary Penalty Adjustment for Inflation Implementation Reporting Act Details 90

APPENDICES 93

Appendix A: Acronyms 94

Appendix B: Contact Information and Acknowledgements 96
4

INTRODUCTION
INTRODUCTION

INTRODUCTION
6 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

INTRODUCTION

ABOUT THIS REPORT

The Federal Trade Commission’s (FTC) fiscal year (FY) 2021 Agency Financial Report (AFR) provides financial 

and high-level performance results and demonstrates to the Congress, the President, and the public the FTC’s 

commitment to its mission and accountability over the resources entrusted to it 

This report, available at the FTC’s website, satisfies the reporting requirements contained in the following legislation: 

n Federal Managers’ Financial Integrity Act of 1982

n Prompt Payment Act of 1982

n Government Performance and Results Act of 1993

n Government Management Reform Act of 1994

n Federal Financial Management Improvement Act of 1996

n Reports Consolidation Act of 2000

n Accountability of Tax Dollars Act of 2002

n Government Performance and Results Modernization Act of 2010

n Improper Payments Elimination and Recovery Improvement Act of 2012

n Digital Accountability and Transparency Act of 2014

n Federal Information Security Modernization Act of 2014

n Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015

n Fraud Reduction and Data Analytics Act of 2015

n Payment Integrity Information Act of 2019

The FTC publishes both an AFR and an Annual Performance Report (APR) The FY 2021 APR will be combined 

with the FY 2023 Annual Performance Plan (APP) and included in the FY 2023 Congressional Budget Justification 

The combined APP and APR will be available at https://www ftc gov/about-ftc/performance along with other 

performance documents 

CERTIFICATE OF EXCELLENCE AND BEST-IN-CLASS AWARD

 

The FTC received the Association of 

Government Accountants’ Certificate 

of Excellence in Accountability 

Reporting for its FY 2020 AFR 

The FTC also received a Special 

Recognition “Best-in-Class” Award 

for creative use of graphics to depict 

the rise in consumer complaints and 

mergers to the FTC’s budget and 

employee resources over the last 8 

years The FY 2020 AFR demonstrates 

the value provided by the FTC, while 

quantifying the benefits the agency 

brought to the American public by 

highlighting examples of cases and 

investigations the agency pursued 
FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 7

INTRODUCTION

HOW THIS REPORT IS ORGANIZED

The FTC Agency Financial Report is organized into the following three major sections, plus supplemental appendices 

1 MANAGEMENT’S DISCUSSION AND ANALYSIS

 The Management’s Discussion and Analysis is required supplementary information that 

provides an overview of the FTC’s financial and summary performance information This 

section includes agency mission and organization, performance goals and highlights, 

management assurances on internal controls, and financial highlights 

2 FINANCIAL SECTION

 This section provides financial details, including the message from the Chief 

Financial Officer, independent auditor’s report, and audited financial statements with 

accompanying notes 

3 OTHER INFORMATION

 This section provides the Office of Inspector General’s summary of top management 

and performance challenges, a summary of financial statement audit and management 

assurances, payment integrity information, and a schedule of civil monetary penalties’ 

adjustments for inflation 

4 APPENDICES

 Appendix A lists the acronyms cited throughout this report; Appendix B provides contact 

information and acknowledgements 

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

MANAGEMENT’S

D I S C U S S I O N 

AND ANALYSIS

FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

O T H E R 

INFORMATION

FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

F I N A N C I A L 

SECTION

OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

APPENDICES
8 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

INTRODUCTION

THE FTC AT-A-GLANCE 

HISTORY

The Federal Trade Commission was created on September 26, 1914, when President Woodrow Wilson signed 

the Federal Trade Commission Act into law The original purpose of the FTC was to prevent unfair methods of 

competition in commerce as part of the battle to “bust the trust ” Over the years, Congress passed additional laws 

giving the agency greater authority to police anticompetitive practices, and in 1938, Congress passed a broad 

prohibition against “unfair and deceptive acts or practices ” Since then, the FTC has been further directed by 

Congress to enforce a wide variety of other consumer protection laws and regulations 

LAWS ENFORCED

The FTC is an independent 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 Examples include the 

Federal Trade Commission Act, Clayton Act, Telemarketing Sales Rule, Fair Credit Reporting Act, Identity Theft Act 

and Equal Credit Opportunity Act In total, the commission has enforcement or administrative responsibilities under 

more than 70 other laws 

PROFILE

The agency is headquartered in Washington, D C and operates in eight regions across the United States 

The agency had 1,123 full-time equivalent employees at the end of FY 2021 

Total new budget authority for FY 2021 is $383 million, which comprises $30 4 million in funding under the American 

Rescue Plan Act of 2021 to address complaints and respond to unfair or deceptive practices related to COVID-19, 

$188 million in general fund appropriations, and $165 million in offsetting collections 

HEADQUARTERS

The FTC established its headquarters at 600 Pennsylvania, N W , with President Franklin D Roosevelt laying the 

cornerstone himself Roosevelt remarked, “May this permanent home of the Federal Trade Commission stand for all 

time as a symbol of the purpose of the government to insist on a greater application of the golden rule to conduct 

the corporation and business enterprises in their relationship to the body politic ” Listen to Franklin D Roosevelt’s 

speech 

The building, which is particularly known 

for its two art deco-style statues, called 

“Man Controlling Trade,” is located at 

the apex of the Federal Triangle, and 

was the culmination of the massive 

Depression-era government building 

project. Commissioners and staff officially 

moved in on April 21, 1938, and the 

building continues to function as the 

FTC’s headquarters, serving the agency’s 

adjudicative, executive, policy, and 

administrative functions.
FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 9

MESSAGE FROM THE CHAIR

Lina M Khan, Chair 

Congress created the FTC to foster fair competition and a thriving economy by 

rooting out unlawful business practices that harm Americans A confluence 

of factors over the last year has made our work particularly challenging A surge 

in merger activity absent any notable increase in agency resources means that 

we are struggling to keep pace and ensure we are fully investigating potentially 

illegal transactions At the same time, the ongoing COVID-19 pandemic has 

created ripe opportunity for fraud and misinformation to proliferate, targeting 

vulnerable families in a time of crisis The Supreme Court’s decision in AMG 

Capital Management curbed one of the agency’s mainstay tools for returning 

money to victims and preventing lawbreakers from pocketing any profits, 

challenging our ability to address the harms from illegal practices and deter 

future violations As this report lays out, the Commission has persisted despite 

these challenges, redoubling our commitment to our mission and our legislative 

mandate I am deeply grateful for the FTC staff’s perseverance and diligence, 

especially given the extreme stresses and uncertainties posed by the global 

pandemic 

On the consumer protection side, the Commission’s enforcement efforts 

resulted in more than $300 million in redress returned to consumers who had 

been harmed and an additional $284 million in civil penalties collected For the 

second year, the agency focused on responding to various COVID-19-related 

scams, including businesses selling cleaning and protective products that were 

never delivered and businesses advertising bogus treatments and cures At the 

first of a new tradition of open Commission meetings, the Commission voted 

to enact the Made in USA Labeling Rule, which will allow the agency to seek a 

variety of remedies, including civil penalties, against companies that make false 

“Made in USA” claims The Commission also issued policy statements signaling 

heightened scrutiny of manufacturer repair restrictions and privacy breaches by 

health apps and devices 

On the competition side, the FTC responded to the near-doubling of merger 

filings by passing a number of process reforms to streamline our investigations 

In FY 2021, the agency concluded 19 matters in which we took action to check 

anticompetitive practices Additionally, 10 ongoing litigations are still active, 

including cases against Facebook and against Vyera Pharmaceuticals and Martin 

Shkreli The agency has also taken steps to ensure we are empowered to use the 

full set of authorities and tools given to us by Congress, including Section 5 of 

the FTC Act, to deter and police unlawful business practices We also recently 

announced with the Department of Justice that we will together be reviewing the 

merger guidelines to determine whether and how they can be updated to better 

reflect empirical learning and market realities 

The Commission is focused on updating its practices to meet the challenges of 

today, which will result in an agency better prepared for the challenges of the 

future We strive to be an agency that is focused on tackling urgent problems, 
10 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

MESSAGE FROM THE CHAIR

learning from new evidence, and course-correcting 

where needed 

FINANCIAL MANAGEMENT 

The FTC takes very seriously our commitment of 

responsible stewardship of the public resources 

entrusted to us by the American taxpayers and 

Congress The agency’s FY 2021 independent financial 

audit yielded our 25th consecutive unmodified opinion, 

the highest audit opinion available The independent 

auditors did not identify any material weaknesses, 

significant deficiencies, or instances of non-compliance 

with internal controls, financial systems, or laws and 

regulations I am pleased to report that management’s 

assessment of risks and review of controls and financial 

systems disclosed no material weaknesses, and that the 

financial and performance data presented here is reliable 

and complete (see Statement of Assurance, p 31) 

MANAGEMENT AND PERFORMANCE 

CHALLENGES 

The Office of Inspector General (OIG) identified five 

management and performance challenges this year: 

(1) securing information systems and networks from 

destruction, data loss, or compromise; (2) seeking 

monetary relief for consumers; (3) controlling expert 

witness costs; (4) ensuring mission success following 

the expiration of current evacuation orders; and (5) 

understanding fraudulent identity theft complaints In 

addition, the OIG highlighted managing records and 

sensitive agency information as a “watch list” item 

that, while not a serious management challenge, still 

requires attention Agency management agrees that 

these are important challenges and concurs with the 

IG’s assessment of our progress in addressing these 

challenges (see p 86) 

The Commission is committed to vigorously enforcing 

the law to protect all Americans and to working with 

federal and state government partners to achieve 

our mission 

Lina M Khan, Chair 

November 12, 2021
FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

M A N A G E M E N T ’ S 

DISCUSSION

A N D A N A LY S I S 
MANAGEMENT’S DISCUSSION AND ANALYSIS

12 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

AGENCY AND MISSION INFORMATION

The work of the Federal Trade Commission (FTC) is 

critical to protecting and strengthening free and open 

markets and promoting informed consumer choice, both 

in the United States (U S ) and around the world The 

FTC performs its mission through the use of a variety of 

tools, including law enforcement, rulemaking, research, 

studies on marketplace trends and legal developments, 

and consumer and business education 

VISION

A vibrant economy characterized by vigorous 

competition and consumer access to accurate 

information 

MISSION

Protecting consumers and competition by preventing 

anticompetitive, deceptive, and unfair business practices 

through law enforcement, advocacy, and education 

without unduly burdening legitimate business activity 

WHAT WE DO

The FTC is a bipartisan federal agency with a unique 

dual mission to protect consumers and promote 

competition For one hundred years, our collegial and 

consensus-driven agency has championed the interests 

of American consumers As we begin our second 

century, the FTC is dedicated to advancing consumer 

interests while encouraging innovation and competition 

in our dynamic economy 

The FTC develops policy and research tools through 

hearings, workshops, and conferences We collaborate 

with law enforcement partners across the country and 

around the world to advance our crucial consumer 

protection and competition missions And beyond 

our borders, we cooperate with international agencies 

and organizations to protect consumers in the global 

marketplace 

PROTECTING CONSUMERS 

The FTC protects consumers by stopping unfair, 

deceptive or fraudulent practices in the marketplace 

We conduct investigations, sue companies and people 

that violate the law, develop rules to ensure a vibrant 

marketplace, and educate consumers and businesses 

about their rights and responsibilities We collect 

reports on hundreds of issues from data security and 

deceptive advertising to identity theft and Do Not Call 

violations, and make them available to law enforcement 

agencies worldwide for follow-up Our experienced and 

motivated staff uses 21st century tools to anticipate – 

and respond to – changes in the marketplace 

PROMOTING COMPETITION

Competition in America is about price, selection, 

and service It benefits consumers by keeping prices 

low and the quality and choice of goods and services 

high By enforcing antitrust laws, the FTC helps 

ensure that our markets are open and free The FTC 

will challenge anticompetitive mergers and business 

practices that could harm consumers by resulting in 

higher prices, lower quality, fewer choices, or reduced 

rates of innovation We monitor business practices, 

review potential mergers, and challenge them when 

appropriate to ensure that the market works according 

to consumer preferences, not illegal practices 

OUR ORGANIZATION

The FTC is headed by a Commission composed of 

five Commissioners, nominated by the President and 

confirmed by the Senate, each serving a staggered 

seven-year term No more than three Commissioners 

may be from the same political party The President 

designates one Commissioner to act as Chair who is 

given the responsibility for the administration of the 

Commission Lina M Khan was sworn in as Chair on 

June 15th, 2021 The four Commissioners at the end 

of FY 2021 are Noah Phillips, Rohit Chopra, Rebecca 

Slaughter, and Christine Wilson who were all sworn in 

during 2018 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 13

Lina M Khan

Chair

Sworn in: June 15, 2021

Noah Joshua Phillips

Commissioner

Sworn in: May 2, 2018

Rohit Chopra

Commissioner

Sworn in: May 2, 2018

Rebecca Kelly Slaughter

Commissioner

Sworn in: May 2, 2018

Christine S Wilson

Commissioner

Sworn in: September 28, 2018

The FTC’s mission is carried out by three bureaus: 

The Bureau of Competition (BC) seeks to prevent 

anticompetitive mergers and other anticompetitive 

business practices in the marketplace By enforcing 

the antitrust laws, the Bureau promotes competition 

and protects consumers’ freedom to choose goods and 

services in an open marketplace at a price and quality 

that fit their needs 

The Bureau of Consumer Protection’s (BCP) mandate 

is to protect consumers against unfair, deceptive or 

fraudulent practices The Bureau enforces a variety of 

consumer protection laws enacted by Congress, as well 

as trade regulation rules issued by the Commission 

Its actions include individual company and industrywide investigations, administrative and federal court 

litigation, rulemaking proceedings, and consumer and 

business education In addition, the Bureau contributes 

to the Commission’s ongoing efforts to inform Congress 

and other government entities of the impact that 

proposed actions could have on consumers 

The Bureau of Economics helps the FTC evaluate the 

economic impact of its actions To do so, the Bureau 

provides economic analysis and support to antitrust and 

consumer protection investigations and rulemakings 

It also analyzes the impact of government regulation 

on competition and consumers and provides Congress, 

the Executive Branch and the public with economic 

analysis of market processes as they relate to antitrust, 

consumer protection, and regulation 

The work of the bureaus is aided by several additional 

offices: 

The Regional Offices work with the Bureaus of 

Competition and Consumer Protection to conduct 

investigations and litigation, provide advice to state 

and local officials on the competitive implications of 

proposed actions, recommend cases, provide local 

outreach services to consumers and businesspersons, 

and coordinate activities with local, state, and regional 

authorities 

The Office of Congressional Relations works closely 

with members of Congress and their staffs The office 

informs Commissioners and FTC staff of Capitol Hill 

issues and policies, and helps provide information 

on legislation of interest to the Commission It also 

coordinates the preparation of both Congressional 

testimony and responses to Congressional inquiries 

concerning FTC policies and programs 

The Office of Public Affairs mission is to reach, inform, 

educate, and engage consumers and businesses through 

media and digital technologies and in collaboration with 

our internal partners to advance consumer protection 

and competition The office is the primary point of 

contact for all news media inquiries 

The Office of the Chief Privacy Officer manages the 

FTC’s internal privacy program and is responsible 

for ensuring that the Commission complies with all 
MANAGEMENT’S DISCUSSION AND ANALYSIS

14 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

applicable privacy laws and guidance The Office of 

the Chief Privacy Officer identifies the privacy risks, 

controls, and mitigating solutions when making 

decisions involving the collection, use, sharing, 

retention, disclosure and destruction of personally 

identifiable information It is also responsible for 

investigating and mitigating privacy incidents, 

supporting the FTC mission with an evolving privacy 

program, and promoting a culture of privacy among FTC 

staff, contractors, and third parties 

The Office of Policy Planning assists the Commission 

to develop and implement long-range competition 

and consumer protection policy initiatives and advises 

staff on cases raising new or complex policy and legal 

issues One of the Office of Policy Planning’s primary 

roles involves advocacy, submitting filings supporting 

competition and consumer protection principles to 

state legislatures, regulatory boards, and officials; 

state and federal courts; other federal agencies; and 

professional organizations The Office also organizes 

public workshops and issues reports on cutting-edge 

competition and consumer protection topics, addressing 

questions of substantive antitrust law, industry-specific 

practices, and significant national and international 

policy debates 

The Office of International Affairs leads and coordinates 

the FTC’s work in international antitrust, consumer 

protection, and technical assistance projects The 

FTC works with competition and consumer protection 

agencies around the world to promote cooperation and 

convergence toward best practices 

The Office of the Secretary oversees prompt processing 

of all matters presented to the Commission, supports 

the Commission decision-making process, and ensures 

it operates efficiently The office also responds to most 

Congressional and White House correspondence raising 

constituent issues 

The Office of the General Counsel is the Commission’s 

chief legal officer and adviser The office represents the 

Commission in court and provides legal counsel to the 

Commission, the three bureaus, and other offices 

The Office of the Executive Director is responsible for 

the administration and management of the Commission 

through four organizations, which manage the 

Commission’s human capital, information technology, 

financial management, administrative services, and 

legal document processing and records management 

activities 

The Office of Administrative Law Judges performs 

the initial adjudicative fact-finding in Commission 

administrative complaint proceedings, guided by the 

FTC Act, the Administrative Procedure Act, relevant 

case law interpreting these statutes, and the FTC’s Rules 

of Practice Administrative Law Judges are independent 

decision makers, appointed under the authority of the 

Office of Personnel Management 

The Office of Inspector General is an independent 

and objective organization within the FTC, established 

in compliance with the Inspector General Act 

Amendments of 1988 Under the Inspector General Act, 

the office conducts audits and investigations relating to 

the programs and operations of the FTC 

The Office of Equal Employment Opportunity and 

Workplace Inclusion ensures that the FTC maintains a 

work environment that is free from all forms of illegal 

discrimination, including reprisal and harassment 

For more information about the agency’s components, 

visit the FTC’s Bureaus and Offices webpage 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 15

FEDERAL TRADE COMMISSION ORGANIZATIONAL CHART

Chair 

Lina M  Khan

Chief of Staff 

Jen Howard

Chief Technologist 

Erie Meyer

Commissioner 

Christine S  Wilson

Commissioner 

Rohit Chopra

Commissioner 

Noah Joshua Phillips

Commissioner 

Rebecca Kelly 

Slaughter

Office of 

Congressional Relations 

Jeanne Bumpus

Office of 

Public Affairs 

Lindsay Kryzak

Office of 

Policy Planning 

Sarah Mackey (Acting)

Office of 

International Affairs 

Randolph W  Tritell

Office of 

the Secretary 

April Tabor

Office of the 

Chief Privacy Officer 

John Krebs

Office of 

Administrative Law Judges* 

D  Michael Chappell

Office of 

Inspector General* 

Andrew Katsaros

Office of Equal Employment 

Opportunity and Workplace 

Inclusion* 

Namon C  Friends (Acting)

Office of the 

General Counsel 

Reilly Dolan 

(Acting)

Bureau of 

Consumer 

Protection 

Samuel Levine

Office of the 

Executive Director 

David B Robbins

Bureau of 

Competition 

Holly Vedova

Bureau of 

Economics 

Marta Wosińska

Regions

* An independent organization within the FTC
MANAGEMENT’S DISCUSSION AND ANALYSIS

16 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

REGIONAL OFFICES

Protecting America’s consumers

Since 1918, regional offices have played an integral role in fulfilling the FTC’s consumer protection and 

competition missions Currently, eight regional offices covering seven geographic regions conduct investigations 

and litigation; provide local outreach to consumers and industry; and build partnerships with local, state, regional, 

and cross-border law enforcement authorities 

The agency is headquartered in Washington, D C , and operates in seven regions across the U S The graphic below 

illustrates the locations of the FTC regions 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 17

PERFORMANCE HIGHLIGHTS 

The FTC has chosen to produce an AFR and a separate 

Annual Performance Report (APR) for FY 2021 The 

APR will be included as part of the FTC’s Congressional 

Budget Justification and will also be available on the 

FTC’s website 

This section explains the FTC’s strategic and 

performance planning framework and summarizes 

the key performance goals 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 

STRATEGIC AND PERFORMANCE PLANNING 

FRAMEWORK 

The FTC’s Annual Performance Report is structured 

around three strategic goals and their supporting 

objectives as established in the FTC Strategic Plan for 

FY 2018 to 2022 The FTC’s strategic goals, objectives, 

and performance measures articulate what the agency 

intends to accomplish to meet its mission, demonstrate 

the highest standards of stewardship, and improve the 

management functions vital to core mission success 

The following table shows the FTC’s net costs for its 

strategic goals 

STRATEGIC GOALS OBJECTIVES

GOAL 1: Protect consumers from 

unfair and deceptive practices in the 

marketplace.

Net Costs: $180 million

1 1 Identify and take actions to address deceptive or unfair 

practices that harm consumers 

1 2 Provide consumers and businesses with knowledge and tools 

that provide guidance and prevent harm 

1 3 Collaborate with domestic and international partners to 

enhance consumer protection 

GOAL 2: Maintain competition to promote 

a marketplace free from anticompetitive 

mergers, business practices, or public 

policy outcomes.

Net Costs: ($68 million)

2 1 Identify and take actions to address anticompetitive mergers 

and practices 

2 2 Engage in effective research, advocacy, and stakeholder 

outreach to promote competition, and advance its 

understanding 

2 3 Collaborate with domestic and international partners to 

preserve and promote competition 

GOAL 3: Advance the FTC’s performance 

through excellence in managing 

resources, human capital, and information 

technology.

