FISCAL YEAR 

2020

AGENCY FINANCIAL

REPORT

FEDERAL TRADE COMMISSION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 1

TABLE OF CONTENTS

INTRODUCTION 3

About This Report 4

How This Report Is Organized 5

The FTC At-A-Glance 6

Message from the Chairman 7

MANAGEMENT’S DISCUSSION AND ANALYSIS 9

Agency and Mission Information 10

Performance Highlights 15

Agency Mission Challenges 26

Management Assurances 33

Financial Highlights 37

FINANCIAL SECTION 55

Message from the Chief Financial Officer 56

Inspector General’s Transmittal Letter for Audit Report 58

Report of Independent Auditors 60

Principal Financial Statements 65

Notes to the Financial Statements 71

OTHER INFORMATION 89

Summary of the Top Management Challenges Identified by the Office of Inspector General 90

Summary of Financial Statement Audit and Management Assurances 91

Payment Integrity 92

Fraud Reduction Report 92

Real Property 93

Civil Monetary Penalty Adjustment for Inflation Implementation Reporting Act Details 94

APPENDICES 97

Appendix A: Acronyms 98

Appendix B: Contact Information and Acknowledgements 100

INTRODUCTION
4 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

INTRODUCTION

ABOUT THIS REPORT

The Federal Trade Commission’s (FTC) fiscal year (FY) 2020 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 2020 APR will be combined 

with the FY 2022 Annual Performance Plan (APP) and included in the FY 2022 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

The FTC received the Association of Government 

Accountants’ Certificate of Excellence in 

Accountability Reporting for its FY 2019 AFR The 

FY 2019 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 

Certificate of Excellence in

Accountability Reporting®

in recognition of outstanding effort in preparing the 

Agency Financial Report for fiscal year 2019

presented to the

Ann M. Ebberts, MS, PMP

Chief Executive Officer, AGA

Diane L. Dudley, CGFM, CPA

Chair, CEAR Board
INTRODUCTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 5

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, 

mission challenges, management assurances on internal controls, and financial highlights 

2. FINANCIAL SECTION

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

Officer (CFO), 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, a fraud reduction report, real property, 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 

MANAGEMENT’S

DISCUSSION AND

ANALYSIS

OTHER

INFORMATION

FINANCIAL

SECTION

APPENDICES
6 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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

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

n The agency had 1,160 full-time equivalent employees at the end of FY 2020 

n Total new budget authority for FY 2020 was $332 million, which comprises $217 million in general fund 

appropriations and $115 million in offsetting collections 

HEADQUARTERS

The FTC established its headquarters at 600 Pennsylvania Ave , N W , with President Franklin D Roosevelt (FDR) 

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 FDR’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 
MESSAGE FROM THE CHAIRMAN

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 7

Joseph J Simons, Chairman

Despite a year of unprecedented challenges presented by the COVID-19 

pandemic, the Federal Trade Commission has continued to deliver on 

our dual mission of protecting consumers and promoting competition 

I am incredibly proud of how well the agency has met these challenges 

and pursued a vigorous law enforcement agenda This Agency Financial Report 

highlights the FTC’s major accomplishments during this time, illustrates 

how efficiently we manage our resources, and outlines our plans to address the 

challenges ahead 

FY 2020 PERFORMANCE HIGHLIGHTS 

CONSUMER PROTECTION

The Commission continued our leadership this year in protecting consumers 

from fraudulent business practices, stopping illegal robocalls, and protecting 

privacy and promoting data security This year, the agency led a multipronged 

effort using warning letters, enforcement actions, education, and outreach, in 

order to stop pandemic-related fraud, including products falsely advertised as 

treatments and cures for COVID-19; online sales of masks or personal protective 

equipment (PPE) that never ship or fail to meet delivery promises and do not 

provide refunds; and misleading claims to consumers and small businesses about 

federal loans or other temporary small business relief 

Other areas of success include:

n A $120 million judgment in the largest land fraud case in FTC history against 

defendants selling lots in a purported luxury development in remote Belize to 

U S retirees 

n A $191 million settlement with the University of Phoenix for falsely 

advertising relationships and job opportunities with major companies This is 

the FTC’s largest settlement in a case against a for-profit school 

n An agreement to bar sales of three mobile “stalking apps,” which allow users to 