Goal 3’s costs are distributed to Goal 1 and Goal 

2 predominately by Goal 1 and Goal 2’s Full-Time 

Equivalent (FTE) usage, except for those non-pay costs 

that are clearly attributable to a specific goal 

3 1 Optimize resource management and infrastructure 

3 2 Cultivate a high-performing, diverse, and engaged 

workforce 

3 3 Optimize technology and information management that 

supports the FTC mission 

Note: Net Costs represent the resources used to achieve strategic goals and signify the relative efficiency and cost-effectiveness of agency 

program/operations The FTC does not divide net costs by objective 
MANAGEMENT’S DISCUSSION AND ANALYSIS

18 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

PERFORMANCE MEASUREMENT REPORTING 

PROCESS 

Bureau and Office representatives serve as the 

Performance Measure Reporting Officials (PMRO), 

who act as data stewards for each of the agency’s 

publicly-reported performance goals The PMROs report 

performance data to the Performance Improvement 

Officer on a quarterly or annual basis via an internal 

data reporting tool The Financial Management Office 

(FMO) also leads periodic performance goal reviews in 

coordination with budget execution reviews Quarterly 

reports are sent to senior managers throughout the 

agency, allowing for adjustments to agency strategies 

based on the interim results 

VERIFICATION AND VALIDATION OF 

PERFORMANCE DATA 

The following outlines how the agency ensures the 

performance information it reports is complete, reliable, 

and accurate: 

n 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 facilitates review of the agency’s 

performance information 

n Each PMRO is responsible for updating the data 

quality appendix (DQA) at least once per year The 

DQA serves as a process document, laying out data 

sources, and collection methods for performance 

information, as well as how metrics are calculated 

n PMROs must provide all supporting documentation 

for their performance results at both the midpoint 

and end of the fiscal year This allows FMO 

Performance Staff to “dig beneath the surface” and 

see the data underlying the metrics 

n After reviewing the underlying data, several 

measures are selected each year to investigate 

more thoroughly, including interviewing the staff 

responsible for data collection, asking about 

alternative methods, and comparing data collection 

and calculations to those reported in the DQA 

PERFORMANCE GOALS OVERVIEW 

In the FY 2018 to 2022 Strategic Plan, the FTC has 

established 36 performance goals and targets for 

assessing program performance against agency 

strategic goals and objectives Of the 36 performance 

goals, nine are considered “key” performance goals 

because they best indicate whether agency activities 

are achieving the desired outcome associated with the 

related objective 

The following tables summarize actual performance 

during FY 2021 against established targets for the FTC’s 

nine key performance goals The tables also include 

results from the prior five fiscal years as well as a 

description of how performance results are calculated 

for that performance goal The FTC met or exceeded FY 

2021 targets on seven of nine key performance goals 

and missed targets on two goals 

LEGEND FOR UPCOMING TABLES 

✔ Signifies that the target was met or exceeded 

X Signifies that the target was not met 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 19

STRATEGIC GOAL 1: PROTECT CONSUMERS FROM UNFAIR AND DECEPTIVE 

PRACTICES IN THE MARKETPLACE 

The FTC uses an interdisciplinary approach to protect the public from unfair and deceptive practices in the 

marketplace The FTC conducts investigations, sues companies and people that violate the law, develops rules to 

protect the public, and educates consumers and businesses about their rights and responsibilities The agency also 

collects reports about a host of consumer issues, including fraud, identity theft, financial matters, and Do Not Call 

violations The FTC makes these reports available to law enforcement agencies worldwide 

KEY PERFORMANCE GOAL 1 1 3:

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

law enforcement 

Description: This measure tracks the efficiency of the FTC’s consumer protection law enforcement spending 

We compare how much money the FTC saves consumers each year through law enforcement to the amount the 

FTC spends on consumer protection law enforcement Consumer savings comprise: (a) the amount of money 

returned to consumers; and (b) an estimate of the amount of harm that would have occurred but for the FTC’s 

law enforcement action To calculate this latter figure, the FTC assumes that the unlawful conduct would have 

continued for one year but for our action The FTC also assumes that the amount of harm that would have occurred 

in that year is the same as what consumers lost in the past Performance Goals 2 1 3 and 2 1 5 are similar measures 

that track the impact of antitrust law enforcement The amount reported is a three-year rolling average (average of 

the current year and two prior year totals) 1

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

$8 80 in 

consumer 

savings per 

$1 spent 

$35 20 in 

consumer 

savings per 

$1 spent 

$39 00 in 

consumer 

savings per 

$1 spent

$38 60 in 

consumer 

savings per 

$1 spent 

$14 40 in 

consumer 

savings per 

$1 spent 

$13 00 in 

consumer 

savings per 

$1 spent

$7 00 in 

consumer 

savings per 

$1 spent 

✔

1 Calculation/Formula: (Amount of money returned to consumers + the sum of the estimated consumer savings generated by law enforcement actions) / 

Annual expenditures on consumer protection law enforcement 

The amount of money returned to consumers: the sum of refund checks cashed by consumers as the result of FTC consumer protection enforcement 

actions plus the amount of redress distributed to consumers without FTC contractors (if refund check cashed information is not available) 

The sum of the estimated consumer savings generated by law enforcement actions: the estimate of harm that would have occurred but for the FTC’s law 

enforcement action The FTC assumes that the unlawful conduct would have continued for one year but for our action and the amount of harm that would 

have occurred in that year is the same as what consumers lost in the past This amount is estimated by BCP case managers by estimating the consumer 

loss due to fraudulent, deceptive, or unfair practices in the 12 months prior to the FTC’s first contact with the defendants or by dividing the estimated 

total economic injury by the amount of time the defendants’ business operated to derive an annualized estimate of consumer savings The measure 

also includes instances wherein, as a result of FTC law enforcement action directed specifically at a business, that business stops its allegedly unfair or 

deceptive practices 

The annual expenditures on consumer protection law enforcement: the FTC budget dollars spent on consumer protection law enforcement Dollars spent 

on the Consumer and Business Education and Economics and Consumer Policy work are excluded from this calculation 

For more details on measurement and data quality, see the FTC Data Quality Appendix 
MANAGEMENT’S DISCUSSION AND ANALYSIS

20 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

KEY PERFORMANCE GOAL 1 1 4:

The amount of money the FTC returned to consumers or forwarded to the U S Treasury resulting from 

FTC enforcement action 

Description: This goal tracks the FTC’s effectiveness in returning money to consumers who were defrauded and 

forwarding money to the U S Treasury (e g , if sending money to individuals is impracticable, or if funds were 

paid as a civil penalty) The FTC targets law enforcement efforts on violations that cause the greatest amount 

of consumer harm; the amount of money returned to consumers or forwarded to the U S Treasury is a useful 

indicator that the FTC is targeting the right defendants The number reported is a three-year rolling average 

(average of the current year and two prior year totals) 2

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

$95 2 

million

$2 69 

billion

$3 25

 billion

$3 52 

billion 

$2 79 

billion

$2 39 

billion

$65 

million ✔

2

 Calculation/Formula: Sum of refund checks cashed by consumers, plus the amount of redress distributed to consumers without FTC contractors (if refund 

check cashed information is not available), plus the amount of money paid to the FTC by defendants and forwarded to the U S Treasury, either because 

sending refunds was not feasible or because the money was paid as a civil penalty The amount reported is a three-year rolling average (average of the 

current year and two prior year totals) 

For more details on measurement and data quality, see the FTC Data Quality Appendix 

$61 7 MILLION SETTLEMENT WITH AMAZON 

Amazon agreed to pay more than $61 7 million to 

settle FTC charges that it failed to pay Amazon Flex 

drivers the full amount of tips they received from 

Amazon customers The FTC alleged that in its 

app and numerous marketing materials, Amazon 

advertised that drivers could earn $18 to $25 per 

hour plus 100% of customer tips According to 

the FTC, during a two-and-a-half year period from 

2016 to 2019, Amazon used about $61 7 million 

in tips to subsidize drivers’ base pay Customers 

thought they were tipping drivers, not Amazon, 

and drivers were left shortchanged The FTC’s 

complaint alleges that the company stopped its behavior only after becoming aware of the FTC’s investigation 

in 2019 The $61 7 million represents the full amount that Amazon allegedly withheld from drivers and will be 

used by the FTC to compensate drivers 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 21

 

KEY PERFORMANCE GOAL 1 2 1:

Rate of consumer satisfaction with FTC consumer education websites 

Description: This measure gauges the effectiveness, helpfulness, and usability of the FTC’s consumer education 

websites Consumer education serves as the first line of defense against deception and unfair practices Wellinformed consumers are better able to protect themselves from bad actors in the marketplace This measure 

includes the customer satisfaction scores for consumer ftc gov 3

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

76 77 76 5 77 7 76 2 72 9

74 6

(average 

rate for 

websites)

X

3

 Calculation/Formula: When visiting consumer ftc gov, consumers are given the option to complete a short survey to provide feedback on the following 

aspects of the site: information browsing, look and feel, navigation, site information, and site performance The formula for the overall satisfaction score is 

proprietary to ForeSee 

For more details on measurement and data quality, see the FTC Data Quality Appendix 

HALTING COVID-RELATED FRAUDS 

The FTC has worked vigorously to halt 

COVID-related scams It has sued entities for 

allegedly breaking promises to quickly ship 

personal protective equipment and cleaning 

products, as well as tricking consumers into 

paying for sanitizing products that were never 

delivered, falsely claiming that their products 

could treat and/or prevent COVID-19, and 

making deceptive claims regarding stimulus 

benefits The FTC made quick use of the civil 

penalty authority granted under the COVID-19 

Consumer Protection Act, filing two cases 

within months of its passage The FTC complemented these efforts by alerting the public about these scams and 

sending cease and desist orders warning marketers to stop making unsubstantiated claims that their products 

and therapies can prevent or treat COVID-19 The FTC will continue to bring enforcement actions against 

companies that make false claims related to COVID-19 and will continue to work closely with other enforcement 

authorities and stakeholders to halt this fraud For more information on the FTC’s response to COVID-19, please 

visit https://www ftc gov/coronavirus
MANAGEMENT’S DISCUSSION AND ANALYSIS

22 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

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 

Description: The Office of International Affairs works to expand cooperation and coordination between the 

FTC and international consumer protection partners through information sharing, investigative assistance, and 

the development of investigative best practices and enforcement capacity This measure counts the number 

of investigations and cases in which the FTC and foreign consumer protection agencies shared information or 

engaged in other enforcement cooperation 4

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

53 50 43 48 42 39 32 ✔

4 Calculation/Formula: # of FTC consumer protection investigations or cases where supporting evidence or information or other investigative assistance 

was obtained from foreign agencies + # of foreign consumer protection investigations or cases where supporting evidence or information or other 

investigative assistance was provided by the FTC + # of enforcement matters where the FTC otherwise engaged in enforcement cooperation with foreign 

agencies or multilateral enforcement networks 

For more details on measurement and data quality, see the FTC Data Quality Appendix 

FTC ISSUES RULE TO DETER RAMPANT “MADE IN USA” FRAUD 

The FTC finalized a new rule that will crack down 

on marketers who make false, unqualified claims 

that their products are “Made in the USA ” Under 

the rule, marketers making unqualified Made in USA 

claims on labels must prove that their products are 

“all or virtually all” made in the United States The 

new rule codifies a broader range of remedies by the 

FTC, including the ability to seek redress, damages, 

penalties, and other relief from those who lie about a 

Made in USA label It will enable the Commission for 

the first time to seek civil penalties of up to $43,280 

per violation of the rule The rule prohibits marketers from including unqualified Made in USA claims on labels 

unless: 1) final assembly or processing of the product occurs in the United States; 2) all significant processing 

that goes into the product occurs in the United States; and 3) all or virtually all ingredients or components of 

the product are made and sourced in the United States 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 23

FTC MOVES TO BLOCK ANTICOMPETITIVE MERGERS 

Cancer Detection Tests: In March 2021, the Commission 

challenged Illumina’s proposed acquisition of Grail, 

makers of DNA-sequencing-based, non-invasive early 

detection liquid biopsy tests used in screening for multiple 

types of cancer According to the complaint, Illumina is the 

only provider of these multi-cancer early detection (MCED) 

testing services in the United States, and the deal would 

likely diminish innovation in the U S market for MCED 

services, which have the potential to identify up to 50 types 

of cancer and save millions of lives This matter is pending in 

administrative adjudication 

Health Care Providers: This year, the FTC challenged two anticompetitive mergers amongst competing 

health care providers In November 2020, the Commission challenged Methodist Le Bonheur Healthcare’s 

proposed $350 million acquisition of two Memphis-area hospitals from Tenet Healthcare Corporation The 

Commission’s complaint alleged that the transaction would have lessened competition for inpatient general 

acute care services in the Memphis area by reducing from four to three the number of hospital systems operating 

in the area, leading to higher prices and reduced quality Shortly after the FTC issued its complaint, the parties 

abandoned their proposed transaction In December 2020, the FTC opposed Hackensack Meridian Health’s 

proposed acquisition of Englewood Health According to the complaint, the deal would eliminate close competition 

between the health care providers in the Bergen County, NJ area, giving the combined hospital system increased 

leverage with insurers, leading to higher insurance premiums, co-pays, deductibles, and other out-of-pocket 

expenses The court granted the FTC a preliminary injunction in August 2021, while the case continues 

Apartment Rental Listing Services: In November 2020, the Commission sued to block CoStar’s proposed 

acquisition of competitor RentPath The two firms both operate online platforms such as Apartments com 

(CoStar) or Rent com (RentPath) for renters to identify available apartments According to the complaint, 

the acquisition would significantly increase concentration for internet listing services advertising for large 

apartment complexes (more than 100 units) in 49 metropolitan areas throughout the United States After the 

Commission issued its complaint, the parties announced the abandonment of the proposed merger 

Shaving Razors: In December 2020, the FTC challenged Procter & Gamble’s proposed acquisition of nascent 

rival Billie, a direct-to-consumer seller of women’s shaving and body care products According to the complaint, 

the acquisition would have allowed Procter & Gamble, the leader in both women’s and men’s wet shave razors, 

to eliminate the threat to its business posed by the growing rival firm, and return to its dominant position to the 

detriment of consumers The parties abandoned the merger after the FTC action 

Cement Makers: In May 2021, the FTC challenged Lehigh Cement Company’s proposed acquisitions of rival 

cement producer Keystone Cement Company The complaint alleged the deal would have harmed competition 

in the market for gray Portland cement, a key ingredient used to make concrete, in the eastern Pennsylvania and 

western New Jersey areas by reducing the number of significant competitors in the market from 4 to 3 Cement 

markets are generally local or regional due to the substantial transportation costs driven by the extreme weight 

of the products Shortly after the Commission issued its complaint, the parties abandoned the proposed 

merger 
MANAGEMENT’S DISCUSSION AND ANALYSIS

24 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

STRATEGIC GOAL 2: MAINTAIN COMPETITION TO PROMOTE A MARKETPLACE 

FREE FROM ANTICOMPETITIVE MERGERS, BUSINESS PRACTICES, OR PUBLIC POLICY 

OUTCOMES 

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

through enforcement The FTC also engages in policy research and development, advocacy, and education to deter 

anticompetitive practices and encourage federal, state, and local governments to evaluate the effects of their policies 

on competition The FTC advances these goals internationally by fostering enforcement and policy convergence and 

through cooperation with counterpart foreign enforcement authorities This work is critical to protect and strengthen 

free and open markets – the cornerstone of a vibrant economy 

KEY PERFORMANCE GOAL 2 1 1:

Percentage of full merger and nonmerger investigations in which the FTC takes action to maintain 

competition 

Description: This measure tracks FTC actions taken to maintain competition, including litigated victories, consent 

orders, abandoned transactions, or restructured transactions (either through a fix-it-first approach or eliminating 

the competitive concern) in a significant percentage of full merger and nonmerger investigations Not counted in 

the percentage are investigations that the Commission chooses not to take action, as well as defeats in litigation 5

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

54 6% 49 1% 67 9% 62 9% 77 1% 67 9% 50%-80% ✔

5

 Calculation/Formula: The measure is calculated by taking the number of full investigations concluded with an action during the fiscal year divided by the 

total number of full investigations concluded during the fiscal year 

 For more details on measurement and data quality, see the FTC Data Quality Appendix 

THE FTC SUES FACEBOOK FOR MONOPOLIZATION 

In December 2020, the Commission filed a 

landmark monopolization case against Facebook 

in federal court alleging the company has 

engaged in a systematic buy-or-bury scheme, 

including the acquisition of nascent competitors 

and monitoring of promising app developers, to 

maintain its monopoly, allowing Facebook to impose 

anticompetitive terms on innovative competitors 

In August 2021, the Commission filed an amended 

complaint that includes additional data and 

evidence to support the FTC’s contention that 

Facebook is a monopolist that abused its excessive market power to eliminate threats to its dominance This 

matter is pending in federal court 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 25

KEY PERFORMANCE GOAL 2 1 3:

Total consumer savings compared to the amount of FTC resources allocated to the merger program 

Description: This measure reports the estimated amount of money that the Commission saved consumers by 

taking action against potentially anticompetitive mergers compared to the amount spent on the merger program 

The amount reported is a five-year rolling average (average of the current year and four prior year totals) 6

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

$46 40 in 

consumer 

savings per 

$1 spent 

$55 60 in 

consumer 

savings per 

$1 spent 

$50 30 in 

consumer 

savings per 

$1 spent 

$65 90 in 

consumer 

savings per 

$1 spent 

$25 70 in 

consumer 

savings per 

$1 spent 

$27 00 in 

consumer 

savings per 

$1 spent 

$35 00 in 

consumer 

savings per 

$1 spent 

X

6

 Calculation/Formula: Estimated consumer savings generated under goal 2 1 2 are divided by the amount of resources spent on the merger program for the 

current fiscal year When available, staff uses case-specific data to generate the estimate of consumer savings Otherwise, staff uses a formula of three 

percent of the volume of commerce of the relevant product market(s) for two years In order to create a balanced performance profile, performance is 

reported as a “rolling average” over five years, compensating for highly variable results in any individual year due to the influence of a few significant cases 

or the level of merger activity in that year 

 For more details on measurement and data quality, see the FTC Data Quality Appendix 

FTC STOPS CASH ADVANCE FIRM 

Yellowstone Capital, a provider of merchant 

cash advances, agreed to pay more than 

$9 8 million to settle FTC charges that it took 

money from businesses’ bank accounts without 

permission and deceived them about the 

amount of financing business owners would 

receive and other features of its financing 

products Merchant cash advances are a form 

of financing in which a company provides 

money to a small business up front in exchange 

for a larger amount repaid through daily 

automatic payments In this case, the FTC alleged that Yellowstone and its owners continued withdrawing 

money from businesses’ bank accounts after their balance had been repaid The complaint alleged that these 

unauthorized withdrawals left businesses without needed cash and that any refunds from the company 

could take weeks or months In addition to the monetary judgment, the settlement permanently prohibits the 

defendants from misleading consumers about the terms of their financing, including the amount and timing of 

any fees and whether business owners are required to be personally liable for the financing The defendants 

will also be prohibited from making withdrawals from consumers’ bank accounts without their express 

informed consent 
MANAGEMENT’S DISCUSSION AND ANALYSIS

26 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

FTC REINVIGORATES ENFORCEMENT AMIDST MERGER WAVE 

The Hart-Scott-Rodino (HSR) Act requires that companies provide the FTC and Department of Justice (DOJ) 

with advance notice of certain transactions above a certain threshold (currently transactions exceeding 

$92 million) The law provides the agencies 30 days to conduct an initial investigation and to determine 

whether additional information is needed to assess the legality of the transaction If the FTC or DOJ seeks 

additional information through what is known as a “second request,” the law prohibits merging firms from 

consummating a transaction until the companies have substantially complied with the second request 

In FY 2021, HSR transactions reported have reached their highest level since the filing thresholds were 

amended by Congress in 2001, straining the agency’s ability to act within statutory time constraints 

The Commission has moved quickly to adapt to the record setting volume of transactions, shifting its limited 

resources to accommodate the wave of reported acquisitions, and implementing a series of process reforms 

aimed at streamlining the investigative process while increasing the analytical rigor of investigations 

Additionally, the agency has acknowledged that in certain instances, it may not be able to rigorously 

investigate transactions ahead of statutory deadlines but has reasserted its authority to determine a merger 

is unlawful, even after the companies have merged, and even if a merger was subject to premerger review 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 27

KEY PERFORMANCE GOAL 2 1 5:

Total consumer savings compared to the amount of FTC resources allocated to the nonmerger program 

Description: This measure reports the estimated amount of money that the Commission saved consumers 

by taking action against potentially anticompetitive business conduct compared to the amount spent on the 

nonmerger program The amount reported is a five-year “rolling average” (average of the current year and four 

prior year totals) 7

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

$52 30 in 

consumer 

savings per 

$1 spent 

$39 60 in 

consumer 

savings per 

$1 spent 

$40 10 in 

consumer 

savings per 

$1 spent 

$75 80 in 

consumer 

savings per 

$1 spent 

$46 00 in 

consumer 

savings per 

$1 spent 

$46 00 in 

consumer 

savings per 

$1 spent 

$35 00 in 

consumer 

savings per 

$1 spent 

✔

7 Calculation/Formula: Estimated consumer savings generated under goal 2 1 4 are divided by the amount of resources spent on the nonmerger program 

for the current fiscal year When available, staff uses case-specific data to generate the estimate of consumer savings Otherwise, staff uses a formula 

of one percent of the volume of commerce of the relevant geographic/product market(s) for one year In order to create a balanced performance profile, 

performance is reported as a “rolling average” over five years, compensating for highly variable results in any individual year due to the influence of a few 

significant cases or the level of nonmerger activity in that year 

 For more details on measurement and data quality, see the FTC Data Quality Appendix 

PHARMACEUTICAL COMPANIES SUED AGAIN FOR ANTICOMPETITIVE AGREEMENT 

The Commission sued Endo Pharmaceuticals and 

Impax Laboratories this year alleging that a 2017 

agreement between them violated the antitrust 

laws by eliminating competition in the market for 

oxymorphone ER According to the complaint, after 

withdrawing its reformulated version of Opana ER 

due to FDA safety concerns, Endo entered into an 

agreement with Impax to share their monopoly 

profits, as the only version of the drug on the 

market, rather than relaunching a competing 

product This matter is pending in federal court The FTC previously found that a 2010 agreement between the 

parties in which Endo paid Impax not to compete by launching a generic version of Opana ER was an illegal 

reverse-payment settlement In April 2021, that decision was upheld on appeal 
MANAGEMENT’S DISCUSSION AND ANALYSIS

28 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

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 

Description: The Office of International Affairs strives to ensure appropriate cooperation on and coordination 

of investigations under parallel review by the FTC and foreign competition agencies This measure gauges the 

effectiveness of the FTC’s enforcement cooperation with foreign antitrust authorities pursuing parallel enforcement 

activities 8

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2021

Actual

FY 2021

Target

FY 

2021

Status

100% 96% 98% 100% 100% 100% 95% ✔

8

 Calculation/Formula: # of FTC cases, with at least one substantive contact with a foreign antitrust agency, where the foreign agency is pursuing a case 

against the same company(ies) and where they followed consistent analytical approaches and reached compatible outcomes / # of FTC cases where the 

FTC had at least one substantive contact with a foreign antitrust agency, where the foreign agency is pursuing a case against the same company(ies) 

For more details on measurement and data quality, see the FTC Data Quality Appendix 

FTC LAUNCHES INITIATIVE TO ENCOURAGE LOWER-INCOME COMMUNITIES 

TO REPORT FRAUD 

The FTC launched a new initiative aimed at partnering with 

community legal aid organizations to expand its outreach to lowerincome communities to encourage them to report fraud and provide 

them with advice to help recover The Community Advocate Center 

initiative provides a new way for organizations that provide free and 

low-cost legal services to report fraud and other illegal business 

practices their clients have experienced directly to the FTC on 

behalf of their clients By participating with the FTC’s Community 

Advocate Center, organizations can connect members of their 

communities to specific, concrete steps they can take to try to get 

their money back They also will receive aggregated data detailing 

the types of fraud and other illegal business practices affecting 

their communities, such as the methods scammers use to defraud 

consumers, the methods they use to demand payment, and the amount of money consumers report losing 

Information about the Community Advocate center is available at ReportFraud ftc gov/community 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 29

STRATEGIC GOAL 3: ADVANCE THE FTC’S PERFORMANCE THROUGH EXCELLENCE IN 

MANAGING RESOURCES, HUMAN CAPITAL, AND INFORMATION TECHNOLOGY 

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

foundation for overall mission success The agency’s work in Strategic Goal 3 highlights ongoing efforts to improve 

the management of agency staffing, finances, information, and physical assets, in order to create a more efficient and 

more agile agency 

KEY PERFORMANCE GOAL 3 2 3:

The extent to which employees believe the FTC cultivates engagement throughout the agency 

Description: The Employee Engagement Index of the Federal Employee Viewpoint Survey (FEVS) determines 

this measure The Index gauges the extent to which employees believe that management listens and provides 

meaningful support and feedback in various areas that assist staff in supporting the overall mission of the agency 9

Note regarding results: Due to the 2020 FEVS Survey being delayed, we did not have results to publish in our FY 

2020 AFR This year, with the results from the 2021 FEVS survey being delayed, we are publishing the FY 2020 

results, which came out in April 2021 

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020

Status

82% 83% 83% 84% 87% 82% (Government 

average +10 points) ✔

9

 Calculation/Formula: The FEVS Employee Engagement Index measures conditions important to supporting employee engagement through responses 

to 20 questions across the three sub factors described above The FEVS automatically calculates an agency Index score from responses to these 20 

questions 

 For more details on measurement and data quality, see the FTC Data Quality Appendix 
MANAGEMENT’S DISCUSSION AND ANALYSIS

30 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

MANAGEMENT ASSURANCES 

IMPLEMENTATION OF THE FEDERAL 

MANAGERS’ FINANCIAL INTEGRITY ACT 

(FMFIA) 

The FTC’s Enterprise Risk Management (ERM) 

and internal controls are integral to managing daily 

operations and carrying out activities that achieve 

strategic goals and objectives Internal controls are 

part of all agency systems and processes Senior 

management holds managers accountable for 

documenting, assessing, and improving these controls in 

order to provide efficient and effective risk management, 

program operations, high-quality data, and accurate 

reporting as well as program compliance with applicable 

laws and regulations 

The FTC’s Senior Management Council (SMC) 

provides oversight to the Senior Assessment Team 

(SAT) activities and is instrumental in the strategic 

direction and mitigation strategies for the Agency’s 

most significant risks The SAT plans and executes the 

Agency’s enterprise risk and internal control program 

activities to include fraud reduction initiatives This 

includes assessing and improving compliance with 

applicable guidance (e g , Office of Management and 

Budget Circular A-123, Management Responsibilities 

for Enterprise Risk Management and Internal Controls), 

monitoring and remediation of identified risk, and 

communicating the results of reviews to senior 

management and the head of the agency 

SAT activities in FY 2021 included planning the 

annual internal controls assessments; identifying key 

processes and related control activities; documenting 

the scope, design, and methodology of risk and internal 

control assessments; testing of internal controls; and 

monitoring corrective action plans and the remediation 

progress In addition, the SMC updated the agency risk 

profile, including risks related to successful mission 

performance Specifically, the FTC’s profile identified 

risk associated with the Supreme Court ruling in AMG 

Capital Management, LLC v. Federal Trade Commission, 

593 U S __, 141 S Ct 1341 (2021), removing the FTC’s 

authority to seek monetary relief for consumers per 

Section 13(b) In addition, the profile listed risks of 

escalating expert witness costs in cases involving 

market competition, impacts of budget constraints 

as they influence litigation options for the consumer 

protection mission, and the schedule risk and cost risk 

associated with the FTC’s technology initiatives Risks 

related to creating a new work environment following 

the expiration of the COVID-19 pandemic emergency 

evacuation orders have also been noted The FTC 

leadership uses the risk profile to monitor agency 

operations, to make budget and resource decisions, and 

to assess mitigation strategies and activities 

This year, the FTC continued with the implementation 

of an ERM program plan and strategy Activities for 

FY 2021 included executing an annual segment of the 

multi-year internal control assessment plan, monitoring 

existing risk registers, identifying and analyzing risk, 

assessing entity level control, and monitoring corrective 

actions, as well as performing Digital Accountability 

and Transparency Act of 2014 (DATA Act) control 

assessments and OMB-directed Internal Control Over 

Reporting assessments In determining if there were any 

management control deficiencies or nonconformance 

that must be disclosed in the annual assurance 

statement, the SAT and the FTC Chair evaluated 

several sources of information These included results 

of ERM activities, other information from independent 

audits or reviews performed by the Office of Inspector 

General (OIG), the Government Accountability Office 

(GAO) (e g , Federal Information Security Management 

Act review), independent audits of service providers’ 

operations and financial systems (e g , reviews 

conducted in accordance with Statement on Standards 

for Attestation Engagements (SSAE No 18)), and other 

relevant evaluations and control assessments 

The Chair’s assurance statement below is supported by 

the processes and reviews described above, which were 

performed in FY 2021 Management assurance tables 

appear in the Other Information section 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 31

UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

CHAIR’S FMFIA STATEMENT OF ASSURANCE

The Federal Trade Commission’s (FTC) management is responsible for establishing and 

maintaining effective risk management, internal control and financial management systems that 

meet the objectives of the Federal Managers’ Financial Integrity Act of 1982 (FMFIA). 

In accordance with the requirements of the Office of Management and Budget (OMB) Circular 

A-123, Management’s Responsibility for Enterprise Risk Management and Internal Control, the

FTC conducted its annual assessment of the effectiveness of the organization’s internal controls

to support effective and efficient programmatic operations, reliable financial reporting, and

compliance with applicable laws and regulations; and whether the financial management system

conforms to applicable financial systems requirements.

Based on the results of this assessment, the FTC provides an unmodified assurance that it’s 

internal controls over the effectiveness and efficiency of operations, reliable financial reporting 

and compliance with applicable laws and regulations as of September 30, 2021, were operating 

effectively and that no material weaknesses were found in the design or operation of our internal 

controls. Some reporting officials identified areas for improvement in their individual 

assessments, which are being addressed internally and are not of a material nature.

Further, based on our assessment, we provide an unmodified statement of assurance (no material 

weaknesses or lack of compliance reported) that the FTC financial management systems 

substantially conform with the Federal Financial Management Improvement Act of 1996 

(FFMIA), applicable financial systems requirements, applicable Federal accounting standards 

and the U.S. Standard General Ledger at the transaction level. 

Signed _

Lina M. Khan 

Chair

October 31, 2021
MANAGEMENT’S DISCUSSION AND ANALYSIS

32 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

SUMMARY OF MATERIAL WEAKNESS AND 

NONCONFORMANCES 

As noted in the Chair’s FMFIA Statement of 

Assurance, the FTC has no material weaknesses or 

nonconformances to report for FY 2021 No new 

material weaknesses or significant nonconformances 

have been identified for over ten years, nor any existing 

unresolved weaknesses requiring corrective action 

FEDERAL INFORMATION SECURITY 

MANAGEMENT ACT (FISMA) 

As mandated by FISMA, the agency continues to 

maintain an information security program to manage 

information technology in accordance with OMB 

Circular A-130 requirements and National Institute of 

Standards and Technology guidance During FY 2021, 

the FTC decommissioned one system and performed 

four assessment and authorization efforts The FTC 

currently has six systems authorized to operate 

The FTC leverages twenty-two Federal Risk and 

Authorization Management Program cloud service 

providers 

DIGITAL ACCOUNTABILITY AND 

TRANSPARENCY ACT OF 2014 (DATA ACT) 

The DATA Act expands the Federal Funding 

Accountability and Transparency Act of 2006 to 

increase accountability and transparency in federal 

spending, making federal expenditure information more 

accessible to the public; improve the quality of the 

information on USASpending gov, as verified through 

regular audits of the posted data; and to streamline 

and simplify reporting requirements through clear data 

standards The FTC successfully transmitted the data 

files, and certified the quarterly submissions as required 

by the government-wide requirements set by OMB and 

the U S Department of Treasury 

DEBT COLLECTION IMPROVEMENT ACT 

The Debt Collection Improvement Act of 1996 

prescribes standards for the administrative collection, 

compromise, suspension, and termination of Federal 

agency collection actions and referrals to the proper 

agency for litigation The FTC monitors, administers, 

and collects on debts less than 120 days delinquent The 

FTC also monitors, administers, and collects on debts 

more than 120 days delinquent Eligible, nonexempt 

debts more than 120 days old are transferred to the 

U S Department of the Treasury for cross-servicing 

In addition, recurring payments were processed by 

electronic funds transfer in accordance with the 

provisions of the Debt Collection Improvement Act 

PROMPT PAYMENT ACT 

The Prompt Payment Act requires Federal agencies to 

make timely payments to vendors, including any interest 

penalties for late invoice payments In FY 2021, the FTC 

processed 2,159 invoices totaling $91 6 million that were 

subject to prompt payment Of these invoices, 99 4 

percent were paid on time During FY 2021, the FTC 

paid a total of $67 27 in interest penalties, or 0 000074 

percent of the total dollar amount invoiced 

AGENCY FINANCIAL MANAGEMENT SYSTEMS 

STRATEGY 

The FTC’s overall strategy for its financial management 

systems is to ensure that the systems provide accurate, 

reliable, and timely information for management 

decision-making, maintain effective internal controls, 

and comply with applicable laws and regulations It is 

also critical that the financial management systems 

support both operational efficiency and effectiveness in 

meeting the agency’s strategic goals 

Through FY 2019, the Department of the Interior’s 

Interior Business Center (IBC) provided financial 

management system services for the FTC Beginning 

in FY 2020, the FTC moved its needs for financial 

management systems and support services to the 

Department of the Treasury’s Administrative Resource 

Center (ARC) to improve operational efficiencies and 

effectiveness The IBC continues to provide personnel 

and payroll support services for the FTC, which it has 

been providing for the agency since 1998 

The FTC uses the Oracle Federal Financials (OFF) 

system as its core financial management system and 

the Oracle Business Intelligence reporting capabilities 

to produce timely reports that support agency 

requirements The FTC also uses several systems 

that integrate with OFF to support agency operations, 

including the Invoice Processing Platform (IPP) for 

efficient and secure processing of invoices, the Concur 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 33

Government Edition to manage travel transactions, and 

the Procurement Information System for Management 

for contract actions 

Since migrating to the new shared services provider, the 

agency continued its efforts to maintain and enhance 

financial management systems to promote operational 

effectiveness, efficiency, reliability, and timeliness of 

data to support the agency’s strategic goals The FTC 

redesigned and improved several financial management 

business processes and procedures and developed new 

tools and reports to assess its financial management 

operations that ultimately contribute to its mission 

success 

The FTC recognizes the importance of financial 

management systems and oversight as part of serving 

as a good steward of taxpayer dollars entrusted to 

it Accordingly, in FY 2021, the FTC will continue to 

work to refine its financial management processes and 

procedures to optimize the performance of operations 

and reporting In addition, the agency will work with the 

Department of the Treasury to implement G-invoicing, 

the long-term sustainable solution to improve the 

quality of Intragovernmental Transactions 

FEDERAL CIVIL PENALTIES INFLATION 

ADJUSTMENT ACT OF 1990 

As established by statutory civil penalty provisions, 

the FTC has jurisdiction to charge civil penalties for 

violations specified in the FTC Act and several other 

laws the Commission is responsible for administering 

and enforcing The FTC adjusts these civil penalty 

amounts for cost of living, as required by Federal Civil 

Penalties Inflation Adjustment Act of 2015 

Details about the FTC’s types of civil penalties, the 

authority for the penalty, adjustment dates, and current 

penalty amount can be found in the Other Information 

section of this report 

FRAUD REDUCTION DATA ANALYTICS ACT 

The Fraud Reduction and Data Analytics Act of 2015 

was passed to improve federal agency financial and 

administrative controls and procedures to assess and 

mitigate fraud risks, and to improve Federal agencies’ 

development and use of data analytics for the purpose 

of identifying, preventing, and responding to fraud, 

including improper payments 

During Fiscal Year 2021, the FTC expanded its fraud 

risk program, strengthened the agency’s processes, 

and improved internal controls to prevent, detect, and 

mitigate fraud risks Please see the Fraud Reduction 

Report in the Other Information section of this report for 

additional information 

ANTIDEFICIENCY ACT 

The Antideficiency Act prohibits federal agencies 

from spending or obligating funds in excess of 

amounts and purposes approved by Congress, and 

from accepting voluntary services The FTC‘s funds 

controls and continuing reviews of funds usage and 

availability ensure it complies with requirements of the 

Antideficiency Act 
MANAGEMENT’S DISCUSSION AND ANALYSIS

34 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

FORWARD LOOKING INFORMATION

The Federal Trade Commission’s (FTC) mission is to 

protect consumers and competition by preventing 

anticompetitive, deceptive, and unfair business 

processes through law enforcement, advocacy, and 

education without unduly burdening legitimate business 

activity 

The FTC appreciates the five Management Challenges 

identified by the Inspector General (IG) and agrees 

that these are critically important areas to focus on 

and to improve in FY 2022 These include: Securing 

Information Systems and Networks from Destruction, 

Data Loss, or Compromise; Seeking Monetary Relief 

for Consumers; Controlling Expert Witness Costs; 

Ensuring Mission Success Following the Expiration 

of Current Evacuation Orders; and Understanding 

Fraudulent Identify Theft Complaints In FY 2021 the 

FTC took numerous steps to address the challenges and 

will continue going forward into FY 2022 Regarding 

securing our information systems, the FTC will continue 

to manage essential supporting IT activities by taking 

a risk-based, cost-effective approach To continue 

controlling Expert Witness costs the FTC will continue 

to leverage in-house economist resources when 

possible 

In addition, the IG is currently conducting a performance 

audit of the FTC’s Contracting Officer’s Representative 

program In FY 2022, the FTC management will evaluate 

any findings and recommendations and, if appropriate, 

will incorporate changes into our Contracting Officer’s 

Representative program 

FY 2021 was the second year the FTC received financial 

management services from the Department of the 

Treasury’s Administrative Resource Center Since 

migrating to the new shared services provider, the 

agency continued its efforts to maintain and enhance 

financial management systems to promote operational 

effectiveness, efficiency, reliability, and timeliness of 

data to support the agency’s strategic goals In FY 

2021, The FTC leveraged reporting tools to automate 

several financial management business processes In 

FY 2022, we will continue efforts to document end to 

end business processes and identifying opportunities 

to improve 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 35

FINANCIAL HIGHLIGHTS

INTRODUCTION 

The FTC’s accounting practices continue to be accurate 

and transparent, directly supporting the agency’s dual 

mission to police unfair methods of competition and 

target unfair or deceptive practices across the economy, 

and consistently demonstrating the FTC’s commitment to 

responsible stewardship of resources and sound financial 

operations For the 25th straight year, the FTC received 

a “clean” or unmodified opinion on its audited financial 

statements Independent auditors issue an unmodified 

opinion when an entity’s financial statements are 

presented fairly, in all material aspects, in accordance with 

U S Generally Accepted Accounting Principles (GAAP) 

The following discussion provides an overview of the 

agency’s financial position and results of operations The 

complete audited financial statements with accompanying 

notes, including the independent auditor’s report, are 

presented in the Financial Section of this report 

BALANCE SHEET 

The FTC’s Balance Sheet includes both entity and nonentity assets and liabilities Entity assets, by law, are 

authorized by the Congress for the FTC to use in its 

operations, i e , Property, Plant, and Equipment (PP&E) 

Entity liabilities consist of probable and measurable 

future outflows of FTC entity resources 

Non-entity assets (which are not available for the 

FTC’s use) are those assets held on behalf of others, 

i e , collections and accounts receivable that arise from 

civil monetary penalties and court-ordered judgments 

for monetary relief in the agency’s consumer redress 

program Non-entity assets are equal to, and offset by, 

non-entity liabilities 

CONDENSED BALANCE SHEET AS OF SEPTEMBER 30, 2021 AND 2020

(Dollars in Millions) FY 2021 FY 2020 % Change

Entity Assets

Fund balance with Treasury $ 233 $ 114 104%

General property, plant, and equipment 22 25 -12%

Total Entity Assets 255 139 83%

Non-Entity Assets

Fund balance with Treasury 385 677 -43%

Accounts receivable 51 628 -92%

Total Non-Entity Assets 436 1,305 -67%

Total Assets $ 691 $ 1,444 -52%

Entity Liabilities

Employee related liabilities 31 30 3%

Accounts payable and other 11 12 -8%

Total Entity Liabilities 42 42 0%

Non-Entity Liabilities

Redress collections not yet disbursed 385 677 -43%

Liability for amounts to be collected 51 628 -92%

Total Non-Entity Liabilities 436 1,305 -67%

Total Liabilities $ 478 $ 1,347 -65%

Unexpected Appropriations 27 - 100%

Cumulative results of operations 186 97 92%

Total Net Position 213 97 120%

Total Liabilities and Net Position $ 691 $ 1,444 -52%
MANAGEMENT’S DISCUSSION AND ANALYSIS

36 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

BALANCE SHEET – ENTITY 

Entity assets totaled $255 million, or 37 percent of all 

FTC assets, as of September 30, 2021, an increase of 

$116 million, or 83 percent, from the FY 2020 total of 

$139 million 

The Fund Balance with Treasury (FBwT) of $233 million 

comprises $123 million that is temporarily unavailable 

for expenditure and $110 million available to the FTC 

to make expenditures and pay liabilities FBwT has 

increased by $119 million, or 104 percent, from the 

FY 2020 total of $114 million At the end of FY 2021, 

the FTC’s FBwT contained $119 million in temporarily 

unavailable offsetting collections (fees from the 

FTC’s National Do Not Call Registry and premerger 

notification filings) that exceeded the amount 

authorized to offset the FTC’s appropriation Of the $119 

million, $6 million was temporarily reduced by the FY 

2013 sequestration 

PP&E, net of accumulated depreciation/amortization, is 

$22 million, which consists of $20 million in leasehold 

improvements, $1 million in equipment, and $1 million 

in software Of the total PP&E, $18 million in leasehold 

improvements is associated with the FY 2014 relocation 

of staff to office space at the Constitution Center Total 

PP&E decreased by $3 million compared to FY2020 

This decrease is primarily due to asset disposals and the 

continued depreciation/amortization of assets related to 

the FY 2014 staff relocation 

The annual trend in the FTC’s total assets reflects the 

OMB Category B apportionment between FY 2010 

and 2013 of more than $74 million for the relocation 

of staff to office space at Constitution Center The 

move was completed in FY 2014, with over $46 million 

being spent on capitalized assets Since these assets 

were placed in service, the FTC’s PP&E balance has 

decreased, primarily due to continual depreciation 

and amortization FBwT increased by $119 million and 

is primarily caused by an increase in premerger filing 

fee collections The FTC received more than 3,400 

Premerger notifications in FY 2021 and represents an 

increase of more than 110 percent from FY 2020 This 

resulted in $87 million of excess offsetting collections 

above the annual Congressional authorized amount, 

which is precluded from obligation In addition, the 

FTC received a $30 4 million appropriation under the 

American Rescue Plan Act of 2021, of which, $27 million 

is unexpended at the end of FY 2021 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 37

Entity liabilities totaled $42 million, or 9 percent of all 

FTC liabilities, as of September 30, 2021, equaling the 

total entity liabilities of FY 2020 

Employee-related liabilities of $31 million consist of 

accrued payroll and benefits, accrued annual leave 

wages earned by employees but not yet paid, and the 

Federal Employees Compensation Act (FECA) liability 

Accounts payable and other liabilities totaling $11 million 

consist of amounts owed, but not yet paid, for goods or 

services the FTC has received 

Entity liabilities have a smaller range of fluctuation in 

comparison to entity assets Accounts payable balances 

fluctuate more significantly when capitalized purchases 

are involved Employee-related liabilities fluctuate 

based on the FTE count and the timing of the payroll 

disbursement cycle At the end of FY 2014, the payroll 

and benefit liability included 7 days of unpaid wages 

while the FY 2021 year-end payroll accrual included 

14 days of unpaid wages, which is 1 more day than the 

FY 2020 year-end payroll accrual of 13 days of unpaid 

wages The uptick in employee-related liabilities in FY 

2021 is attributable to the additional payroll accrual 

The $1 million decrease in Accounts payable and other 

liabilities is primarily due to timing differences on 

payment of invoices Fewer invoices are outstanding at 

the end of FY 2021 and the total outstanding invoices 

plus accrued expenses at FY 2021 year end is slightly 

lower than the total at the end of FY 2020 
MANAGEMENT’S DISCUSSION AND ANALYSIS

38 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

BALANCE SHEET - NON-ENTITY 

Non-entity assets totaled $436 million, or 63 percent 

of all FTC assets, as of September 30, 2021 This 

represents a decrease of $869 million, or 67 percent, 

from the FY 2020 total of $1,305 million 

Non-entity assets are equal to, and offset by, nonentity liabilities The $51 million net accounts receivable 

balance is offset by the $51 million liability for amounts 

to be collected, while the $385 million FBwT is offset by 

the $385 million liability for redress collections 

The FY 2021 ending net accounts receivable balance 

of $51 million reflects amounts to be paid to the FTC 

from court-ordered judgments in the consumer redress 

program This represents a $577 million decrease in net 

accounts receivable from the FY 2020 total of $628 

million This decrease is primarily due to adjustments 

to accounts receivable as a result of the Supreme 

Court decision on April 22, 2021, in the AMG Capital 

Management, LLC v FTC case that eliminated the FTC’s 

longstanding authority under Section 13(b) of the FTC 

Act, 15 U S C § 53(b) to recover money for harmed 

consumers 

The remaining ending net accounts receivable balance 

of $51 million primarily consists of amounts to be paid 

to the FTC from the following cases: AmeriDebt, Inc for 

involvement in the allegedly deceptive sale of real estate 

properties in Belize to U S consumers; Apex Capital 

Group, LLC for engaging in unlawful conduct that 

enabled a deceptive “free trial” offer scheme; AH Media 

Group LLC for luring consumers with supposedly “free 

trial” offers for cosmetics and dietary supplements, then 

enrolling them in subscriptions and billing them without 

their consent; Elegant Solutions, Inc (Mission Hills 

Federal) for operating a student loan debt relief scheme; 