spy on phones with the app installed The developers must take steps to ensure 

that the apps will be used only for legitimate purposes 

PROMOTING COMPETITION

For over 100 years, the FTC has enforced the antitrust laws and ensured that 

consumers benefit from competition By preventing anticompetitive mergers and 

stopping business practices that diminish competition, we ensure that consumers 

enjoy benefits such as lower prices, higher quality products and services, and 

more choices in the marketplace In FY 2020, the Hart-Scott-Rodino (HSR) 

merger filing process—long done via paper—was quickly converted to digital 

processes in response to the COVID-19 pandemic Meanwhile, even as they 

were teleworking, agency attorneys were as busy as ever The FTC challenged 28 

mergers this year, more than in any year since FY 2001 

The agency also launched two large competition studies, using our authority 

under Section 6(b) of the FTC Act The first study is looking at what happens 

to health care prices, quality, access, and innovation when states grant antitrust 
8 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

MESSAGE FROM THE CHAIRMAN

immunity to hospital mergers and collaborations through 

the use of certificates of public advantage (COPAs) The 

second study is examining a decade of tech company 

acquisitions made by Alphabet/Google, Amazon com, 

Apple, Facebook, and Microsoft This study will deepen 

our understanding of these types of acquisitions and help 

us evaluate whether we are getting adequate notice of 

transactions that might harm competition 

The FTC also voted to issue new Vertical Merger 

Guidelines, the first ever issued jointly by the 

Commission and the Department of Justice These 

Guidelines explain in clear language how we analyze 

vertical issues in our merger enforcement practice 

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 2020 independent financial audit yielded 

our 24th 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 34)

LOOKING FORWARD

As markets rapidly evolve, the FTC must not only 

address present challenges, but also focus intently on 

the future in order to continue to protect American 

consumers and maintain competition 

The agency will continue to prioritize stopping fraud 

in all of its forms, protecting consumer privacy, and 

targeting illegal robocalls and deceptive advertising, 

while staying apprised of technological developments 

in order to assist with enforcement actions, inform 

policymaking efforts, and educate consumers and 

businesses 

Our competition work remains focused on promoting 

competition across industries, including in the health 

care, pharmaceutical, and high-tech markets To reinforce 

our commitment to ensuring that consumers benefit 

from robust competition in rapidly evolving technology 

markets, we established the Technology Enforcement 

Division 

For more details regarding the Agency Mission 

Challenges, see p 26 

The Office of Inspector General (OIG) identified four 

significant management challenges this year: (1) securing 

information systems and networks from destruction, data 

loss, or compromise; (2) maintaining mission success 

during the COVID-19 pandemic; (3) understanding 

fraudulent identity theft complaints; and (4) costs of 

expert witnesses In addition, the OIG highlighted 

acquisition planning and contract management as a 

“watch list” issue that, while not a serious management 

challenge, still requires attention Agency management 

agrees that these are important challenges and concurs 

with the OIG’s assessment of our progress in addressing 

these challenges (see p 90) 

Working with the FTC’s partners and colleagues in 

Congress, domestic and international law enforcement, 

and industry, the agency will continue to pursue its 

mission to protect American consumers and promote 

competition 

Joseph J Simons, Chairman

November 13, 2020
MANAGEMENT’S

DISCUSSION AND

ANALYSIS
MANAGEMENT’S DISCUSSION AND ANALYSIS

10 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 

OUR PURPOSE AND HISTORY

Consumers and businesses are likely to be more familiar 

with the work of the FTC than they think In the 

consumer protection area, the product warranties, care 

labels in clothes, and labels on home appliances showing 

their energy cost provide information that is required 

by the FTC Likewise, businesses must be familiar with 

the laws requiring truthful advertising and protecting 

consumers’ personally identifiable information These 

laws are enforced by the FTC 

Competition among independent businesses is good for 

consumers, the businesses themselves, and the economy 

Competitive markets yield lower prices and better quality 

goods and services, and a vigorous marketplace provides 

the incentive and opportunity for the development of 

new ideas and innovative products and services Many 

of the laws governing competition are also enforced 

by the FTC 

The FTC has a long tradition of maintaining a 

competitive marketplace for both consumers and 

businesses In 1903, Congress created the predecessor to 

the FTC, the Bureau of Corporations, as an investigatory 

agency within the Department of Commerce and 

Labor The Bureau investigated and published reports 

on the operation of interstate corporations, looking for 

monopolistic practices In one case of note, the Justice 

Department used the Bureau’s 1906 report on petroleum 

transportation when it successfully prosecuted and broke 

up Standard Oil in 1911 In 1914, President Woodrow 

Wilson signed the Federal Trade Commission Act into 

law, creating the FTC, which then absorbed the Bureau 

of Corporations in 1915 

When the FTC was created in 1914, its purpose was 

to prevent unfair methods of competition in commerce 

as part of the battle to “bust the trusts ” Over the years, 

Congress passed additional laws giving the agency 

greater authority over anticompetitive practices 

Recognizing that unfair and deceptive practices can 

distort a competitive marketplace as much as unfair 

methods of competition, in 1938 Congress passed a 

broad prohibition against “unfair or deceptive acts or 

practices in or affecting commerce ” Since then, the FTC 

also has been directed to enforce a wide variety of other 

consumer protection laws and regulations 

OUR ORGANIZATION

The FTC is an independent Federal law enforcement 

agency that reports to the President and to Congress 

on its actions, with both consumer protection and 

competition jurisdiction in broad sectors of the economy 

The agency administers a wide variety of laws, such 

as the Federal Trade Commission Act (FTC Act), 

Fair Credit Reporting Act, and Clayton Act In total, 

the Commission has enforcement or administrative 

responsibilities under more than 70 laws The FTC 

also enforces rules issued pursuant to the FTC Act or 

other laws, including the Business Opportunity Rule 

and the Telemarketing Sales Rule FTC actions include 

pursuing vigorous and effective law enforcement; 

advancing consumers’ interests by sharing its expertise 

with Congress and state legislatures and U S and 

international government agencies; developing policy 

and research tools through hearings, workshops, and 

conferences; and creating practical and plain-language 

educational programs for consumers and businesses 

in a global marketplace with constantly changing 

technologies 

The FTC is headed by a Commission composed of 

five commissioners, nominated by the President and 

confirmed by the Senate, each serving a staggered sevenyear 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 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 11

FTC Commissioners (from left to right): Rebecca Kelly Slaughter, Noah Joshua Phillips, Chairman Joseph J. Simons, 

Joseph J. Simons was sworn in as Chairman on May 

1, 2018. The four Commissioners are Noah Phillips, 

Rohit Chopra, Rebecca Slaughter, and Christine Wilson 

who were also sworn in during 2018. This was the first 

complete changeover in leadership since the agency’s 

founding. 

The FTC’s workforce is its greatest asset. The agency’s 

workforce consists of 1,160 civil service employees 

dedicated to carrying out the agency’s mission.

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

The Bureau of Competition (BC) enforces the nation’s 

antitrust laws, which form the foundation of our free 

market economy. The antitrust laws promote the interests 

of consumers; they support unfettered markets and 

result in lower prices and more choices. 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 seeks to prevent 

anticompetitive mergers and other anticompetitive 

business practices in the marketplace.

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 industry-wide 

Rohit Chopra, Christine S. Wilson.

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 
MANAGEMENT’S DISCUSSION AND ANALYSIS

12 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 to provide 

expertise on topics related to consumer protection and 

business competition 

The Office of Public Affairs informs the news media, 

as well as the public at large, about the activities of 

the FTC and responds to media inquiries about 

Commission actions and policy The office also manages 

FTC gov, the agency’s public website, and social media 

accounts, which are critical communication tools for 

the agency 

The Office of the Chief Privacy Officer ensures that the 

agency’s practices and policies comply with applicable 

federal information privacy and security requirements 

The Office of Policy Planning conducts research, 

develops policy recommendations, and generates written 

comments and reports on a variety of competition 

and consumer protection issues Policy Planning 

staff research and analyze emerging issues relating to 

competition in a variety of industries, including issues at 

the intersection of competition and intellectual property, 

in order to enrich the Commission’s expertise and 

inform enforcement decisions involving novel or 

complex legal issues 

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 

(IT), finances, records, and administrative services 

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 advises and assists the FTC in 