Jeremy Lee Marcus, et al (Helping America Group)

for allegedly selling phony debt relief and credit repair 

services, including fake loans; and I Works, Inc , et al for 

deceptive “trial” memberships for bogus governmentgrant and money-making schemes Sixteen additional 

matters account for the remainder of the balance 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 39

FY 2021 Non-Entity Fund Balance with Treasury Timeline Activity

$677.1M Beginning Balance - FY 2021 Non-Entity Fund Balance with Treasury

A $7 6M AT&T Mobility, LLC

Collected $7 6M from a 2019 settlement of allegations that AT&T Mobility, LLC 

misled millions of its smartphone customers by charging them for “unlimited” 

data plans while reducing their data speeds 

B $5 5M Stark Law, LLC

Collected $5 5M from a 2017 settlement with Stark Law, the operators of a 

Chicago-area fake debt collection scheme Stark Law allegedly used a host of 

business names to target consumers who obtained or applied for payday or other 

short-term loans, pressuring them into paying debts they either did not owe or 

that the defendants had no authority to collect 

C $10 0M Indivior, Inc 

Collected $10 0M from a 2020 settlement with Indivior (a former division of 

Reckitt Benckiser) to settle FTC charges that it violated antitrust laws through a 

deceptive scheme to thwart lower priced generic competition with its branded 

opioid replacement therapy drug Suboxone 

D $4 3M Online Trading Academy

Collected $4 3M from a 2020 settlement with Online Training Academy (OTA) to 

settle FTC charges that OTA had deceived consumers with claims that purchases 

of OTA’s investment training were likely to generate significant income 

E ($4 7M) Digital Altitude, LLC

Disbursed $4 7M (10,249 payments) to individuals who lost money to the Digital 

Altitude business coaching scheme The defendants promised consumers that 

they would receive individualized coaching from successful marketers to build a 

successful business, but, in reality, the coaches were merely salespeople selling 

higher membership levels in the scheme Refunds result from 2018 and 2019 

settlements 

F ($6 2M) Cardinal Health, Inc 

Disgorged to U S Treasury $6 2M from a 2015 settlement against Cardinal Health, 

which resolved charges that it illegally monopolized 25 local markets for the sale 

and distribution of low-energy radiopharmaceuticals and forced hospitals and 

clinics to pay inflated prices for these drugs 
MANAGEMENT’S DISCUSSION AND ANALYSIS

40 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

FY 2021 Non-Entity Fund Balance with Treasury Timeline Activity

G ($6 5M) Fashion Nova, Inc 

Disbursed $6 5M (518,552 payments) to consumers affected by online retailer 

Fashion Nova’s violations of the FTC’s Mail, Internet, or Telephone Order 

Merchandise Rule Refunds result from a 2020 settlement 

H ($49 7M) The University of 

Phoenix, Inc 

Disbursed $49 7M (147,481 payments) to The University of Phoenix students 

who may have been lured by allegedly deceptive advertisements touting the 

university’s relationship and job opportunities with companies such as AT&T, 

Yahoo!, Microsoft, Twitter, and the American Red Cross Refunds result from a 

2019 settlement 

I ($11 1M) E M Systems & Services, 

LLC 

Disbursed $11 1M (over 11,000 payments) to consumers who lost money to a 

bogus credit card interest rate reduction scheme operated by E M Systems & 

Services Refunds result from a 2020 settlement 

J ($9 7M) Age of Learning, Inc 

(ABCmouse) 

Disbursed $9 7M (206,814 payments) to consumers who were automatically 

billed for ABCmouse renewals and consumers were prevented from cancelling 

their memberships Refunds result from a 2020 settlement 

K ($4 1M) Stark Law, LLC

Disbursed $4 1M (over 10,000 payments) to consumers who lost money to 

the Stark Law phantom debt collection scheme Refunds result from a 2017 

settlement 

L ($59 1M) Reckitt Benckiser Group 

PLC & Indivior, Inc 

Disbursed $59 1M (51,875 payments) to consumers who were victims of an 

allegedly deceptive scheme by Reckitt Benckiser Group and Indivior, Inc to 

thwart lower-priced generic competition with the branded drug Suboxone 

Refunds result from a 2019 settlement with Reckitt Benckiser Group PLC and a 

2020 settlement with Indivior, Inc 

M ($172 8M) Progressive Leasing

Disbursed $172 8M (more than 2 million payments) to harmed consumers who 

overpaid for merchandise they purchased using rent-to-own plans provided by 

Progressive Leasing Refunds result from a 2020 settlement 

N ($30 0M) Career Education 

Corporation

Disbursed $30 0M (over 8,000 payments) to people tricked by agents working 

on behalf of Career Education Corporation, the operator of several postsecondary schools CEC’s lead generators tricked consumers into providing their 

information and enrolling at CEC schools using a variety of deceptive methods, 

according to the FTC’s complaint Refunds result from a 2019 settlement 

O $4 8M Vivint Smart Home, Inc 

Collected $4 9M from a 2021 settlement of FTC charges that Vivint Smart Home, 

Inc misused credit reports to help unqualified customers obtain financing for its 

products and services 

P $9 8M Yellowstone Capital, LLC

Collected $9 8M from a 2021 settlement of FTC charges that Yellowstone Capital, 

LLC took money from businesses’ bank accounts without permission and 

deceived them about the amount of financing business owners would receive 

Q $61 7M Amazon com, Inc 

Collected $61 7M from a 2021 settlement of FTC charges that Amazon com failed 

to pay Amazon Flex drivers the full amount of tips they received over a two and a 

half year period 

R $18 0M LendingClub Corporation

Collected $18 0M from a 2021 settlement of FTC charges that LendingClub 

deceived consumers about hidden fees that it charged and about whether their 

loan applications were approved 

S ($5 4M) Online Trading Academy

Disbursed $5 4M (31,144 payments) to consumers who purchased an allegedly 

deceptively marketed investment training scheme offered by Online Trade 

Academy Refunds result from a 2020 settlement 

T ($61 7M) Amazon com, Inc 

Disbursed $61 7M to a third party administer, who is in the process of issuing 

payments to Amazon Flex drivers who did not receive the full amount of their 

tips over a two and a half year period Refunds are a result of a 2021 settlement 

U ($4 9M) Hold Billing Services, Ltd 

Disbursed $4 9M (86,752 payments) to consumers who lost money to a 

cramming scheme that added charges to their home phone bills without their 

permission Refunds are a result from 2016 settlement 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 41

FY 2021 Non-Entity Fund Balance with Treasury Timeline Activity

V $15 0M MOBE Ltd , et al 

Collected $15 0M from a 2020 settlement of FTC charges that My Online Business 

Education (MOBE) lured consumers to join its online coaching program by 

promising a pathway to online entrepreneurship and vast riches on the internet, 

but then charged these consumers tens of thousands of dollars for worthless 

program membership upgrades 

 ($3 1M) Net of other collections $31 9M and disbursing ($35 0M) activities, related to over 190 additional matters 

$384.8M Ending Balances – FY 2021 Non-Entity Fund Balance with Treasury 

Significant Contributors to the FY 2021 Non-Entity Fund Balance with 

Treasury Ending Balance

$150 1M AdvoCare 

International, L P 

$150M held by the FTC from a 2020 settlement of allegations AdvoCare deceived 

consumers into believing they could earn significant income as “distributors” of its 

health and wellness products 

$234 7M The remaining Fund Balance with Treasury balance consists of funds held by the FTC from 169 separate 

matters 

$384.8M Ending Balance - FY 2021 Non-Entity Fund Balance with Treasury

Historic trends of FBwT for consumer redress are 

primarily driven by several notable cases 

• In FY 2015, the FTC collected $458 million from 

a settlement resolving antitrust charges that 

Cephalon, Inc illegally blocked generic competition 

to its drug Provigil by engaging in “pay for delay” 

conduct 

• In FY 2016, the FTC collected $200 million from 

Herbalife International of America, Inc to settle 

FTC charges that Herbalife deceived consumers as 

part of a multi-level marketing operation This large 

collection was primarily offset by a $120 million 

disbursement to harmed parties as a result of the 

Cephalon, Inc settlement 

• In FY 2017, the FTC disbursed $200 million from 

the Herbalife settlement to claimants Additionally, 

the FTC disbursed $125 million to harmed parties 

as a result of the Cephalon, Inc settlement 

• In FY 2018, the FTC collected $471 million from 

AMG Services from a 2016 judgment for a payday 

lending scheme that deceived consumers across 

the country and illegally charged them inflated and 

undisclosed fees The FTC disbursed $505 million to 

consumers harmed by this scheme during FY 2018 

($47 million had been collected prior to FY 2018) 

• In FY 2019, the FTC disbursed $194 million to 

harmed parties as a result of the 2015 settlement 

agreement with Cephalon, Inc 

• In FY 2020, the FTC collected $150 million 

from Advocare International, L P , for deceiving 

consumers into believing they could earn significant 

income as “distributors” of its health and wellness 

products Also in FY 2020, the FTC collected $175 

million from Progressive Leasing for misleading 

consumers about the true price of its leasing plans 
MANAGEMENT’S DISCUSSION AND ANALYSIS

42 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

STATEMENT OF NET COST

STATEMENT OF NET COST SUMMARY

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(Dollars in Millions) FY 2021 FY 2020 % Change

Protecting Consumers:

Gross costs $ 193 $ 195 -1%

Less: earned revenue (13) (13) 0%

Protecting Consumers 180 182 -1%

Maintain Competition:

Gross costs $ 170 $ 167 2%

Less: earned revenue (238) (102) 133%

Maintaining Competition (68) 65 -205%

Net Cost of Operations $ 112 $ 247 -55%

The Statement of Net Cost presents the FTC’s gross 

costs less revenue earned for two of the FTC’s strategic 

goals: Protect Consumers and Maintain Competition 

The third goal, Advance Organizational Performance, 

has its costs distributed to the other two strategic goals 

based on the percentage of dollars directly traceable 

to each of these two goals The FTC’s net cost of 

operations was $112 million in FY 2021, which consists 

of $363 million in gross costs offset by $251 million in 

earned revenue 

The FY 2021 net cost of operations for the Protect 

Consumers strategic goal is $180 million, consisting 

of $193 million in gross costs offset by $13 million in 

earned revenue, which is mostly revenue from fees 

collected for the National Do Not Call (DNC) Registry 

The FTC receives fees from telemarketers who pay an 

annual subscription fee to download telephone numbers 

of consumers who do not wish to receive calls The 

DNC fees are based on the number of area codes that a 

telemarketer downloads 

The FY 2021 net cost of operations for the Maintain 

Competition strategic goal is ($68) million, consisting 

of $170 million in gross costs offset by $238 million 

in earned revenue, which is mostly revenue from fees 

collected for premerger notification filings, with a small 

portion (about $1 million) from multiple reimbursable 

agreements with other Federal agencies Premerger 

notification filings are made under the Hart-ScottRodino (HSR) Antitrust Improvement Act of 1976, 

which gives the federal government the opportunity 

to investigate and challenge certain mergers that are 

likely to harm consumers before injury occurs The HSR 

Act requires the filing of premerger notifications with 

the FTC and the Department of Justice (DOJ) Antitrust 

Division The filing fees are determined by the size 

of the merging parties and the value of the proposed 

transaction By law, the FTC retains one-half of all 

premerger filing fees collected and remits one-half to 

the DOJ Antitrust Division 

The decrease in overall net cost is primarily due to 

higher revenues from premerger filing fees In FY 

2021 the FTC received more than 3,400 Premerger 

notification filings which represents an increase of more 

than 110 percent from FY 2020 Increased premerger 

fee revenues significantly reduced the FTC’s FY 2021 net 

cost of operations 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 43

FTC NET COST OF OPERATIONS VS BENEFIT TO 

AMERICAN PUBLIC 

The FTC had gross costs of $363 million in FY 2021, 

offset by $251 million in earned revenue, resulting in a 

total net cost of operations of $112 million However, a 

large portion of the FTC’s operations result in activity 

whose benefits are not reflected on the Statement of 

Net Cost These important benefits to the public should 

be considered in determining the overall impact of the 

agency’s strategic goals 

The Statement of Net Cost includes only entity activity 

During FY 2021, the FTC returned $607 million in nonentity collections to consumers and the U S Treasury 

General Fund Redress disbursements to harmed 

consumers during FY 2021 totaled $453 million with 

an additional $8 million in disgorgements to Treasury 

Civil Penalty collections returned to Treasury totaled 

$146 million 

Throughout FY 2021, the FTC saved consumers an 

estimated $2 4 billion* through its merger and nonmerger competition law enforcement actions and an 

estimated $1 5 billion* through its consumer protection 

law enforcement actions 

The FTC’s cost to protect consumers and maintain 

competition is a small fraction of the amount the FTC 

has saved consumers For FY 2021, the FTC provided an 

estimated total of $ 4 billion in benefits to consumers 

When this benefit is compared to the $112 million 

in net costs, it equates to every $1 of the FTC’s cost 

returning an estimated $36 in FTC-provided benefits 

to consumers 

For every $1 of the FTC’s cost there is an estimated $36 in benefits provided to the consumer

FTC’S IMPACT 

ON 

THE CONSUMER

FTC Net Cost of Operations

$112 Million Non-entity funds 

disbursed to 

claimants, third party 

administrators, and 

the General Fund of 

the U.S. Government

$607 Million Other benefits to consumers*

$3.4 Billion

*These estimates were calculated based on performance measures 

1 1 3 (consumer savings from consumer protection law enforcement), 

2 1 3 (consumer savings from merger enforcement), and 2 1 5 

(consumer savings from non-merger enforcement) For more details 

on measurement and data quality, see the FTC Data Quality Appendix 
MANAGEMENT’S DISCUSSION AND ANALYSIS

44 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

STATEMENT OF CUSTODIAL ACTIVITY

CONDENSED STATEMENT OF CUSTODIAL ACTIVITY FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(Dollars in Millions) FY 2021 FY 2020 % Change

Revenue Activity:

Sources of collections:

Premerger filing fees (net of refunds) $ 16 $ 101 -84%

Civil penalties and fines 146 4,854 -97%

Consumer redress 8 7 14%

Other miscellaneous receipts - - 0%

Total cash collections 170 4,962 -97%

Accural adjustments - - 0%

Total Custodial revenue $ 170 $ 4,962 -97%

Disposition of Collections:

Transferred to others:

Treasury general fund $ 154 $ 4,861 -97%

Department of Justice 16 101 -84%

Amounts yet to be transferred - - 0%

Total Disposition of Collections $ 170 $ 4,962 -97%

Net Custodial Activity $ - $ - 0%

The Statement of Custodial Activity displays the 

custodial revenue recognized during the fiscal year 

in comparison to the disposition or transfer out of 

cash held on behalf of other entities The FY 2021 

total custodial revenue is $170 million, a decrease 

of $4,792 million or 97 percent from the FY 2020 

amount The decrease results from declines in both 

premerger filing fees and civil penalties In FY 2021, 

the FTC implemented a new collection process for the 

Premerger filing fees to split collections evenly between 

the FTC and the DOJ upon receipt Prior to FY 2021, the 

FTC collected the full amount of fees under the HSR 

premerger notification program and remitted half to the 

DOJ, which resulted in a custodial liability A total of 

$16 million in Premerger fees were processed on behalf 

of the DOJ at the start of fiscal year 2021 before the 

process change was implemented The FTC’s revenue of 

$237 million for premerger filing fees is reported on the 

Statement of Net Cost under the Maintain Competition 

strategic goal Civil penalties and fines are collected in 

connection with the settlement or litigation of the FTC’s 

administrative or Federal court cases At the end of each 

fiscal year, all civil penalties collected are transferred 

to the Treasury General Fund Collections held for 

consumer redress will also be transferred, or disgorged, 

to the Treasury General Fund in the event redress is 

determined to be not practicable 

The significant decrease in civil penalties and fines 

reflects the FY 2020 collection from the substantial 

civil penalty settlement that the FTC and the DOJ 

reached with Facebook in the amount of $5 billion 

that significantly raised the FY 2020 civil penalties 

and fines The FTC’s portion is $4,850 million The 

settlement with Facebook relates to allegations that 

the company violated its 2012 FTC privacy order 

by deceiving users about their ability to control the 

privacy of user’s personal information The FY 2021 civil 

penalties returned to the Treasury General Fund include 

$122 million from DISH Network for violations of the 

Telemarketing Sales Rule and Telephone Consumer 

Protection Act 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 45

FTC BUDGETARY RESOURCES AND HOW THEY WERE USED 

BUDGET AUTHORITY 

The FTC receives an annual appropriation that 

is available until expended, subject to Office of 

Management and Budget (OMB) apportionment and 

Congressional restrictions on the expenditure of funds 

(see FTC’s FY 2021 Congressional Budget Justification, 

pages 3 to 4, “Appropriations Language Provisions”) 

The FTC’s budget authority is derived from a direct 

appropriation and offsetting collections 

In FY 2021, the FTC received an additional appropriation 

of $30 4 million under the American Rescue Plan 

Act of 2021 (ARPA), signed into law by President 

Biden on March 11, 2021, to remain available through 

FY 2026 This appropriation authorizes funding for 

the FTC to cover higher costs associated with the 

COVID-19 pandemic to include: $24 million for payroll 

expenses, $4 4 million for processing and monitoring of 

consumer complaints received through the Consumer 

Sentinel Network, and $2 million for consumer-related 

education 

Including the funds under the ARPA, the FTC’s FY 2021 

new budget authority totals $383 million, representing a 

$51 million increase from the FY 2020 amount The FY 

2021 budget authority comprised $218 million in general 

fund appropriations plus $165 million in spending 

authority from offsetting collections, consisting of $150 

NEW BUDGET AUTHORITY

Offsetting

Collection

$165 Million

General Fund 

Annual Appropriation

$188 Million

General 

Fund-ARPA

$30 Million

FY 2020 - $332 MILLION

General Fund

Annual 

Appropriation

$217 Million

Offsetting

Collection

$115 Million
MANAGEMENT’S DISCUSSION AND ANALYSIS

46 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

million from fees collected for premerger notification 

filings under the HSR Antitrust Improvements Act of 

1976, $13 million from fees collected for the National 

Do Not Call Registry, and $2 million from reimbursable 

work on behalf of other Federal agencies 

Because current year offsetting collections up to the 

congressionally authorized amount are deducted from 

gross budget authority and outlays, only 57 percent of 

the FTC’s net budget authority comes from Treasury 

General Fund appropriations This reduces the burden 

the FTC places on the federal budget to $218 million, 

which is less than 1/10 of 1 percent of the total nondefense discretionary spending for FY 2021 

Historically, the FTC’s budget authority has been 

relatively static From FY 2010 through FY 2014, the 

FTC received an OMB category B apportionment for the 

relocation of staff to office space at the Constitution 

Center Excluding the category B funding, the FTC had 

a 39 percent or $107 million change from FY 2010 

($276 million) to FY 2021 ($383 million) The modest 

increase in the FTC’s budget authority over the last 

decade significantly lags behind the agency’s increased 

responsibilities that result from rising expectations of 

the American public For example, consumer complaints 

to the FTC rose by over 300 percent, and premerger 

filings rose by over 200 percent, among other measures 

of the FTC’s increased workload in the past decade In 

addition, the FTC continues facing profound impacts 

from the COVID-19 pandemic and resulting challenges 

during FY 2021 Consumer complaints increased by 26 

percent and premerger filings increased by 114 percent 

in 2021 alone, compared to FY 2020 volumes In FY 

2021 the FTC incurred $4 million of obligations for 

payroll expenses and management and professional 

support services in support of agency initiatives to 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 47

process increased consumer complaints, provide 

consumer-related education, and address unfair or 

deceptive acts related to the COVID-19 pandemic 

The FTC’s increasing costs are also reflected in expert 

witness costs The agency is engaged in a larger 

number of complex investigations and litigation 

matters that require the services of expert witnesses 

In particular, expert witnesses are critical to the 

successful investigation and litigation of merger cases, 

as experts provide insight on proper definition of 

product and geographic markets, assess the likelihood 

of entry by new competitors, and develop models to 

evaluate merger efficiencies as compared to potential 

competitive harm Although spending on expert witness 

declined in FY 2021 from the previous year, rising costs 

for critical expert services in litigation matters continue 

to pose significant challenges on the FTC’s limited 

budgetary resources and the FTC is currently exploring 

ways to reduce those costs 

Visit the FTC’s Data and Visualizations page to view 

interactive dashboards on data collected from consumer 

complaints, and the Do Not Call program Visit 

Premerger Notification page to learn more about the 

Premerger Notification Program 

THE FTC’S FY 2021 OBLIGATIONS: 

In FY 2021, the FTC received $383 million in new budget 

authority and authority to obligate $5 million in its 

unobligated balance brought forward in addition to $5 

million in recoveries of prior-year obligations Pursuant 

to these authorities, the FTC obligated $351 5 million 

in FY 2021 This was an increase of $2 1 million, or 0 6 

percent, compared to new obligations in FY 2020 The 

increase in obligations incurred in FY 2021 was mainly 

attributable to higher payroll costs offset by lower costs 

for travel, supplies, and utilities as well as lower costs 

for expert witnesses Payroll spending has increased by 

3 9 percent to $227 million in FY 2021 from $218 million 

in FY 2020 This is the result of the 1 percent pay raise 

for FY 2021, and higher cost factors associated with 

employee benefits The reduction in travel costs is due 

to travel restrictions from the COVID-19 pandemic The 

decrease in rent and utilities expenses compared to FY 

2020 is also a continued impact from the pandemic 

as the agency’s workforce continued the mandatory 

telework in place since Q3 of FY 2020 Finally, the FTC 

incurred lower obligations in FY 2021 for expert witness 

support services compared to FY 2020 While this 

demonstrates the FTC’s efforts to limit costs on expert 

witness services, the agency continues to face pressure 
MANAGEMENT’S DISCUSSION AND ANALYSIS

48 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

from resource constraints as it continues to perform 

mission-critical work and maintain fair competition in 

increasingly complex and pervasive technology markets 

that raise unique antitrust considerations 

Historically the FTC’s obligations by category have 

remained relatively static when expressed as a 

percentage of all obligations incurred during a particular 

fiscal year Between FY 2017 and FY 2021, there were 

several notable changes 

• Although expert witness costs may fluctuate 

year over year, the proportion of expert witness 

obligations relative to all obligations incurred during 

FY 2021 is in-line with the five-year trend from FY 

2017 to FY 2021 During FY 2021, the expert witness 

obligations balance is 4 6 percent of total obligations 

while the five-year average of the percentage of 

expert witness to total obligations is 4 76 percent 

Expert witness costs increased from $15 2 million 

in FY 2017 to $16 1 million in FY 2021 The services 

of these expert witnesses continue to be critical 

to the successful investigation and litigation of 

merger cases and are affected by the number and 

complexity of investigations and litigation matters in 

which the agency engages, including merger filings 

initiated by outside parties 

• Property, Plant, and Equipment obligations 

decreased from $3 8 million in FY 2017 to $1 1 

million in FY 2021, or a decrease from 1 2 percent of 

total obligations in FY 2017 to 0 03 percent in 

FY 2021 

• Payroll costs have increased steadily each year 

over the past five years, starting at $197 million in 

FY 2017 and growing to $226 7 million in FY 2021, 

representing an increase of 15 percent over five 

years The increase is mostly a result of pay raises 

and increases in benefits costs 
MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 49