carrying out its responsibilities and duties relative to 

Title VII of the Civil Rights Act of 1964, as amended, 

and other laws, executive orders, and regulatory 

guidelines affecting affirmative employment and the 

processing of equal employment opportunity complaints 

to maintain 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

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 13

FEDERAL TRADE COMMISSION ORGANIZATIONAL CHART

Office of the

Executive Director

David B Robbins

Regions

Bureau of

Competition

Ian Connor

Bureau of

Consumer 

Protection

Andrew Smith

Chairman

Joseph J. Simons

Chief of Staff

Molly Crawford

Commissioner

Noah Joshua 

Phillips

Office of the

General Counsel

Alden F. Abbott

Bureau of

Economics

Andrew Sweeting

Commissioner

Rohit Chopra

Commissioner

Christine S. Wilson

Office of

Congressional Relations

Jeanne Bumpus

Office of

Public Affairs

Cathy MacFarlane

Office of

Inspector General*

Andrew Katsaros

Office of

International Affairs

Randolph W. Tritell

Office of

Policy Planning

Bilal Sayyed

Office of Equal Employment 

Opportunity and Workplace 

Inclusion*

Kevin D. Williams

Office of

the Secretary

April Tabor (Acting)

Commissioner

Rebecca Kelly 

Slaughter

Office of the 

Chief Privacy Officer 

John Krebs

* An independent organization within the FTC

Office of

Administrative Law Judges*

D. Michael Chappell
MANAGEMENT’S DISCUSSION AND ANALYSIS

14 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 Read more about the FTC’s regional offices by clicking on the map below 

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 

Midwest

Western - San Francisco

Southeast

Southwest

East Central

Northeast

Puerto Rico

Northwest

Alaska

Western - Los Angeles

Hawaii

District of

Columbia
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 15

PERFORMANCE HIGHLIGHTS

The FTC has chosen to produce an AFR and a separate 

Annual Performance Report (APR) for FY 2020 The 

FY 2020 APR will be included as part of the FY 2022 

Congressional Budget Justification to be published in 

February 2021 The AFR and APR, will be published at 

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

(Dollars in millions) OBJECTIVES

GOAL 1: Protect consumers from 

unfair and deceptive practices in the 

marketplace.

Net Costs: $182

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: $65

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 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

16 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 (PIO) 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 2020 against established targets for the 

FTC’s nine key performance goals The tables also 

include results from the prior four fiscal years as well as 

a description of how performance results are calculated 

for that performance goal The FTC met or exceeded 

FY 2020 targets on six of nine key performance goals, 

missed targets on two goals, and are still awaiting results 

for one goal 

LEGEND FOR UPCOMING TABLES 

  Signifies that the target was met or exceede

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

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 17

STRATEGIC GOAL 1: PROTECT CONSUMERS FROM UNFAIR AND 

DECEPTIVE PRACTICES IN THE MARKETPLACE

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 are comprised of: (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 2020 Results: The agency saved consumers on average over 14 times the amount of resources devoted to the 

consumer protection program in the past three years, or an average of $1 4 billion per year This is largely attributable 

to the Online Trading Academy, Western Union, and RevenueWire cases Although the results for FY 2020 are 

more than double the target, the amount reported in FY 2020 decreased from prior years because the $7 3 billion in 

consumer redress for the Volkswagen case, which was part of the FY 2017 result, is no longer included in the threeyear average 

FY 2016 

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020

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

$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

18 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 2020 Results: In the last three years, the annual average of the total amount returned to consumers and forwarded 

to the U S Treasury is $2 79 billion In FY 2020, the FTC returned $131 8 million to consumers and forwarded 

$5 0 billion to the U S Treasury The FTC returned money to more than 2 2 million consumers in dozens of cases, 

including Office Depot, LifeLock, Helping America Group and I Works The money returned to the U S Treasury 

included civil penalties obtained in settlements with Facebook, Kohl’s, and HyperBeard In addition, in FY 2020, 

some FTC orders required defendants to self-administer refund programs worth more than $510 7 million in refunds 

to consumers, including University of Phoenix, AT&T Mobility, and Western Union 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