FTC PROFILE ON USA SPENDING: 

Additional details of agency spending are captured on usaspending gov where, beginning in FY 2017, federal agencies 

have certified to the accuracy of data Federal spending is available for public consumption to ensure taxpayers can 

see how their money is being used in communities across America 

The below excerpt is taken from the FTC’s Agency profile page on usaspending gov 

FINANCIAL MANAGEMENT INDICATORS FOR FY 2021 

The following table shows standard indicators developed by the Chief Financial Officers Council and used by the 

OMB to monitor agencies’ financial management practices 

DEBT MANAGEMENT

Eligible debt transferred to Treasury 100%

FUNDS MANAGEMENT

Fund balance with Treasury (identifies the difference between the fund balance reported in 

Treasury reports and the agency fund balance with Treasury recorded in its general ledger) 100% reconciled

PAYMENT MANAGEMENT

Percentage invoices paid on time (per Prompt Payment Act) 99 44%

Percentage interest penalties paid to total dollars invoiced 000074%

Percentage of total dollars outstanding in current status (good standing) for individually billed 

travel account holders 100%

Percentage of total dollars outstanding in current status (good standing) for centrally billed travel 

accounts 100%

Percentage of total dollars outstanding in current status (good standing) for purchase cards 100%

LIMITATIONS OF FINANCIAL STATEMENTS 

The principal financial statements are prepared to report 

the financial position, financial condition, and results of 

operations, pursuant to the requirements of 31 U S C 

§ 3515(b) The statements are prepared from records 

of Federal entities in accordance with Federal generally 

accepted accounting principles (GAAP) and the 

formats prescribed by OMB Reports used to monitor 

and control budgetary resources are prepared from 

the same records Users of the statements are advised 

that the statements are for a component of the U S 

Government 

Federal Trade Commission

Agency Mission

Protecting consumers and competition by preventing anticompetitive, deceptive and unfair 

business pratices through law enforcement, advocacy and education without unduly 

burdening legitimate business activity 

Website 

https://www ftc gov/

Congressional Justification of Budget (CJ)

https://www ftc gov/cj
FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 
FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

F I N A N C I A L 

SECTION
52

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

David Rebich

Chief Financial Officer

I am pleased to present the Agency Financial Report (AFR) for Fiscal Year 2021 

The AFR provides a comprehensive view of the FTC’s financial activities and 

demonstrates the FTC’s stewardship and management of public funds The 

financial statements and corresponding financial analysis, together with the 

Agency’s Performance Highlights, demonstrate how the FTC optimizes its 

financial resources to protect American consumers and maintain competition in 

the marketplace 

In FY 2021, the FTC has achieved, for the twenty-fifth consecutive year, an 

unmodified audit opinion from the independent auditors We are very proud of 

this accomplishment This sustained achievement is due to the efforts of the 

Financial Management Office (FMO) staff, as supported by fund managers and 

a cadre of Contracting Officer Representatives throughout the agency This past 

year, the FTC has demonstrated its commitment to continuous improvement 

with the following accomplishments: 

n No material weaknesses or significant deficiencies in Internal Controls Over Financial Reporting; 

n No instances of noncompliance with laws and regulations that are required to be reported under Government 

Auditing Standards; 

n Closed seventeen Corrective Action Plans (CAPs) in FMO, and collaborated within the agency to close an 

additional fifteen CAPs; 

n Continued monitoring Fraud Risk by collecting and analyzing related fraud control data from FTC program areas; 

n Continued work to streamline our internal processes to leverage efficiencies with our Shared Service provider, the 

Department of the Treasury’s Administrate Resource Center (ARC) - reduced direct costs to process accounts 

receivable transactions by over 50 percent; 

n Leveraged reporting tools to gain process efficiencies ensuring month end close within two business days 

compared to the previous five day close process; 

n Updated the FTC risk profile to identify and monitor risk associated with the Supreme Court ruling that removed 

the authority to seek monetary relief for consumers per Section 13(b); and 

n Completed a review of all agency performance metrics in preparation for the agency strategic planning process 

The accomplishments outlined in this report are the result of the FTC employees’ hard work and dedication The 

unmodified audit opinion and financial accomplishments reflect an organizational commitment to sound financial 

management and accountability that the agency hopes earns the trust of the American public This agency is 

steadfastly committed to its mission, returning substantial value to the American consumer, and being an exemplary 

steward of the funds entrusted to it 

David Rebich, Chief Financial Officer

November 15, 2021
53

FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

 November 12, 2021

MEMORANDUM

FROM: Andrew Katsaros

 Inspector General

TO: Lina M. Khan, Chair 

SUBJECT: Report on Audit of the FTC’s Fiscal Year 2021 and 2020 Financial Statements

I am pleased to provide you with the attached audit report required by the Accountability of Tax Dollars 

Act of 2002, which presents an unmodified opinion on the Federal Trade Commission’s (FTC) financial 

statements for fiscal years 2021 and 2020. We commend the FTC for attaining an unmodified (clean) 

opinion for the 25th consecutive year.

We contracted with the independent certified public accounting firm of Brown & Company CPAs and 

Management Consultants, PLLC (Brown & Company), to audit the financial statements of the FTC as 

of and for the fiscal years ended September 30, 2021 and 2020, and to provide reports on internal 

control over financial reporting and compliance with laws and other matters. The contract required the 

audit be performed in accordance with U.S. generally accepted government auditing standards, Office 

of Management and Budget audit guidance, and the Government Accountability Office/Council of the 

Inspectors General on Integrity and Efficiency’s Financial Audit Manual.

In its audit, Brown & Company found that

• the FTC’s financial statements as of and for the fiscal years ended September 30, 2021 and 2020, are 

presented fairly, in all material respects, in accordance with U.S. generally accepted accounting

principles; 

• no material weaknesses in internal control over financial reporting based on the limited procedures 

performed; and

• no reportable noncompliance for fiscal year 2021 with provisions of applicable laws, regulations, 

contracts, and grant agreements tested.

Brown & Company is responsible for the attached auditor’s report dated November 12, 2021, and the 

conclusions expressed in the report. We do not express opinions on FTC’s financial statements or 

conclusions about the effectiveness of internal control or conclusions on compliance with laws and 

regulations. 
54

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

2 

We appreciate the cooperation given by management to Brown & Company and the Office of Inspector 

General during the audit. If you have any questions or would like to discuss the report, please contact me 

at (202) 326-3527. 
55

INDEPENDENT AUDITOR’S REPORT 

Inspector General 

Federal Trade Commission 

Washington, D.C. 

In our audits of the fiscal years 2021 and 2020 financial statements of the Federal Trade Commission 

(FTC), we found:

• FTC’s financial statements as of and for the fiscal years ended September 30, 2021, and

2020, are presented fairly, in all material respects, in accordance with U.S. generally accepted 

accounting principles; 

• no material weaknesses in internal control over financial reporting based on the limited

procedures we performed; and

• no reportable noncompliance for fiscal year 2021 with provisions of applicable laws,

regulations, contracts, and grant agreements we tested.

The following sections discuss inmore detail (1) our report on the financial statements, which includes 

required supplementary information (RSI) and other information included with the financial

statements; (2) our report on internal control overfinancial reporting; and (3) our report on compliance 

with laws, regulations, contracts, and grant agreements. 

Report on the Financial Statements

In accordance with the provisions of the Accountability of Tax Dollars Act of 2002 (ATDA) (Pub. L. No. 

107-289), we have audited FTC’s financial statements. FTC’s financial statements comprise the

balance sheets as of September 30, 2021, and 2020; the related statements of net cost, changesin net 

position, budgetary resources, and custodial activity for the fiscal years then ended; and the related 

notes to the financial statements. 

We conducted our audits in accordance with U.S. generally accepted government auditing standards and 

the provisions of OMB Bulletin No. 21-04, Audit Requirements for Federal Financial Statements. We

believe that the audit evidence we obtained is sufficient and appropriate to provide a basis for our audit 

opinions. 

Management’s Responsibility 

FTC management isresponsible for (1) the preparation and fair presentation of these financial statements 

in accordance with U.S. generally accepted accounting principles; (2) preparing, measuring, and 

presenting the RSI in accordance with U.S. generally accepted accounting principles; (3) preparing and

presenting other information included in documents containing the audited financial statements and 

auditor’s report, and ensuring the consistency of that information with the audited financial statements

and the RSI; and (4) maintaining effective internal control over financial reporting, including the design,

implementation, and maintenance of internal control relevant to the preparation and fair presentation of

financial statements that are free from material misstatement, whether due to fraud or error.
56

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

Auditor’s Responsibility 

Our responsibility isto express an opinion on these financial statements based on our audits. U.S. generally 

accepted government auditing standards require that we plan and perform the audit to obtain reasonable 

assurance about whether the financial statements are free from material misstatement. We are also 

responsible for applying certain limited procedures to RSI and other information included with the financial 

statements.

An audit of financial statements involves performing procedures to obtain audit evidence about the amounts 

and disclosures in the financial statements. The procedures selected depend on the auditor’s judgment, 

including the auditor’s assessment ofthe risks of material misstatement of the financial statements, whether

due to fraud or error. In making those risk assessments, the auditor considers internal control relevant to

the entity’s preparation and fair presentation of the financial statements in order to design audit procedures 

that are appropriate in the circumstances, but not for the purpose of expressing an opinion on the

effectiveness of the entity’s internal control. Accordingly, we express no such opinion. An audit of financial

statements also involves evaluating the appropriateness of the accounting policies used and the

reasonableness of significant accounting estimates made by management, as well as evaluating the overall 

presentation of the financial statements. Our audits also included performing such other procedures as we

considered necessary in the circumstances. 

Opinion on Financial Statements 

In our opinion, FTC’s financial statements present fairly, in all material respects, FTC’s financial position

as of September 30, 2021, and 2020, and its net cost of operations, changes in net position, budgetary 

resources, and custodial activity for the fiscal years then ended in accordance with U.S. generally accepted

accounting principles. 

Other Matters

RequiredSupplementary Information

U.S. generally accepted accounting principles issued by the Federal Accounting Standards

Advisory Board (FASAB) require that the RSI be presented to supplement the financial

statements. Although the RSI is not a part of the financial statements, FASAB considers this 

information to be an essential part of financial reporting for placing the financial statements in

appropriate operational, economic, or historical context. We have applied certain limited

procedures to the RSI in accordance with U.S. generally accepted government auditing

standards, which consisted of inquiries of management about the methods of preparing the RSI

and comparing the information for consistency with management’s responses to the auditor's 

inquiries, the financial statements, and other knowledge we obtained during the audit of the 

financial statements, in order to report omissions or material departures from FASAB

guidelines, if any, identified by these limited procedures. We did not audit and we do not 

express an opinion or provide any assurance on the RSI because the limited procedures we

applied do not provide sufficient evidence to express an opinion or provide any assurance.
57

Other Information

FTC’s other information contains a wide range of information, some of which is not directly

related to the financial statements. This information is presented for purposes of additional

analysis and is not a required part of the financial statements or the RSI. We read the other 

information included with the financial statements in order to identify material inconsistencies,

if any,with the audited financial statements. Our audit was conducted for the purpose offorming

an opinion on FTC’s financial statements. We did not audit and do not express an opinion or

provide any assurance on the other information.

Report on Internal Control over Financial Reporting

In connection with our audits of the FTC’s financial statements, we considered the FTC’s internal 

control over financial reporting, consistent with our auditor’s responsibility discussed below. We

performed our procedures related to the FTC’s internal control over financial reporting in accordance 

with U.S. generally accepted government auditing standards.

Management’s Responsibility

FTC management is responsible for maintaining effective internal control over financial reporting, 

including the design, implementation, and maintenance of internal control relevant to the preparation 

and fair presentation of financial statements that are free from material misstatement, whether due to

fraud or error.

Auditor’s Responsibility

In planning and performing our audit of FTC’s financial statements as of and for the year ended 

September 30, 2021, in accordance with U.S. generally accepted government auditing standards, we

considered the FTC’s internal control over financial reporting as a basisfor designing audit procedures 

that are appropriate in the circumstances for the purpose of expressing our opinion on the financial 

statements, but not for the purpose of expressing an opinion on the effectiveness of the FTC’s internal 

control over financial reporting. Accordingly, we do not express an opinion on the FTC’s internal 

control over financial reporting. We are required to report all deficiencies that are considered to be

significant deficienciesor material weaknesses. We did not consider all internal controls relevant to

operating objectives, such as those controls relevant to preparing performance information and

ensuring efficient operations. 

A deficiency in internal control exists when the design or operation of a control does not allow 

management or employees, in the normal course of performing their assigned functions, to prevent, or 

detect and correct, misstatements on a timely basis. A material weakness is a deficiency or

combination of deficiencies in internal control, such that there is a reasonable possibility that a

material misstatement of the entity’s financial statements will not be prevented, or detected and 

corrected on a timely basis. A significant deficiency is a deficiency, or a combination of deficiencies, 

in internal control that is less severe than a material weakness, yet important enough to merit attention 

by those charged with governance. 
58 FEDERAL TRADE COMMISSION

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

Definition and Inherent Limitations of Internal Control over Financial Reporting

An entity’s internal control over financial reporting is a process effected by those charged with

governance, management, and other personnel, the objectives of which are to provide reasonable 

assurance that (1) transactions are properly recorded, processed, and summarized to permit the 

preparation of financial statements in accordance with U.S. generally accepted accounting principles, 

and assets are safeguarded against loss from unauthorized acquisition, use, or disposition, and (2) 

transactions are executed in accordance with provisions of applicable laws, including those governing

the use of budget authority, regulations, contracts, and grant agreements, noncompliance with which 

could have a material effect on the financial statements.

Because of its inherent limitations, internal control over financial reporting may not prevent, or detect 

and correct, misstatements due to fraud or error.

Results of Our Consideration of Internal Control over Financial Reporting

Our consideration of internal control was for the limited purpose described above, and was not

designed to identify all deficiencies in internal control that might be material weaknesses and

significant deficiencies or to express an opinion on the effectiveness of the FTC’s internal control over

financial reporting. Given these limitations, during our audit, we did not identify any deficiencies in

internal control over financial reporting that we consider to be material weaknesses. However,

material weaknesses may exist that have not been identified.

Intended Purpose of Report on Internal Control over Financial Reporting

The purpose of this report is solely to describe the scope of our consideration of the FTC’s internal

control over financial reporting and the results of our procedures, and not to provide an opinion on the

effectiveness of the FTC’s internal control over financial reporting. This report is an integral part of

an audit performed in accordance with U.S. generally accepted government auditing standards in

considering internal control over financial reporting. Accordingly, this report on internal control over

financial reporting is not suitable for any other purpose.

Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements 

In connection with our audits of FTC’s financial statements, we tested compliance with selected 

provisions of applicable laws, regulations, contracts, and grant agreements consistent with our 

auditor’s responsibility discussed below. We caution that noncompliance may occur and not be

detected by these tests. We performed our tests of compliance in accordance with U.S. generally 

accepted government auditing standards. 

Management’s Responsibility

FTC management is responsible for complying with laws, regulations, contracts, and grant agreements 

applicable to the FTC.
59

Auditor’s Responsibility

Our responsibility is to test compliance with selected provisions of applicable laws, regulations,

contracts, and grant agreements applicable to FTC that have a direct effect on the determination of

material amounts and disclosures in FTC’s financial statements, and perform certain other limited

procedures. Accordingly, we did not test compliance with all laws, regulations, contracts, and grant 

agreements applicable to FTC. 

Results of Our Tests for Compliance with Laws, Regulations, Contracts, and Grant Agreements 

Our tests for compliance with selected provisions of applicable laws, regulations, contracts, and grant 

agreements disclosed no instances of noncompliance for fiscal year 2021 that would be reportable 

under U.S. generally accepted government auditing standards. However, the objective of our tests was

not to provide an opinion on compliance with laws, regulations, contracts, and grant agreements 

applicable to FTC. Accordingly, we do not express such an opinion.

Intended Purpose of Report on Compliance with Laws, Regulations, Contracts, and Grant Agreements

The purpose of this report is solely to describe the scope of our testing of compliance with selected 

provisions of applicable laws, regulations, contracts, and grant agreements, and the results of that 

testing, and not to provide an opinion on compliance. This report is an integral part of an audit 

performed in accordance with U.S. generally accepted government auditing standards in considering

compliance. Accordingly, this report on compliance with laws, regulations, contracts, and grant 

agreements is not suitable for any other purpose.

Greenbelt, Maryland 

November 12, 2021
60

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

PRINCIPAL FINANCIAL STATEMENTS

FINANCIAL STATEMENT DESCRIPTIONS

A brief description of the five principal financial statements presented on the following pages is provided: 

Balance Sheet – Presents the combined amounts the agency had to use or distribute (assets) versus the amounts the 

agency owed (liabilities), and the difference between the two (net position) 

Statement of Net Cost – Presents the annual cost of agency operations The gross cost less offsetting revenue is used 

to determine the net cost 

Statement of Changes in Net Position – Reports the accounting activities that caused the change in net position 

during the reporting period 

Statement of Budgetary Resources – Reports how budgetary resources were made available and the status of those 

resources at fiscal year-end 

Statement of Custodial Activity – Reports collections and their disposition by the agency on behalf of the Treasury 

General Fund and one other Federal agency The FTC acts as custodian and does not have use of these funds 

The accompanying Notes to the Financial Statements describe significant accounting policies as well as detailed 

information on select statement lines 
61

BALANCE SHEET

AS OF SEPTEMBER 30, 2021 AND 2020

(DOLLARS IN THOUSANDS)

2021 2020

Assets (Note 2):

Intragovernmental:

Fund balance with Treasury (Note 3) $ 617,499 $ 790,507 

Accounts receivable, Net (Note 4) 32 69 

Advances and prepayments 6 153 

Total intragovernmental assets 617,537 790,729 

Other than intragovernmental:

Accounts receivable, Net (Note 4) 51,166 628,049 

General property, plant, and equipment, Net (Note 5) 22,262 25,604 

Total other than intragovernmental assets 73,428 653,653

Total Assets $ 690,965 $ 1,444,382 

Liabilities (Notes 6 and 7):

Intragovernmental:

Accounts payable $ 1,270 $ 830 

Other liabilities (Note 7) 2,753 2,708 

Total intragovernmental liabilities 4,023 3,538 

Other than intragovernmental:

Accounts payable 9,610 11,724 

Other liabilities:

Accrued redress due to claimants 51,116 628,026 

Undisbursed redress collections (Note 13) 384,821 677,109

Other (Note 7) 28,351 27,272 

Total other than Intragovernmental liabilities 473,898 1,344,131

Total Liabilities 477,921 1,347,669 

Net position (Note 1(o)):

Total unexpended appropriations 27,000 - 

Total cumulative results of operations 186,044 96,713 

Total Net Position 213,044 96,713 

Total Liabilities and Net Position $ 690,965 $ 1,444,382 

The accompanying notes are an integral part of these statements.
62

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020 

(DOLLARS IN THOUSANDS)

2021 2020

Strategic Goal 1: Protect Consumers:

Intragovernmental costs $ 48,723 $ 50,640 

Public costs 144,410 144,239 

Gross costs, protect consumers 193,133 194,879 

Intragovernmental earned revenue (268) (5)

Public earned revenue (12,936) (12,470)

Earned revenue, protect consumers (13,204) (12,475)

Net Cost, Protect Consumers 179,929 182,404 

Strategic Goal 2: Maintain Competition:

Intragovernmental costs 42,861 43,486 

Public costs 127,038 123,863 

Gross costs, maintain competition 169,899 167,349 

Intragovernmental earned revenue (918) (848)

Public earned revenue (236,655) (101,580)

Earned revenue, maintain competition (237,573) (102,428)

Net Cost, Maintain Competition (67,674) 64,921 

Net Cost of Operation $ 112,255 $ 247,325 

The accompanying notes are an integral part of these statements.
63

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(DOLLARS IN THOUSANDS)

2021 2020

Unexpended Appropriations:

Beginning balance $ - $ - 

Appropriations received 218,472 216,966 

Appropriations used (191,472) (216,966)

Change in unexpended appropriations 27,000 - 

Total Unexpended Appropriations 27,000 - 

Cumulative Results of Operations:

Beginning balance $ 96,713 $ 113,716 

Appropriations used 191,472 216,966 

Imputed financing 10,131 13,373 

Other (17) (17) 

Net cost of operations (112,255) (247,325)

Change in Cumulative Results of Operations 89,331 (17,003)

Cumulative Results of Operations 186,044 96,713 

Net Position (Note 1(o)) $ 213,044 $ 96,713

The accompanying notes are an integral part of these statements.
64

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

STATEMENT OF BUDGETARY RESOURCES

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(DOLLARS IN THOUSANDS)

2021 2020

Budgetary Resources: 

 Unobligated balance, brought forward, October 1 $ 4,969 $ 15,027

 Recoveries of unpaid prior year obligations 8,607 7,114

 Other changes in unobligated balance 92 125

 Unobligated balance from prior year budget authority, net 13,668 22,266

 Appropriations 218,472 216,966

 Spending authority from offsetting collections 164,761 115,117

Total Budgetary Resources $ 396,901 $ 354,349 

Status of Budgetary Resources: 

 New obligations and upward adjustments (total) (Note 10) $ 351,526 $ 349,380

 Unobligated balance, end of year: 

 Apportioned, unexpired accounts 41,695 2,742

 Unapportioned, unexpired accounts 3,680 2,227 

 Unexpired unobligated balance, end of year 45,375 4,969 

 Unobligated balance, end of year (total) 45,375 4,969

Total Budgetary Resources $ 396,901 $ 354,349

Outlays, Net: 

 Outlays, gross $ 350,082 $ 340,159

 Actual offsetting collections (250,891) (115,028)

 Outlays, net 99,191 225,131

 Distributed offsetting receipts (8,143) (6,705)

 Agency outlays, net $ 91,048 $ 218,426

The accompanying notes are an integral part of these statements.
65

STATEMENT OF CUSTODIAL ACTIVITY

FOR THE YEARS ENDED SEPTEMBER 30, 2021 AND 2020

(DOLLARS IN THOUSANDS)