Status

$95.2 million $2.69 billion $3.25 billion $3.52 billion $2.79 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 

$191 MILLION SETTLEMENT WITH UNIVERSITY OF PHOENIX

The University of Phoenix 

(UOP) and its parent company, 

Apollo Education Group, 

agreed to settle for a record 

$191 million to resolve FTC 

charges that they used deceptive 

advertisements that falsely 

touted their relationships 

and job opportunities with 

companies such as AT&T, 

Yahoo!, Microsoft, Twitter, and 

the American Red Cross Under 

the settlement, UOP agreed to 

pay $50 million in cash as well as 

cancel $141 million in debts owed to the school by students who were harmed by the deceptive ads This is the 

largest settlement the Commission has obtained in a case against a for-profit school 

FTC

Settlement

with University

of Phoenix

$191 million

judgment:

$50 million

In consumer refunds

$141 million Source: In debt forgiveness Federal Trade Commission | FTC.gov
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 19

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 Well-informed 

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 2020 Results: In FY 2020, the FTC used the desktop survey on Consumer ftc gov to determine the rate of 

customer satisfaction with FTC consumer education websites The rate of customer satisfaction for Consumer ftc gov

(desktop) was 76 2 The average citizen satisfaction score for participating federal government websites was 75 5 

Due to customer satisfaction survey changes during FY 2020, the FTC can no longer report a combined score for 

Consumer ftc gov and Bulkorder ftc gov, which was done for previous years The Consumer ftc gov desktop survey 

receives the most responses, so the FTC will report this score starting in FY 2020 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

Status

76 77 77 77.7 76.2

75.5 (average

rate for

websites)

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 

FTC RESPONDS TO COVID-19 SCAMS WITH WARNING LETTERS, LITIGATION, AND 

EDUCATION 

The FTC has pursued a multi-prong strategy to fight scams and address consumer issues involving the novel 

Coronavirus Disease 2019 (COVID-19) crisis, including an unprecedented warning letter campaign, law 

enforcement actions, consumer and business education, and national and local outreach Since the pandemic 

began in March, the Commission has issued more than 300 warning letters to marketers claiming their products 

will treat, cure, or prevent COVID-19; multi-level marketers regarding health and earnings claims they or 

their participants are making related to COVID-19, including more than eighty joint warning letters with the 

FDA; Voice over Internet Protocol (VoIP) service providers and other companies warning against “assisting and 

facilitating” illegal COVID-19-related telemarketing calls; and advertisers for potentially misleading claims about 

their purported affiliation with the federal government or emergency loan programs created to protect businesses or 

provide stimulus funds during the pandemic In addition, the FTC has brought enforcement actions against several 

companies for making false claims related to COVID-19 Beginning 

in early February, the FTC stepped up its consumer and business 

education and outreach, building COVID-specific webpages, drafting 

more than 100 blog posts and scam alerts, and partnering with 

other law enforcement partners and industry to reach all segments 

of the population For more information on the FTC’s response to 

COVID-19, please visit https://www ftc gov/coronavirus 
MANAGEMENT’S DISCUSSION AND ANALYSIS

20 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 2020 Results: In FY 2020, the FTC cooperated in 42 instances on consumer protection and privacy matters 

to obtain or share evidence or engage in other enforcement cooperation in investigations, cases, and enforcementrelated projects Foreign authorities assisted the FTC in activities such as sharing consumer complaints, obtaining 

corporate records, and providing other investigative information The FTC also provided assistance to numerous 

foreign authorities to share information and provide investigative assistance using compulsory process The FTC also 

cooperated on enforcement matters with international enforcement organizations such as the ICPEN, the GPEN, 

the UCENet, and the International Mass-Marketing Fraud Working Group 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