Protect 

Consumers

Maintain 

Competition 2021 2020

Revenue Activity (Note 12):

Sources of collections:

Premerger filing fees (net of refunds) $ - $ 16,460 $ 16,460 $ 101,573 

Civil penalties and fines 146,197 - 146,197 4,854,148 

Consumer redress 7,993 - 7,993 6,969 

Other miscellaneous receipts 134 - 134 34 

Total cash collections 154,324 16,460 170,784 4,962,724 

Accrual adjustments - - - (236)

Total Custodial Revenue $ 154,324 $ 16,460 $ 170,784 $ 4,962,488 

Disposition of Collections (Note 12):

Transferred to others:

Treasury general fund $ 154,324 $ - $ 154,324 $ 4,861,151 

Department of Justice - 16,460 16,460 101,573 

Amounts yet to be transferred - - - (236)

Total Disposition of Collections $ 154,324 $ 16,460 $ 170,784 $ 4,962,488 

Net Custodial Activity $ - $ - $ - $ - 

The accompanying notes are an integral part of these statements.
66

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTES TO THE FINANCIAL STATEMENTS 

NOTE 1—SIGNIFICANT ACCOUNTING POLICIES 

(a) Reporting Entity 

The reporting entity is a component of the U S 

Government For this reason, some of the assets and 

liabilities reported by the Federal Trade Commission 

may be eliminated for Government-wide reporting 

because they are offset by assets and liabilities 

of another U S Government entity The financial 

statements should be read with the realization that they 

are for a component of the U S Government, a sovereign 

entity The accompanying financial statements and 

notes of the FTC include financial activity recorded in 

all funds under the FTC’s control The FTC maintains 

these funds including appropriations received for 

salaries and necessary expenses, as well as non-entity 

funds that are primarily collections derived from court 

ordered judgments and settlements held for subsequent 

distribution to approved claimants 

The FTC records and tracks financial activities using 

Treasury Account Symbols (TAS) Each TAS included 

in the agency’s fund accounting structure is described 

below: 

General Funds 

Salaries and Expenses (TAS 29X0100): Each year, this 

account receives budget authority from an appropriation 

and offsetting collections, up to a limit set by Congress, 

to fund necessary expenses of the agency Offsetting 

collections include fees collected for premerger 

notification filings under the Hart-Scott-Rodino (HSR) 

Antitrust Improvement Act of 1976, and fees collected 

for the National Do Not Call Registry, which operates 

under Section 5 of the FTC Act Collections in excess 

of congressional limits are unavailable by law and are 

included in the FTC’s unavailable – excess offsetting 

collections (See Note 3, Fund Balance with Treasury ) 

Salaries and Expenses (TAS 29 0100): In FY 2021, 

the FTC received an appropriation under the American 

Rescue Plan Act (ARPA) ARPA provides funding 

to cover cost increases as a result of the COVID-19 

pandemic of 2020-2021 Funding for the FTC under 

ARPA includes payroll costs, consumer education, and 

monitoring of consumer complaints received into the 

Consumer Sentinel Network ARPA funds will remain 

available until the end of fiscal year 2026 

Deposit Fund

Consumer Redress Escrow (TAS 29X6013): This 

account consists of money collected as a result of 

court ordered judgments related to the consumer 

redress program and held temporarily by the FTC until 

distributed (either directly by the FTC or through a 

third-party agent) to consumers or harmed entities, or 

transferred to the General Fund of the U S Government 

Judgments imposed but not yet collected are accrued 

as accounts receivable and recorded in this account 

Accrued receivables and funds collected are considered 

non-entity assets under the FTC’s custody or 

management They do not affect the FTC’s net position 

and are not reported on the agency’s Statement of 

Changes in Net Position (See Note 3, Fund Balance with 

Treasury and Note 13, Consumer Redress Activities ) For 

reporting purposes, funds held by redress third 

party administrators outside of the U S Treasury on 

behalf of harmed consumers are not part of the FTC 

reporting entity 

Clearing/Suspense Account 

Budget Clearing and Suspense (TAS 29F3875): Prior 

to a systems process change in the first quarter of FY 

2021, fees collected for premerger notification filings 

under the HSR Act were deposited, initially, into the 

Budget Clearing and Suspense account, then distributed 

equally to the FTC (as an offsetting collection in the 

general fund) and the Department of Justice (DOJ) 

Premerger receipts are now split evenly upon collection 

between the FTC and the DOJ, eliminating the custodial 

activity transactions The Budget Clearing and Suspense 

account is still used to process refund payments to 

vendors (See Note 1(p), Revenues and Other Financing 

Sources ) 

Receipt Accounts 

Fines, Penalties, and Forfeitures, Customs, Commerce, 

and Antitrust Laws (TAS 29 1040): Collections of civil 

penalties imposed in court actions for violations of 

antitrust acts and FTC orders are deposited into this 
67

account Penalties imposed but not yet collected are 

accrued as accounts receivable and recorded in this 

account The cash balance in the account is transferred 

to the General Fund of the U S Government at the end 

of each fiscal year 

General Fund Proprietary Receipts (TAS 29 3220): 

Miscellaneous receipts that by law are not available for 

the FTC’s use are recorded in this account An example 

is fees collected under the Freedom of Information 

Act Furthermore, collections for the consumer 

redress program for which redress to consumers is not 

practicable are also recorded in this account These 

funds are ultimately disgorged to the U S Treasury The 

Department of the Treasury automatically transfers all 

cash balances in this receipt account to the General 

Fund of the U S Government at the end of each fiscal 

year 

(b) Basis of Presentation and Accounting 

The accompanying financial statements present the 

financial position, net cost of operations, changes in net 

position, budgetary resources, and custodial activities 

of the FTC, and have been prepared from the accounting 

records of the FTC These financial statements may 

differ from other financial reports submitted pursuant to 

the Office of Management and Budget (OMB) directives 

for the purpose of monitoring and controlling the use of 

the FTC’s budgetary resources 

The FTC’s financial statements are prepared in 

conformity with U S Generally Accepted Accounting 

Principles (GAAP) for federal entities, as promulgated 

by the Federal Accounting Standards Advisory Board 

(FASAB), and with OMB Circular A-136, Financial 

Reporting Requirements (as revised in August 2021) 

Transactions are recorded on both an accrual and a 

budgetary basis Accordingly, revenues are recognized 

when earned and expenses are recognized when 

incurred, without regard to the receipt or payment of 

cash Accrual methods of accounting may differ from 

budgetary accounting principles, which are designed 

to facilitate compliance with legal requirements and 

controls over the use of Federal funds The differences 

relate primarily to the capitalization and depreciation of 

property and equipment, as well as the recognition of 

other long-term assets and liabilities 

As described in Note 1(a), Reporting Entity, the FTC 

maintains a primary fund to account for salaries and 

operating expenses There are limited intra-entity 

transactions with any other fund (e g , deposit fund) 

that require eliminating entries to present consolidated 

statements Furthermore, the FTC does not currently 

have any funds classified as dedicated collections 

which require separate reporting under FASAB 

Statement of Federal Financial Accounting Standards 

(SFFAS) 43, Funds from Dedicated Collections 

Accordingly, the proprietary financial statements 

are not labeled consolidated nor is the Statement of 

Budgetary Resources (SBR) presented as combined 

FTC reconciles its intragovernmental activity and works 

with agency trading partners to reduce significant 

or material differences in conformance with U S 

Treasury intragovernmental reporting guidelines and 

requirements of OMB Circular A-136 

Assets, liabilities, revenues, and costs are classified 

in these financial statements according to the type 

of entity associated with the transactions Balances 

classified as intragovernmental arise from transactions 

with other federal entities Balances not classified 

as intragovernmental arise from transactions with 

individuals or organizations outside of the Federal 

Government (i e , with the public) 

The FTC presents net cost of operations by its two 

major strategic goals: Protect Consumers and Maintain 

Competition These goals are described in the agency’s 

strategic and performance plan and align with the 

agency’s major programs 

(c) Use of Estimates 

The preparation of financial statements in conformity 

with GAAP requires management to make estimates 

and assumptions that affect the reported amounts 

of assets and liabilities at the date of the financial 

statements and the reported amounts of revenues and 

expenses during the reporting period For example, 

estimates are used in computing accounts payable 

for vendor service contracts, the allowance for 

uncollectible accounts, and the allocation of costs to 

strategic goals in the Statement of Net Cost Actual 

results could differ from the estimated amounts The 

vendor accounts payable accrual is an estimate, and is 
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FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

accrued separately from the accounts payable accruals 

for travel and interagency agreements The FTC uses 

statistical techniques to evaluate vendor accounts 

payable balances for previous fiscal years, averages 

the balances to obtain an accrual estimate, and then 

adjusts the estimate using a factor that represents 

the proportional change in obligations between the 

current and the previous fiscal year Every year, the 

agency statistically validates that the year-end vendor 

accounts payable accrual was reasonable The validated 

amount is subsequently used in calculating the following 

year’s estimate, which also considers any changes to 

invoice payment timeframes that may affect the vendor 

accounts payable statistical assumptions 

(d) Budget Authority 

The Congress passes appropriations annually that 

provide the FTC with authority to obligate funds for 

necessary expenses to carry out program activities 

These funds are available until expended, subject 

to the OMB apportionment and to congressional 

restrictions on the expenditure of funds (see FTC’s 

FY 2021 Congressional Budget Justification, page 3, 

“Appropriations Language Provisions”) In addition, the 

FTC places internal restrictions on fund expenditures 

to ensure the efficient and proper use of all funds 

The FTC’s budget authority is derived from direct 

appropriations and offsetting collections The FTC 

accounts for budget authority in its General Fund 

accounts (29X0100 and 29 0100) as reflected in the 

Statement of Budgetary Resources 

(e) Classified Activities 

Accounting standards require all reporting entities 

to disclose that accounting standards allow certain 

presentations and disclosures to be modified, if needed, 

to prevent the disclosure of classified information 

(f) Entity and Non-Entity Assets 

The FTC reports on both entity and non-entity assets 

in the financial statements Assets that the agency is 

authorized to use in its operations are entity assets 

Assets that the agency holds on behalf of another 

federal agency or a third party and are not available 

for the FTC’s use are non-entity assets Non-entity 

assets include collections and accounts receivable that 

arise from court-order judgments for monetary relief 

and civil monetary penalties These non-entity assets 

are included in the financial statements along with 

offsetting non-entity liabilities of equal amount (See 

Note 2, Entity and Non-Entity Assets ) 

(g) Fund Balance with Treasury 

Fund Balance with Treasury (FBwT) is an asset of a 

reporting entity and a liability of the General Fund of 

the U S Government Amounts reported for FBwT 

represent commitments by the federal government 

to provide resources to particular programs; however, 

they do not represent net assets to the government as 

a whole When a reporting entity seeks to use FBwT to 

liquidate budgetary obligations, Treasury will finance 

the disbursements with current receipts or borrow 

from the public if a deficit exists On the FTC’s financial 

statements, FBwT represents the aggregate amount of 

undisbursed funds in the FTC’s general funds, deposit 

fund, and clearing/suspense fund The general fund cash 

balance includes a portion that is available to the FTC to 

make expenditures and pay liabilities and a portion that 

is unavailable Deposit fund and clearing/suspense fund 

balances are non-entity funds that are temporarily held 

by the FTC until transferred to another federal agency 

or distributed to a third party Fund balances are carried 

forward into subsequent fiscal years until disbursements 

are made (See Note 3, Fund Balance with Treasury ) 

(h) Accounts Receivable, Net 

Accounts receivable, net of allowances, reflect the 

FASAB standard for the recognition of losses using 

the collection criterion of “more likely than not” as 

prescribed in SFFAS 1, Accounting for Selected Assets 

and Liabilities This criterion results in receivable 

balances that are more conservatively stated than those 

valued by the private sector under GAAP FASAB states 

that it is appropriate to recognize the nature of federal 

receivables, which, unlike trade accounts of private 

firms or loans made by banks, are not created through 

credit screening procedures Rather, these receivables 

arise because of the assessment of fines from regulatory 

violations In these circumstances, historical experience 

and economic realities indicate that these types of 

claims are frequently not fully collectible Accounts 

receivable includes estimates of the net cash value from 
69

court appointed receivers for which the FTC anticipates 

the proceeds will be deposited in the Consumer Redress 

Escrow account (29X6013) 

The method used to estimate the allowance for 

uncollectible accounts consists of individual case 

analysis by a case manager who assesses the debtor’s 

ability and willingness to pay, the defendant’s payment 

history, and the probable recovery amount including the 

value of assets Based on the litigation and collection 

status, cases may be referred to the Treasury for 

collection action (See Note 4, Accounts Receivable, 

Net ) 

(i) General Property, Plant, and Equipment 

The FTC’s property, plant, and equipment (PP&E) 

consists of general equipment used by the agency and 

capital improvements made to buildings leased from the 

General Services Administration (GSA) by the FTC for 

office space, as well as software leased and purchased 

from vendors The FTC’s capitalization policy, Accounting 

for Property, Plant, and Equipment, was updated with an 

effective date on or after October 1, 2014 PP&E placed 

in service prior to October 1, 2014, will continue to be 

accounted for based on the capitalization policy in effect 

at the time acquired, until fully depreciated or removed 

from service 

Effective October 1, 2014, capitalization thresholds are 

as follows:

Asset Type Capitalization 

Threshold

Furniture $ 50,000

General Equipment $ 50,000

IT Equipment $ 150,000

Leasehold Improvements $ 150,000

Internal Use Software $ 200,000

The FTC reports property and equipment at historical 

cost and capitalizes acquisitions based on the above 

thresholds for items with a useful life of two or more 

years Property and equipment that meet these criteria 

are depreciated or amortized using the straight-line 

method over the estimated useful life of the asset 

An exception applies to leasehold improvements, 

which are amortized over the lesser of the useful 

life of the asset or the remaining lease term Assets 

under development, such as internal use software and 

leasehold improvements with an estimated aggregate 

cost meeting the threshold criteria, are capitalized and 

then amortized once completed and placed into service 

Normal repairs and maintenance, and PP&E that do 

not meet the capitalization criteria, are recognized as 

an expense in the current period (See Note 5, General 

Property, Plant, and Equipment, Net ) 

(j) Accrued Liabilities and Accounts Payable 

Accrued liabilities and accounts payable represent a 

probable future outflow or other sacrifice of resources 

from past transactions or events Liabilities are 

recognized when they are incurred, regardless of 

whether they are covered by budgetary resources The 

FTC has both entity and non-entity liabilities Entity 

liabilities cannot be liquidated without legislation 

that provides the resources to do so In addition, the 

government, acting in its sovereign capacity, can 

abrogate the FTC’s liabilities (other than contracts) 

Non-entity liabilities represent claims against non-entity 

assets and include: undisbursed consumer redress 

collections, accrued redress amounts due to claimants, 

and the custodial liability for amounts owed to the 

General Fund of the U S Government 

(k) Employee Health Benefits and Life Insurance 

FTC employees are eligible to participate in the 

contributory Federal Employees’ Health Benefit 

Program (FEHBP) and the Federal Employees’ Group 

Life Insurance Program (FEGLIP) administered by the 

Office of Personnel Management (OPM) The FTC 

contributes a percentage to each program to pay for 

current benefits In accordance with FASAB SFFAS 5, 

Accounting for Liabilities of the Federal Government, 

the FTC recognizes the liability and associated expense 

for health and life insurance benefits at the time the 

employee’s services are rendered 

(l) Employee Retirement Benefits 

FTC employees participate in either the Civil Service 

Retirement System (CSRS) or the Federal Employees’ 

Retirement System (FERS) administered by the OPM 

Employees hired after December 31, 1983, are covered 

by FERS and Social Security, while employees hired prior 
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FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

to January 1, 1984, were allowed to elect joining FERS or 

remaining in CSRS For employees participating in CSRS, 

the FTC contributes 7 percent of the employee’s basic 

pay to the Civil Service Retirement and Disability Fund 

For employees participating in FERS, the FTC contributes 

13 2 percent to the Federal Employees’ Retirement 

Fund New employees hired between January 1 and 

December 31, 2013, participate in FERS-RAE (Revised 

Annuity Employees) New employees hired on or after 

January 1, 2014, participate in FERS-FRAE (Further 

Revised Annuity Employees) The FTC contributes 11 1 

percent for both FERS-RAE and FERS-FRAE In addition, 

the FTC contributes the employer’s matching share to 

the Social Security Administration under the Federal 

Insurance Contributions Act (FICA), which fully covers 

FERS participating employees FTC contributions are 

recognized as current operating expenses 

The Thrift Savings Plan (TSP) is a defined contribution 

retirement savings and investment plan for employees 

covered by either CSRS or FERS Participating employees 

may contribute any dollar amount or percentage of 

basic salary to the TSP, not to exceed an annual dollar 

limit set by law In calendar year 2021, the annual 

contribution limit is $19,500 and employees age 50 

and over may contribute an additional $6,500 in catchup contributions For those employees participating in 

FERS, the FTC makes a mandatory 1 percent contribution 

to this plan and, in addition, matches 100 percent of the 

first 3 percent contributed by employees and 50 percent 

of the next 2 percent of employee contributions CSRSparticipating employees do not receive a matching 

contribution from the FTC The FTC contributions to the 

TSP are recognized as current operating expenses 

The FTC does not report CSRS and FERS assets, 

accumulated plan benefits, or unfunded liabilities, if 

any, applicable to its employees This information is 

reported by the OPM; however, the FTC recognizes 

the full cost of providing future pension benefits to 

covered employees at the time the employees’ services 

are rendered using cost factors provided by the OPM 

that estimate the true service cost of providing the 

pension benefits Contributions made by the FTC and 

its employees do not cover the full cost of retirement 

benefits The FTC recognizes the excess of the true 

service cost over amounts contributed as an imputed 

cost to achieve compliance with SFFAS 5 This additional 

cost is financed by the OPM and has no impact on the 

budgetary resources of the FTC Imputed costs are 

reported as expenses on the Statement of Net Cost 

with offsetting imputed financing sources reported on 

the Statement of Changes in Net Position (See Note 14, 

Reconciliation of Net Operating Cost and Net Budgetary 

Outlays ) 

(m) FECA and Other Post-Employment Benefits 

The Federal Employees’ Compensation Act (FECA) 

administered by the U S Department of Labor (DOL) 

provides income and medical cost protection to covered 

Federal civilian employees injured on the job, and 

employees who have incurred a work-related injury or 

occupational disease The DOL bills the FTC annually 

for the claims paid and the FTC recognizes the FECA 

liability for future payment Payment is deferred for two 

years to allow for funding through the budget The FTC 

also recognizes a FECA actuarial liability, which is an 

estimate for the future workers compensation as a result 

of past events using procedures developed by the DOL 

to estimate the liability FECA liabilities are reported 

as not covered by budgetary resources (See Note 6, 

Liabilities Not Covered by Budgetary Resources ) 

FTC employees eligible to participate in the FEHBP 

and the FEGLIP may continue to participate in these 

programs after their retirement The FTC recognizes a 

current cost of providing post-retirement benefits using 

cost factors provided by the OPM that estimate the true 

cost of providing these benefits to current employees 

The cost of providing post-retirement benefits for 

the FEHBP and FEGLIP is financed by the OPM and 

recognized as an imputed financing source by the FTC 

(See Note 14, Reconciliation of Net Operating Cost and 

Net Budgetary Outlays ) 

(n) Annual and Sick Leave 

The FTC accrues an annual leave liability when 

employees earn leave and reduces the liability when 

employees take leave The balance in this account 

reflects the current leave balances and pay rates of the 

FTC employees Budget execution rules do not allow 

this liability to be funded as earned The liability is 
71

funded when leave is taken or when paid out as a lump 

sum at the end of employment As a result, accrued 

annual leave is reported as not covered by budgetary 

resources Sick leave is non-vested and expensed as 

used (See Note 6, Liabilities Not Covered by Budgetary 

Resources ) 

(o) Net Position 

The portion of the FTC’s budget authority funded 

by its no-year direct appropriation is fully expended 

during the year Therefore, the remaining unexpended 

appropriation balance in net position at the end of the 

fiscal year reflects the unspent ARPA funds 

Cumulative results of operations represent the net 

results of operations since the agency’s inception, the 

cumulative amount of prior period adjustments, the 

remaining net book value of capitalized assets, and 

future funding requirements (See Statement of Changes 

in Net Position ) 

(p) Revenues and Other Financing Sources 

As a component of the Government-wide reporting 

entity, the FTC is subject to the federal budget process, 

which involves annual appropriations The financial 

transactions that are supported by budgetary resources, 

which include appropriations, are generally the same 

transactions reflected in agency and Government-wide 

financial reports In addition to an annual appropriation 

provided by the Congress, the FTC’s activities are 

financed through exchange revenues it receives from 

others Intragovernmental exchange revenues arise from 

reimbursable transactions with other federal entities 

The FTC provides consulting and technical assistance 

aimed at developing sound competition policies under 

interagency agreements Reimbursable revenue is 

recognized as expenses are incurred 

The majority of the FTC’s exchange revenues are from 

the public, consisting of fees collected for premerger 

notification filings under the HSR Act and fees collected 

for the National Do Not Call (DNC) Registry The 

HSR Act establishes a waiting period before mergers, 

acquisitions, or transfers of assets that meet or exceed 

certain thresholds may be completed Entities must file 

premerger notifications with the FTC and the Antitrust 

Division of the DOJ HSR fees are split equally between 

the FTC and the DOJ with fees determined by the 

values and sizes of involved parties As mandated by 

an amendment to the Clayton Act, the FTC revises 

the jurisdictional threshold requirements annually 

based on the change in gross national product The 

DNC Registry Fee Extension Act of 2007 established 

a permanent fee structure for the DNC registry and 

provides that fees be reviewed annually and adjusted 

for inflation, as appropriate Telemarketers must pay an 

annual subscription fee and download a list of telephone 

numbers of consumers who do not wish to receive 

calls Fees are based on the number of area codes 

downloaded Revenues for both HSR and DNC fees are 

recognized upon collection 

The reporting entity’s budgetary resources reflect past 

congressional action and enable the entity to incur 

budgetary obligations, but they do not reflect assets 

to the federal government as a whole Budgetary 

obligations are legal obligations for goods, services, or 

amounts to be paid based on statutory provisions After 

budgetary obligations are incurred, Treasury will make 

disbursements to liquidate the budgetary obligations 

and finance those disbursements in the same way it 

finances all disbursements, which, is to borrow from the 

public if there is a budget deficit 

(q) Methodology for Assigning Costs and 

Exchange Revenues 

The FTC allocates costs and exchange revenues on the 

Statement of Net Cost to its two major strategic goals: 

Protect Consumers and Maintain Competition Costs 

and exchange revenues that are identified specifically 

with each of these two strategic goals are charged or 

credited directly Costs not directly attributable to these 

two goals, including costs related to the FTC’s third 

goal, Advance Performance, are allocated based on the 

percentage of dollars directly traceable to each of these 

two goals 
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FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTE 2—ENTITY AND NON-ENTITY ASSETS 

The FTC’s entity assets are comprised of undisbursed 

general funds; accounts receivable; advances and 

prepayments; and property, plant, and equipment 

Accounts receivable, net, represents amounts due from 

other Federal agencies, current and former employees, 

and vendors Advances and prepayments include 

amounts paid to the Department of Transportation for 

transit subsidies on behalf of FTC employees The FTC’s 

non-entity assets include fund balance with Treasury 

and accounts receivable The fund balance with Treasury 

consists of amounts held temporarily in a deposit 

fund pending disbursement to harmed consumers for 

redress Accounts receivable, net, is the estimated 

amount collectible on consumer redress judgments and 

civil penalties 

Entity and non-entity assets consisted of the following as of September 30, 2021: 

(Dollars in thousands) 2021

Entity

2021

Non-Entity

2021

Total

Intragovernmental:

 Fund balance with Treasury:

 General funds $ 232,678 $ - $ 232,678 

 Deposit funds - consumer redress - 384,821 384,821 

 Accounts receivable, net 32 - 32 

 Advances and Prepayments 6 - 6

Total intragovernmental assets 232,716 384,821 617,537 

 Accounts receivable, net 50 51,116 51,166 

 Property, plant and equipment, net 22,262 - 22,262 

Total Assets $ 255,028 $ 435,937 $ 690,965 

Entity and non-entity assets consisted of the following as of September 30, 2020: 

(Dollars in thousands) 2020

Entity

2020

Non-Entity

2020

Total

Intragovernmental:

 Fund balance with Treasury:

 General funds $ 113,398 $ - $ 113,398 

 Deposit funds - consumer redress - 677,109 677,109 

 Accounts receivable, net 69 - 69 

 Advances and Prepayments 153 - 153 

Total intragovernmental assets 113,620 677,109 790,729 

 Accounts receivable, net 23 628,026 628,049 

 Property, plant and equipment, net 25,604 - 25,604 

Total Assets $ 139,247 $ 1,305,135 $ 1,444,382 
73

NOTE 3—FUND BALANCE WITH TREASURY 

There are no differences between amounts reported 

by the FTC and those reported to U S Treasury as 

of September 30, 2021, and 2020 In terms of the 

relationship to the budget, the FTC’s Fund balance 

with Treasury consists of undisbursed appropriated 

funds, which are either unobligated or obligated, as 

well as non-budgetary deposit funds arising from 

amounts collected for consumer redress and not yet 

disbursed to disbursing agents or directly to claimants 

The unobligated balance includes both available and 

unavailable balances The higher unobligated balance 

available is primarily attributable to the receipt of 

the ARPA appropriation of $30 4 million in FY 2021 

Furthermore, the FTC’s direct appropriation has 

increased by $20 million in FY 2021 from the FY 2020 

amount 

The large increase in Unavailable – Excess Offsetting 

Collections is due to HSR Premerger fees collected 

during FY 2021 in excess of the congressional 

authorized amount Under the FTC statutory authorities, 

the agency is permitted to retain a specified amount of 

offsetting collections to use for the necessary expenses 

of its direct appropriation For FY 2021, the maximum 

amount is $150 million and the agency collected $237 

million in HSR Premerger filing fees The volume of 

Premerger filings has more than doubled from FY 

2020, which was severely impacted by the coronavirus 

pandemic The unavailable-unapportioned balance 

is the result of recoveries of prior-year obligations 

that exceed apportioned amounts The unavailable - 

temporary reduction of $6,450 thousand consists of 

$5,418 thousand HSR Premerger and $1,032 thousand 

National Do Not Call Registry offsetting collections 

sequestered from FY 2013 

Fund balance with Treasury consisted of the following as of September 30, 2021 and 2020:

(Dollars in thousands) 2021 2020

Status of Fund Balance with Treasury:

 Unobligated balance:

 Available - apportioned $ 41,695 $ 2,742 

 Unavailable - unapportioned 3,680 2,227 

 Unavailable - excess offsetting collections 112,651 26,004 

 Unavailable - temporary reduction 6,450 6,450 

 Total Unobligated balance: 164,476 37,423 

 Obligated balance not yet disbursed 68,202 75,975 

 Non-budgetary fund balance with Treasury 384,821 677,109 

Total Status of Fund Balance with Treasury $ 617,499 $ 790,507 
74

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTE 4—ACCOUNTS RECEIVABLE, NET 

The majority of the FTC’s accounts receivable are nonentity accounts receivable arising from the settlement 

or litigation of administrative and federal court cases 

in connection with the consumer redress program, and 

from civil monetary penalties imposed for violation 

of an FTC order and/or antitrust acts Because of the 

nature of these receivables, they are frequently not fully 

collectible and are offset with a significant allowance 

The allowance for uncollectible accounts is based on an 

analysis by a case manager who assesses the debtor’s 

ability and willingness to pay, the defendant’s payment 

history, and the probable recovery amount including the 

value of assets These non-entity accounts receivable 

are included in the financial statements along with 

offsetting non-entity liabilities 

Non-entity redress gross accounts receivable is the 

court ordered judgment amount, usually a calculated 

amount of ill-gotten gains by the defendant(s) The 

decrease in gross receivables is primarily due to a 

vacated 2018 judgment against AbbVie for $493,716 

thousand The related allowance for uncollectible 

accounts is the estimate the FTC will not collect from 

the defendant(s), which often is a large percentage of 

the judgment 

Net interest and the related allowance for doubtful 

accounts balance was recorded as of September 30, 

2021 Accumulated unrecognized interest on receivables 

deemed uncollectible totaled $41,886 thousand and 

$23,983 thousand as of September 30, 2021, and 2020 

Accounts receivable, net consisted of the following as of September 30, 2021:

(Dollars in thousands) Gross

Receivables 

Allowance for

Uncollectible

Accounts 

 2021 Net

 Entity Accounts Receivable: 

 Intragovernmental $ 32 $ - $ 32 

 With the public 50 - 50 

 Total entity accounts receivable 82 - 82 

 Non-Entity Accounts Receivable: 

 Consumer redress 2,403,071 (2,351,955) 51,116 

 Civil penalties - - - 

 Total non-entity accounts receivable 2,403,071 (2,351,955) 51,116 

Total Accounts Receivable $ 2,403,153 $ (2,351,955) $ 51,198

Accounts receivable, net consisted of the following as of September 30, 2020:

(Dollars in thousands) Gross

Receivables 

Allowance for

Uncollectible

Accounts 

 2020 Net

 Entity Accounts Receivable: 

 Intragovernmental $ 69 $ - $ 69

 With the public 23 - 23 

 Total entity accounts receivable 92 - 92 

 Non-Entity Accounts Receivable: 

 Consumer redress 2,977,274 (2,349,248) 628,026 

 Civil penalties 151 (151) - 

 Total non-entity accounts receivable 2,977,425 (2,349,399) 628,026 

Total Accounts Receivable $ 2,977,517 $ (2,349,399) $ 628,118 
75

NOTE 5—GENERAL PROPERTY, PLANT, AND 

EQUIPMENT, NET 

The following represents the FTC’s capital assets and 

accumulated depreciation as of September 30, 2021, 

and 2020 No asset impairments were recognized 

in either year The net book value of capitalized 

assets has declined from the previous fiscal year as 

a result of continual depreciation and amortization 

expenses Current year depreciation and amortization 

expense is $3,803 thousand, as presented in Note 14 

“Reconciliation of Net Operating Cost and Net 

Budgetary Outlays ” The capitalized asset value 

has declined from the prior year as a result of asset 

disposals Assets disposed of include WAN circuits, 

data storage expansions, software, and system 

enhancements All assets disposed of have been fully 

depreciated to a zero net book value Asset purchases 

during the last 12 months total $462 thousand, 

the majority of which is attributable to leasehold 

improvements in relation to the San Francisco office 

relocation 

Property, plant, and equipment, net consisted of the following as of September 30, 2021:

Asset Class

(Dollars in thousands)

Service 

Life

Acquisition 

Value

Accumulated 

Depreciation/

Amortization

Net 

Book Value

Equipment 5-20 Years $ 20,361 $ (19,515) $ 846 

Leasehold improvements 15 Years 46,959 (26,360) 20,599 

Software 5 Years 18,064 (17,247) 817 

Total Property, Plant, and Equipment $ 85,384 $ (63,122) $ 22,262 

Property, plant, and equipment, net consisted of the following as of September 30, 2020:

Asset Class

(Dollars in thousands)

Service 

Life

Acquisition 

Value

Accumulated 

Depreciation/

Amortization

Net 

Book Value

Equipment 5-20 Years $ 20,813 $ (19,439) $ 1,374 

Leasehold improvements 15 Years 46,542 (23,459) 23,083 

Software 5 Years 20,709 (19,562) 1,147 

Total Property, Plant, and Equipment $ 88,064 $ (62,460) $ 25,604 
76

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTE 6—LIABILITIES NOT COVERED BY 

BUDGETARY RESOURCES 

The FTC recognizes two categories of liabilities not 

covered by budgetary resources described below: 

Liabilities not Covered by Budgetary Resources 

Liabilities not covered by budgetary resources require 

future congressional action whereas liabilities covered 

by budgetary resources reflect prior congressional 

action Regardless of when the Congressional action 

occurs, when the liabilities are liquidated, Treasury will 

finance the liquidation in the same way that it finances 

all other disbursements, which is to use current receipts 

in the event of a budget surplus or borrow from the public 

in the event of a budget deficit These liabilities include 

unfunded FECA liabilities and accrued annual leave 

Liabilities Not Requiring Budgetary Resources 

Liabilities that do not require the use of budgetary 

resources are covered by monetary assets that are not 

budgetary resources to the entity (non-entity assets) 

These include: 

Undisbursed Redress Collections - offsetting liability 

to the non-entity deposit fund balance for consumer 

redress that is payable to approved claimants 

Accrued Redress due to Claimants - offsetting liability 

to the non-entity accounts receivable for consumer 

redress that upon collection will be payable to approved 

claimants 

Liabilities Not Covered by Budgetary Resources consisted of the following as of September 30, 2021:

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2021 Total

Intragovernmental Liabilities:

FECA liability $ 170 $ - $ 170 

Total Intragovernmental Liabilities 170 - 170 

Non-Federal Liabilities:

Accrued leave 17,294 - 17,294 

Actuarial FECA 1,966 - 1,966 

Undisbursed redress collections - 384,821 384,821 

Accrued redress due to claimants - 51,116 51,116 

Total Non-Federal Liabilities 19,260 435,937 455,197 

Total Unfunded Liabilities 19,430 435,937 455,367 

Liabilities Covered by Budgetary Resources 22,554 

Total Liabilities $ 477,921 

Liabilities Not Covered by Budgetary Resources consisted of the following as of September 30, 2020:

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2020 Total

Intragovernmental Liabilities:

FECA liability $ 380 $ - $ 380 

Total Intragovernmental Liabilities 380 - 380 

Non-Federal Liabilities:

Accrued leave 16,278 - 16,278 

Actuarial FECA 2,442 - 2,442 

Undisbursed redress collections - 677,109 677,109 

Accrued redress due to claimants - 628,026 628,026 

Total Non-Federal Liabilities 18,720 1,305,135 1,323,855 

Total Unfunded Liabilities 19,100 1,305,135 1,324,235 

Liabilities Covered by Budgetary Resources 23,434 

Total Liabilities $ 1,347,669 
77

NOTE 7 – OTHER LIABILITIES 

As of September 30, 2021, and 2020, components 

of amounts reported on the Balance Sheet as Other 

Intragovernmental Liabilities and Other Liabilities 

(Other Than Intragovernmental) are presented below 

FECA liabilities are long-term in nature and are not 

funded with budgetary resources while accrued 

employee benefits and accrued funded payroll and leave 

are covered by budgetary resources For Governmentwide reporting, the liabilities for Accrued Redress Due 

to Claimants and Undisbursed Redress Collections are 

reported as Other Liabilities in the Financial Report 

of the U S Government Because these liabilities are 

material to the FTC, they are displayed as separate 

line-items on the agency’s Balance Sheet (See Note 6, 

Liabilities Not Covered by Budgetary Resources ) 

Other Liabilties consisted of the following as of September 30, 2021 and 2020:

(Dollars in thousands) 2021 2020

Intragovernmental liabilities:

 Accrued employee benefits $ 2,583 $ 2,328

 FECA liability 170 380 

Total intragovernmental liabilities 2,753 2,708

Other than intragovernmental liabilities:

 Accrued funded payroll and leave 26,385 24,830

 Actuarial FECA 1,966 2,442 

Total other than intragovernmental liabilities 28,351 27,272 

Total Other Liabilities $ 31,104 $ 29,980 
78

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTE 8—LEASES 

Leases of government-owned and commercial-owned 

property are made through and managed by the 

GSA While leases with the GSA are cancellable, the 

FTC’s intention is to stay in the GSA leased space and 

disclose the amounts that will be paid in the future 

to the GSA under signed lease agreements The FTC 

currently leases spaces from four government-owned 

properties and seven commercial properties totaling 

approximately 591 thousand square feet for use as 

offices, storage, and parking The FTC’s government 

leases expire on various dates through 2029, while the 

commercial leases expire at various dates through 2031 

In addition, the FTC is committed under short-term 

operating leases with commercial vendors for parking 

and telecommunications equipment Total short-term 

lease obligations are $1,284 thousand as of September 

30, 2021 and these contracts expire in fiscal year 2022 

with options to renew Future minimum lease payments 

on contracts with remaining terms in excess of one year 

are presented in the tables below 

NOTE 9 – INTER-ENTITY COSTS 

Goods and services may be received from other federal 

entities at no cost or at a cost less than the full cost 

to the providing federal entity In accordance with 

accounting standards, certain costs of the providing 

federal entity that are not fully reimbursed are 

recognized as imputed costs in the Statement of Net 

Cost and are offset by imputed financing sources in the 

Statement of Changes in Net Position Such imputed 

costs and financing sources relate to employee benefits 

paid by the OPM No other unreimbursed costs of 

goods and services are included in the FTC’s financial 

statements as imputed costs and imputed 

financing sources 

Future minimum lease payments due under leases of government-owned property for 

the fiscal year ended September 30, 2021:

Fiscal Year 2021

(Dollars in thousands)

2022 $ 8,232

2023 8,084

2024 8,096

2025 8,108 

2026 8,121 

Thereafter 23,313 

Total Future Minimum Lease Payments $ 63,954 

Future minimum lease payments due under leases of commercial-owned property for 

the fiscal year ended September 30, 2021:

Fiscal Year 2021

(Dollars in thousands)

2022 $ 15,679 

2023 15,790 

2024 7,506 

2025 2,012 

2026 1,687 

Thereafter 5,020 

Total Future Minimum Lease Payments $ 47,694
79

NOTE 10—UNDELIVERED ORDERS AT THE END OF THE PERIOD 

In addition to future lease commitments discussed in Note 8, the FTC is committed under obligations for goods and 

services that have been ordered but not yet received Aggregate undelivered orders are presented in the table below 

Undelivered obligations consisted of the following as of September 30, 2021 and 2020:

(Dollars in thousands) 2021 2020

Non-Federal Undelivered Orders Unpaid $ 40,374 $ 47,561 

Non-Federal Undelivered Orders Paid - -

Total Non-Federal Undelivered Orders 40,374 47,561

Federal Undelivered Orders Unpaid 6,478 5,574 

Federal Undelivered Orders Paid 6 153 

Total Federal Undelivered Orders 6,484 5,727 

Total Undelivered Orders $ 46,858 $ 53,288 

NOTE 11—EXPLANATION OF DIFFERENCES 

BETWEEN THE STATEMENT OF BUDGETARY 

RESOURCES AND THE BUDGET OF THE UNITED 

STATES GOVERNMENT 

The Budget of the United States Government 

(President’s Budget) contains budget proposals for the 

upcoming fiscal year along with forecasted results for 

the current fiscal year and actual results for the previous 

fiscal year The most current version of the President’s 

Budget is the FY 2022 President’s Budget, which 

contains FY 2020 actual results Detailed information 

on the FTC is available in the Appendix to the 

President’s Budget under Other Independent Agencies 

There are no material differences between amounts 

reported in the FY 2020 Statement of Budgetary 

Resources and the FY 2020 actual amounts as reported 

in the FY 2022 President’s Budget; however, the 

Statement of Budgetary Resources includes Distributed 

Offsetting Receipts, which are excluded from the 

President’s Budget The FY 2023 Budget of the United 

States Government is not available to compare FY 2021 

actual amounts to the FY 2021 Statement of Budgetary 

Resources The expected availability for this report is 

February 2022 on the OMB’s website 

NOTE 12—CUSTODIAL ACTIVITIES 

The primary custodial activities of the FTC are: 

Premerger Filing Fees 

Fees collected for premerger notification filings under 

the HSR Act are divided evenly between the FTC and the 

DOJ In FY 2021, the FTC implemented a new collection 

process for the Premerger filing fees Collections are 

now split evenly between the FTC and the DOJ upon 

receipt Under the previous method, the FTC collected 

the full amount and remitted half to the DOJ, which 

resulted in a custodial liability and custodial transfers A 

total of $16 million in Premerger fees were processed on 

behalf of the DOJ at the start of fiscal year 2021 before 

the process change was implemented As of September 

30, 2021 and 2020, the FTC collected $236,648 and 

$101,573 thousand in HSR premerger filing fees Filings 

have more than doubled in FY 2021 as the onset of the 

COVID-19 pandemic severely impacted the prior year’s 

volume 

Civil Penalties 

Civil monetary penalties and antitrust violations 

collected in connection with the settlement or litigation 

of the FTC’s administrative or Federal court cases are 
80

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

collected by either the FTC or the DOJ as provided 

by law In those situations where the FTC collects the 

penalties, the funds are deposited in a receipt account 

with the Treasury Civil penalties collected also include 

amounts collected for undecided civil penalty cases 

that are held until final disposition of the cases All 

civil penalties collected are transferred to the General 

Fund of the U S Government at the end of the fiscal 

year In FY 2021, DISH Network paid a penalty of $122 

million for violations of the Telemarketing Sales Rule 

and Telephone Consumer Protection Act In FY 2020, 

the FTC collected $4,850 million from Facebook as part 

of a settlement agreement related to allegations the 

company violated a 2012 privacy order by deceiving 

users about their ability to control personal information 

The penalty against Facebook is the largest ever 

imposed on a company for violating consumers’ privacy 

and ranks among the largest penalties ever assessed by 

the U S government for any violation 

Consumer Redress 

Collections for consumer redress reported on the 

Statement of Custodial Activity are limited to those 

collections that have been disgorged to the Treasury 

Net disgorgements to the Treasury were $7,993 

thousand as of September 30, 2021 and $6,969 

thousand as of September 30, 2020 

Other line items on the Statement of Custodial Activity 

include: 

Accrual Adjustments 

Accrual adjustments represent the change in accounts 

receivable, net of allowances for uncollectible accounts, 

for civil penalties assessed in court actions 

Amounts yet to be Transferred 

Amounts yet to be transferred represent the change in 

the offsetting liability for civil penalties due to Treasury 

that is established at the time an accounts receivable for 

civil penalties is recorded 
81

NOTE 13—CONSUMER REDRESS ACTIVITIES 

The FTC obtains funds for consumer redress in 

connection with the settlement or litigation of both 

administrative proceedings and Federal court cases The 

FTC holds redress funds in a deposit fund at Treasury 

until a determination is made on the practicability of 

redress The FTC attempts to distribute funds to injured 

parties whenever possible If redress is determined to 

be practicable, funds are either directly disbursed by 

the FTC to claimants or are transferred to accounts at 

financial institutions from which redress third party 

administrators process claims and disburse proceeds to 

injured parties Disbursements to claimants and third 

party administrators totaled $453,345 and $130,301 

thousand as of September 30, 2021, and 2020 

In those cases where consumer redress is not 

practicable, funds are transferred (disgorged) to the 

Treasury, or on occasion, used for consumer education 

or another purpose as directed by the final order issued 

by the court Major components of the redress program 

include eligibility determination, claimant notification, 

and administration of redress to claimants 

Redress fund activities consisted of the following for the fiscal years ended September 30, 2021 and 2020:

(Dollars in thousands) 2021 2020

Consumer Redress:

Fund Balance with Treasury

Beginning balance $ 677,109 $ 265,432 

Collections 169,050 548,947 

Disbursements to claimants and third party administrators for 

redress, net (453,345) (130,301)

Disgorgements to Treasury, net (7,993) (6,969)

Total Fund Balance with Treasury, Ending $ 384,821 $ 677,109 

Accounts Receivable, Net

Beginning balance $ 628,026 $ 616,306 

Net activity (576,910) 11,720 

Total Accounts Receivable, Ending $ 51,116 $ 628,026 
82

FINANCIAL SECTION

 ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

NOTE 14 — RECONCILIATION OF NET 

OPERATING COST AND NET BUDGETARY 

OUTLAYS 

In accordance with the requirements of SFFAS 7, 

Accounting for Revenue and Other Financing Sources, 

as amended by SFFAS 53, Budget and Accrual 

Reconciliation, the schedules presented below bridge 

the gap between the net operating costs presented on 

the Statement of Net Cost and the net outlays presented 

on the Statement of Budgetary Resources for the fiscal 

years ended September 30, 2021, and 2020 Net cost is 

calculated on an accrual basis while net outlays consist 

of the receipt and use of cash from a budgetary basis 

This reconciliation assures the integrity of relationships 

between proprietary and budgetary accounting 

Reconciliation of Net Operating Cost and Net Budgetary Outlays for the Year Ended September 30, 2021:

(Dollars in thousands)

FY 2021

Intragovernmental With the Public Total

Net Operating Cost (SNC) $ 90,398 $ 21,857 $ 112,255 

Components of Net Operating Cost Not Part of the Budgetary Outlays

Depreciation and Amortization - (3,803) (3,803)

Losses on Asset Dispositions - - -

Increase/(Decrease) in Assets (185) 28 (157)

(Increase)/Decrease in Liabilities (485) 1,035 550

Imputed Costs (10,131) - (10,131)

Total Components of Net Operating Cost Not Part of the Budgetary Outlays (10,801) (2,740) (13,541)

Components of Budgetary Outlays Not Part of Net Operating Cost

Purchases of Assets 417 44 461 

Total Components of Budgetary Outlays Not Part of Net Operating Cost 417 44 461

Other Reconciling Items

Deposits in Clearing Funds - Pre-Merger Refunds Due - - -

Miscellaneous Receipts - (8,127) (8,127)

Total Other Reconciling Items - (8,127) (8,127) 

Net Outlays (Calculated) $ 80,014 $ 11,034 $ 91,048

Budgetary Agency Outlays, Net - Statement of Budgetary Resources $ 91,048 

Net Operating Cost (SNC) $ 93,273 $ 154,052 $ 247,325 

Components of Net Operating Cost Not Part of the Budgetary Outlays

Depreciation and Amortization - (5,587) (5,587)

Losses on Asset Dispositions - (617) (617)

Increase/(Decrease) in Assets (68) 16 (52)

(Increase)/Decrease in Liabilities (642) (3,695) (4,337)

Imputed Costs (13,373) - (13,373)

Total Components of Net Operating Cost Not Part of the Budgetary Outlays (14,083) (9,883) (23,966)

Components of Budgetary Outlays Not Part of Net Operating Cost

Purchases of Assets 17 1,738 1,755 

Total Components of Budgetary Outlays Not Part of Net Operating Cost 17 1,738 1,755

Other Reconciling Items

Deposits in Clearing Funds - Pre-Merger Refunds Due - 315 315

Miscellaneous Receipts - (7,003) (7,003)

Total Other Reconciling Items - (6,688) (6,688)

Net Outlays (Calculated) $ 79,207 $ 139,219 $ 218,426

Budgetary Agency Outlays, Net - Statement of Budgetary Resources $ 218,426 

Reconciliation of Net Operating Cost and Net Budgetary Outlays for the Year Ended September 30, 2020:

(Dollars in thousands)

FY 2020

Intragovernmental With the Public Total
83

NOTE 15 — COVID-19 ACTIVITY 

In FY 2021, the FTC received an appropriation of 

$30,400 thousand through the American Rescue Plan 

Act (ARPA), signed into law by President Biden on 

March 11, 2021 This appropriation authorizes funding 

for the FTC to cover higher costs associated with the 

COVID-19 pandemic to include: $24,000 thousand for 

payroll expenses, $4,400 thousand for processing and 

monitoring of consumer complaints received through 

the Consumer Sentinel Network, and $2,000 thousand 

for consumer-related education In FY 2021 the FTC 

incurred $4,390 thousand of obligations for payroll 

expenses and management and professional support 

services in support of these initiatives to combat the 

rising costs of the agency due to COVID-19 Funds are 

available through the end of FY 2026 Summarized 

financial information is provided below as of the end of 

FY 2021 

Summarized COVID-19 financial activity for the fiscal years ended September 30, 2021 and 2020:

(Dollars in thousands) 2021 2020

Total Assets $ 27,000 $ -

Total Liabilities - -

Unexpended Appropriations 27,000 -

Net Operating Cost $ 3,400 $ - 

Budgetary Resources $ 30,400 $ -

Obligations Incurred 4,390 - 

Unobligated Balance 26,010 -

Net Outlays $ 3,400 $ -
84 FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 
FINANCIAL SECTION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

O T H E R 

INFORMATION
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FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

Summary of the Top Management and 

Performance Challenges Identified by the 

Office of Inspector General

As required by the Reports Consolidation Act of 2000, the Federal Trade Commission (FTC) Office of Inspector 

General (OIG) has identified the following issues as the most serious management and performance challenges 

facing the FTC.1

1. Securing Information Systems and Networks from Destruction, Data Loss, or Compromise 

Guarding information technology (IT) systems remains a continuing challenge for the FTC. Our FY 2020 Federal 

Information Security Modernization Act of 2014 (FISMA) evaluation concluded that the FTC’s information 

security program and practices were effective––however, data breaches, ransomware attacks, and other forms of 

cyber intrusion remain an ever-present concern. 

FTC Progress in Addressing the Challenge. The Commission reports that it continues to manage essential 

supporting IT activities by taking a risk-based, cost-effective approach. It describes improvements that include the 

augmentation of security services, addressing staffing challenges, mitigating the risk of ransomware and supply 

chain attacks through updated controls and reporting, and continuing to implement TIC 3.0-compliant services. 

2. Seeking Monetary Relief for Consumers 

This year’s unanimous Supreme Court ruling in AMG Capital Management, LLC v. Federal Trade Commission,

593 U. S. __, 141 S. Ct. 1341 (2021), stripped the FTC of its authority, exercised for more than 4 decades, to seek 

monetary relief for consumers per Section 13(b). For the past few years, the FTC has lobbied Congress to pass 

legislation affirming the FTC’s ability to seek monetary relief in federal court. Without the passage of legislation, 

the FTC will continue to have challenges in obtaining monetary relief in a significant portion of its cases. 

FTC Progress in Addressing the Challenge. Since the Supreme Court issued its decision in AMG, the Commission 

has described for the OIG how it has taken steps to mitigate the loss of its equitable monetary relief authority 

under Section 13(b). First, the Commission reports that it continues to provide support and technical assistance to 

Congress on proposed legislation to restore the Commission’s authority to obtain monetary relief under 13(b)—

as well as taking other steps to retain maximum ability to return money to harmed consumers. In addition, in 

several cases filed prior to AMG and pending at the time of the ruling, the Commission reports that it negotiated 

settlements that included some amount of monetary relief notwithstanding the Commission’s loss of its equitable 

monetary relief authority under Section 13(b). . 

3. Controlling Expert Witness Costs 

The escalating costs of expert witness services represents a significant and continuing risk to the FTC: between 

FYs 2014 and 2020, the FTC’s costs for expert witness services rose from $7.7 million to $21.3 million. In the 

FTC’s FY 2022 budget request, the agency identified a need to allocate an additional $10,200,000 in FY 2021 for 

competition-related expert witness needs due to the increased numbers of complex investigations and litigations. 

This highlights the difficulties that unpredictable case demands present as the FTC decides whether or not to 

commit initially to the use of FTC resources for expert services. 

FTC Progress in Addressing the Challenge. FTC management reports that, during the past year, the Bureau of 

Competition has performed monthly expert witness cost projections—consistently updating them with data from 

current, abandoned, and new cases. The FTC also describes how management is leveraging in-house economist 
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FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

resources, when possible, to help reduce the costs associated with contracting for expert witnesses. Finally, 

as noted in the FTC’s FY 2022 budget request, an additional $10,200,000 was allocated in FY 2021 for 

competition-related expert witness needs.

4. Ensuring Mission Success Following the Expiration of Current Evacuation Orders

In March 2020, the COVID-19 pandemic caused the FTC, along with many federal agencies, to abruptly 

transform its works environment from primarily in-person to almost entirely remote. Despite the challenges 

brought on by this sudden shift in the work environment, the FTC was able to continue functioning successfully. 

In creating this new work environment, the FTC, like other federal agencies, will face the challenge of 

continually evolving public health conditions, as well as IT-related challenges. 

FTC Progress in Addressing the Challenge. FTC management has described how its Pandemic Response Team 

has ensured the continuity of all operations under changing conditions. In addition, OCIO informs the OIG that 

it intends to update the agency’s Information Resource Management Plan and IT Strategy to ensure that the 

agency’s investments in IT infrastructure can support management’s considerations for indefinite operations in a 

hybrid environment.

5. Understanding Fraudulent Identity Theft Complaints 

As first mentioned in our FY 2020 top management and performance challenges report, the FTC faces 

challenges in addressing an increasing number of potentially fraudulent complaints submitted to IdentityTheft.gov. 

The FTC has continued to experience a significant increase in the volume of identity theft complaints 

compared to the same period in 2020. As the number of all complaints in Sentinel rise, so does the number of 

fraudulent ones; the FTC’s challenge is in determining the legitimacy of these identity theft complaints. A high 

volume of fraudulent complaints could require considerable FTC resources in identifying and implementing 

countermeasures—and, more broadly, could affect the FTC’s data and reputational integrity. 

FTC Progress in Addressing the Challenge. The FTC reports that it is continuously analyzing IdentityTheft.gov 

for patterns in complaints to identify those that are potentially fraudulent. It also indicates that it is taking steps 

to mitigate the harm, such as disallowing system users from downloading and printing suspect complaints. The 

FTC describes how it is actively collaborating with the OIG and external law enforcement on investigations of 

IdentityTheft.gov abuse. 

Watch List Item

The OIG also maintains a “watch list,” which currently contains one issue that does not meet the threshold of a 

serious management or performance challenge, but nevertheless warrants the vigilant attention of agency officials. 

Managing Records and Sensitive Agency Information 

The success of the FTC’s consumer protection and competition missions increasingly depends on ingesting and 

integrating, large volumes of complex data into Commission activities—and protecting the data from misuse. 

The FTC needs a more consistent application of standard procedures over the collection, organization, and 

standardization of data. 

Agency Status. The FTC reports exploring ways to eliminate organizational silos and implement a unified 

agency-wide method for managing matters, information, and records. For example, the FTC has informed the 

OIG that it is considering establishing and implementing an agency-wide matter management work flow and 

recordkeeping system used to conduct and preserve all information and records in National Archives and Records 

Administrations-approved formats throughout the lifecycle of each matter. 

1

The entire FY 2021 report is available at https://www.ftc.gov/system/files/documents/reports/final-oig-fy-2021-report-ftcs-top-managementperformance-challenges/oig_fy_2021_ftc_top_management_challenges_final_report_9-30-21.pdf
88

OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

SUMMARY OF FINANCIAL STATEMENT AUDIT AND MANAGEMENT ASSURANCES

TABLE 1: SUMMARY OF FINANCIAL STATEMENT AUDIT

Audit Opinion Unmodified

Restatement No

Material Weaknesses Beginning 

Balance New Resolved Consolidated Ending Balance

0 0 0 0 0

Total Material Weaknesses 0 0 0 0 0

TABLE 2: SUMMARY OF MANAGEMENT ASSURANCES

Effectiveness of Internal Control Over Financial Reporting 

(Federal Managers’ Financial Integrity Act (FMFIA) Para. 2)

Statement of Assurance Unmodified

Material Weaknesses Beginning 

Balance New Resolved Consolidated Reassessed Ending Balance

0 0 0 0 0 0

Total Material Weaknesses 0 0 0 0 0 0

Effectiveness of Internal Control Over Operations (FMFIA Para. 2)

Statement of Assurance Unmodified

Material Weaknesses Beginning 

Balance New Resolved Consolidated Reassessed Ending Balance

0 0 0 0 0 0

Total Material Weaknesses 0 0 0 0 0 0

Conformance with Financial Management System Requirements (FMFIA Para. 4)

Statement of Assurance Systems conform to financial management system requirements

Non-Conformances Beginning 

Balance New Resolved Consolidated Reassessed Ending Balance

0 0 0 0 0 0

Total Non-Conformances 0 0 0 0 0 0

Compliance with Section 803(a) of the Federal Financial Management Improvement Act (FFMIA) 

Federal Trade Commission Auditor

1. Federal Financial Management System 

Requirements No lack of compliance noted No lack of compliance noted

2. Applicable Federal Accounting Standards No lack of compliance noted No lack of compliance noted

3. USSGL at Transaction Level No lack of compliance noted No lack of compliance noted
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OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

PAYMENT INTEGRITY

The Improper Payments Elimination and Recovery 

Improvement Act (IPERIA) of 2012 requires agencies to 

annually report on all programs and activities, identify 

those that may be susceptible to significant improper 

payments, estimate annual improper payments in the 

susceptible programs and activities, and report the 

results of their improper payment activities 

In accordance with the OMB A-123 Appendix C 

guidance, the FTC performed the FY 2021 risk 

assessment for all major payment programs including 

payroll, procurement, redress payments to consumers, 

travel, purchase card, premerger filing fee refunds, 

training, and two miscellaneous payment processes The 

FTC evaluated each payment program over $1 million 

using the following qualitative risk factors identified in 

OMB Circular A-123 Appendix C: 

• The relative complexity of the program or activity 

operation 

• The extent and significance of recent changes in the 

program that may be reason for improper payment in 

funding, authorities, practices and procedure 

• The extent and significance of recent changes in 

program payment amounts or volume of payments

• The level, experience, and quality of training for 

personnel responsible for program eligibility 

determination or certifying that payments are 

accurate 

• The inherent risks of improper payments due to the 

nature of programs or operation 

• Known control deficiencies (i e , reported by OIG, 

or GAO) that might hinder accurate payment 

certification 

The FTC performed its FY 2021 quantitative risk 

assessment which assessed risks related to the amounts 

of payments processed relative to the OMB specified 

threshold amounts that define payment programs 

susceptible to improper payments As a result of 

the FY 2021 risk assessment, the FTC determined 

that the agency’s programs and activities presented 

low risk of improper payments and that none of the 

agency’s programs or activities were determined to be 

susceptible to significant improper payments 

The FTC also reviews potential matches on an on-going 

basis and incorporates a pre-award check on potential 

contractors against the Do Not Pay databases to prevent 

improper payments In 2015, the FTC performed and 

documented testing of statistical samples from larger 

payment processes to verify that the FTC payment 

programs are not susceptible to significant improper 

payments which served as the baseline for the FY 2021 

risk assessment In addition, the FTC regularly conducts 

assessments over the internal controls over payment 

processes In 2021, the FTC performed an assessment 

of the Redress payments to consumers program to 

assess the effectiveness of controls over the proper 

authorization, approval, and processing of payments 

For programs with more than $1 million of expenditures, 

the FTC determined and documented that performing 

recapture audits were not cost effective The FTC’s 

analysis had two parts; first the error rates determined 

during the FY 2015 quantitative risk assessment, and 

second the documented management assessments of 

the effective operation of controls within the payment 

processes The 2015 test work used statistical methods 

to project error rates to the population of payments for 

the larger payment processes These larger payment 

amounts could have produced errors classifying the 

process as “Significant” This test work did not detect 

errors within the population of payments and, therefore, 

did not identify payments subject to recapture Recent 

management assessments of each payment process 

determined sufficient controls to detect and prevent 

improper payments were in place and operating 

effectively As a result, the Office of the Chief Financial 

Officer determined and documented that projected 

amounts subject to recapture audits are “de minimis” 

and recapture audits are not cost-effective 
90

OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

CIVIL MONETARY PENALTY ADJUSTMENT FOR INFLATION

The Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation 

Adjustment Act Improvements Act of 2015, requires agencies to make regular and consistent inflationary 

adjustments of civil monetary penalties to improve the effectiveness of civil monetary penalties and to maintain 

their deterrent effect The 2015 Act requires agencies to: (1) adjust the level of civil monetary penalties with an initial 

“catch-up” adjustment; and (2) make subsequent annual adjustments for inflation Accordingly, the Federal Trade 

Commission increased its maximum civil penalty amounts to address inflation since the initial catch-up adjustment 

The following table lists the civil monetary penalties that the FTC may impose, the authority for imposing the penalty, 

penalty description, year enacted, latest year of adjustment, current penalty level, the Bureau that administers 

the penalty, and location for penalty update details Additional information about these penalties and the latest 

adjustment is available in the Federal Register 

Statutory 

Authority 

Penalty 

(Name or 

Description)

Year 

Enacted

Latest year of 

adjustment 

(via statute or 

regulation)

Current Penalty 

Level ($ Amount 

or Range)

SubAgency/ 

Bureau/

Unit

Location for 

Penalty Update 

Details

16 CFR 1 98(a): 15 U S C 18a(g)(1) Premerger filing 

notification 

violations

1976 January 13, 2021 $ 43,792 BC Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(b): 15 U S C 21(l) Violations of cease 

and desist orders

1959 January 13, 2021 $ 23,266 BC Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

6 CFR 1 98(c): 15 U S C 45(l) Unfair or deceptive 

acts or practices

1973 January 13, 2021 $ 43,792 BC and BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(d): 15 U S C 45(m)(1)(A) Unfair or deceptive 

acts or practices

1975 January 13, 2021 $ 43,792 BC and BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(e): 15 U S C 45(m)(1)(B) Unfair or deceptive 

acts or practices

1975 January 13, 2021 $ 43,792 BC and BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(f): 15 U S C 50 Failure to file 

required reports

1914 January 13, 2021 $ 576 BC and BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(g): 15 U S C 65 Failure to 

file required 

statements

1918 January 13, 2021 $ 576 BC Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(h): 15 U S C 68d(b) Failure to maintain 

required records 

1940 January 13, 2021 $ 576 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(i): 15 U S C 69a(e) Failure to maintain 

required records 

1951 January 13, 2021 $ 576 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541
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OTHER INFORMATION

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Statutory 

Authority 

Penalty 

(Name or 

Description)

Year 

Enacted

Latest year of 

adjustment 

(via statute or 

regulation)

Current Penalty 

Level ($ Amount 

or Range)

SubAgency/ 

Bureau/

Unit

Location for 

Penalty Update 

Details

16 CFR 1 98(j): 15 U S C 69f(d)(2) Failure to maintain 

required records 

1951 January 13, 2021 $ 576 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(k): 42 U S C 6303(a) Knowing violations 1975 January 13, 2021 $ 474 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(l): 42 U S C 6395(a) Recycled oil 

labeling violations

1975 January 13, 2021 $ 23,266 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(l): 42 U S C 6395(b) Willful violations 1975 January 13, 2021 $ 43,792 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(m): 15 U S C 1681s(a)(2) Knowing violations 1996 January 13, 2021 $ 4,111 BCP Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

16 CFR 1 98(n): 21 U S C 355 note Non-compliance 

with filing 

requirements

2003 January 13, 2021 $ 15,482 BC Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541

T16 CFR 1 98(o): 42 U S C 17304 Market 

manipulation or 

provision of false 

information to 

federal agencies

2007 January 13, 2021 $ 1,246,249 BC Federal Register 

Vol 86, January 13, 

2021, pages 2539-

2541
OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 
OTHER INFORMATION

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

APPENDICES
94

APPENDICES

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

APPENDIX A: ACRONYMS

Because many of the acronyms in this document are not commonly used, or have multiple meanings, this Appendix 

is provided as a reference This is not all-inclusive, and only meant to show how these acronyms are used in the 

context of this AFR 

Acronym Definition

AFR Agency Financial Report 

APP Annual Performance Plan 

APR Annual Performance Report 

ARC Administrative Resource Center

ARPA American Rescue Plan Act of 2021 

BC Bureau of Competition 

BCP Bureau of Consumer Protection 

CAP Corrective Action Plan 

CSRS Civil Service Retirement System 

DATA Act Digital Accountability and Transparency Act of 2014 

DNC Do Not Call 

DOJ Department of Justice 

DOL Department of Labor 

DQA Data Quality Appendix

ERM Enterprise Risk Management 

FASAB Federal Accounting Standards Advisory Board 

FBwT Fund Balance with Treasury 

FECA Federal Employees’ Compensation Act 

FEGLIP Federal Employees’ Group Life Insurance Program 

FEHBP Federal Employees’ Health Benefit Program 

FERS Federal Employees’ Retirement System 

FERS-FRAE Federal Employees’ Retirement System – Further Revised Annuity Employees

FERS-RAE Federal Employees’ Retirement System – Revised Annuity Employees

FEVS Federal Employee Viewpoint Survey

FISMA Federal Information Security Management Act 

FMFIA Federal Managers’ Financial Integrity Act 

FMO Financial Management Office 

FTC Federal Trade Commission 

FTE Full-Time Equivalent 

FY Fiscal Year 

GAAP Generally Accepted Accounting Principles 

GAO Government Accountability Office 

GSA General Services Administration 

HSR Hart-Scott-Rodino Act 
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APPENDICES

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021

Acronym Definition

IBC Department of the Interior Business Center 

IG Inspector General 

IPERIA Improper Payments Elimination and Recovery Improvement Act 

IT Information Technology 

MCED Multi-Cancer Early Detection 

MOBE My Online Business Education 

NIST National Institute of Standards and Technology 

OCASO Office of the Chief Administrative Services Officer

OFF Oracle Federal Financials 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

OTA Online Trading Academy

PMRO Performance Measure Reporting Official 

PP&E Property, Plant, and Equipment 

SAT Senior Assessment Team 

SBR Statement of Budgetary Resources 

SMC Senior Management Council

TAS Treasury Account Symbol 

TSP Thrift Savings Plan
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APPENDICES

FEDERAL TRADE COMMISSION ❙ Agency Financial Report ❙ FISCAL YEAR 2021 

APPENDIX B: CONTACT INFORMATION AND ACKNOWLEDGEMENTS

FEDERAL TRADE COMMISSION 600 Pennsylvania Avenue, NW

Washington, D C 20580

General Information Number 202-326-2222

Internet Home Page www ftc gov

FTC Spanish Home Page www ftc gov/espanol

Strategic Plan Internet Site www ftc gov/about-ftc/performance

FTC Press Releases www ftc gov/news-events/press-releases

AGENCY FINANCIAL REPORT (AFR) SPECIFIC

The FTC welcomes comments or suggestions for improvement of its AFR Please contact the agency to provide 

feedback or to request additional copies 

AFR Internet Site www ftc gov/about-ftc/performance

AFR Contact Randall Salzer

AFR Telephone 202-326-2028

AFR Email Address gpra@ftc gov

AFR Mailing Address Federal Trade Commission

Attn: AFR, M/D H-701 

600 Pennsylvania Avenue, NW

Washington, D C 20580

CONSUMER RESPONSE CENTER

General Complaints 877-FTC-HELP (877-382-4357) 

Identity Theft Complaints 877-ID-THEFT (877-438-4338) 

TTY (Teletype Consumer Response Center) 866-653-4261 

FTC Complaint Assistant www ftc gov/complaint 

Identity Theft Education, Complaints, and Recovery Plan www identitytheft gov 

National Do Not Call Registry www donotcall gov 

ACKNOWLEDGEMENTS

The FTC offers our sincerest thanks and acknowledges the following individuals who made significant contributions 

in producing this report: Jen Howard and Gretchen Abraham of the Office of the Chair; George Adam, Chris Bryan, 

Monique Fortenberry, Kathryn Gillis, James Hale, Qi Li, Leonard Nadybal, David Rebich, David Robbins, Randall 

Salzer, Lori Walsh-Van Wey, and Michael Ward of the Office of the Executive Director; Nathan Hawthorne, Andria 

Jones, and Kelly Signs of the Bureau of Competition; Jenny Kellogg and Robin Moore of the Bureau of Consumer 

Protection; Catherine Wayne of the Office of Congressional Relations; Mary Harmison and Andrew Katsaros of the 

Office of Inspector General; Betsy Lordan and Jason Wolf of the Office of Public Affairs Finally, we offer thanks to 

AOC Solutions, Heartland Consulting, and Graphic Visions for their contributions in the design and production of this 

report 

WWW FTC GOV

/federaltradecommission

@FTC

ftc gov

/FTCvideos

FEDERAL TRADE COMMISSION

The Work of the Federal Trade Commission is Critical to Protecting 

and Strengthening Free and Open Markets and Promoting Informed 

Consumer Choice, Both in the United States and Around the World