Status

53 50 43 48 42 40 

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 

THE SAFE WEB ACT HELPS THE FTC FIGHT FRAUD ACROSS BORDERS 

In September 2020, Congress reauthorized the SAFE WEB Act, originally 

passed in 2006, for a third seven-year period The Act confirms the FTC’s 

statutory authority to sue foreign wrongdoers and supports enforcement 

cooperation with the agency’s foreign counterparts, making it an essential 

tool to combat cross-border fraud Since the SAFE WEB Act’s passage, 

the FTC has relied on the Act’s authority to respond to 165 SAFE WEB 

information-sharing requests from 42 enforcement agencies in 18 foreign 

countries The FTC also has helped its foreign enforcement partners, both 

civil and criminal, to obtain U S -based evidence by issuing more than 138 

civil investigative demands (investigative subpoenas) in 65 investigations, 

on behalf of 18 foreign agencies from ten countries This has led to reciprocal information sharing, evidence 

gathering, and case coordination in numerous cross-border matters that affect U S consumers – ranging from 

sweepstakes and lotteries frauds to privacy violations and data breach incidents to misleading health claims The 

Act also enables the FTC’s “International Fellows” program, which brings officials from foreign competition, 

consumer protection, and privacy agencies to work alongside FTC staff on investigations and cases The FTC has 

hosted 131 foreign colleagues from 41 jurisdictions under the staff exchange provision of the Act 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 21

STRATEGIC GOAL 2: MAINTAIN COMPETITION TO PROMOTE 

A MARKETPLACE FREE FROM ANTICOMPETITIVE MERGERS, 

BUSINESS PRACTICES, OR PUBLIC POLICY OUTCOMES

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 5

FY 2020 Results: In FY 2020, the agency took action to maintain competition in 27 of 35 full merger and 

nonmerger investigations concluded The FTC’s 27 actions included 11 consent orders, two litigated victories (Benco, 

Peabody/Arch Coal), one stipulated injunction (Indivior), one settlement with a party to an ongoing administrative 

adjudication (Safariland), three matters in which the parties abandoned their transactions after the Commission 

authorized staff to challenge the proposed acquisition in federal or administrative proceedings (Illumina/PacBio, 

Edgewell/Harry’s, Post/TreeHouse), and nine abandoned transactions This year’s results exceeded the target range for 

this performance goal, primarily because more matters than anticipated led to enforcement actions 

The agency’s 27 actions included 24 merger actions and three nonmerger actions in second request or compulsory 

process investigations in a broad array of industries such as healthcare, pharmaceuticals, consumer goods and services, 

energy, and manufacturing The agency concluded eight merger matters in which it did not take an enforcement 

action during FY 2020 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

Status

54.6% 49.1% 67.9% 62.9% 77.1% Between 

40%-70% 

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 

FTC HOSTS WORKSHOP ON NON-COMPETE AGREEMENTS IN THE WORKPLACE 

On January 9, 2020, the Federal Trade Commission held a public workshop to examine whether there is a 

sufficient legal basis and empirical economic support to promulgate a Commission rule that would restrict the 

use of non-compete clauses in employer-employee employment contracts 

This workshop, titled “Non-Competes in the Workplace: Examining 

Antitrust and Consumer Protection Issues,” included legal scholars, 

economists, and policy experts who considered whether the Commission 

had rulemaking authority under either unfair method of competition 

or unfair or deceptive act or practice principles and who reviewed the 

current state of the law and economic literature on non-compete clauses in 

contracts between employers and employees 
MANAGEMENT’S DISCUSSION AND ANALYSIS

22 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 2020 Results: In FY 2020, the FTC saved consumers, on average, approximately $25 70 for every dollar 

devoted to its merger program Merger actions in the healthcare, pharmaceuticals, consumer goods and services, and 

manufacturing resulted in considerable consumer savings in the period These results fell short of the target level for 

the period, due in large part to unusually large consumer savings from merger actions in FY 2015 that are no longer 

included in the five-year timeframe for the goal Targets have been adjusted for FY 2021 Significant increases in 

case-related spending during the period, primarily attributable to a growing antitrust litigation docket, also resulted 

in a reduction in the ratio of estimated consumer savings to program costs during the period 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

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

$42.00 in 

consumer 

savings per 

$1 spent

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 AND DOJ UPDATE VERTICAL MERGER GUIDELINES

In June 2020, the Federal Trade Commission and Department of Justice (DOJ) 

jointly issued new Vertical Merger Guidelines that outline how the agencies 

evaluate the likely competitive impact of vertical mergers and whether they 

comply with U S antitrust law These guidelines represent the first major revision 

to DOJ’s 1984 Non-Horizontal Merger Guidelines, and mark the first time 

the two agencies have jointly issued such guidance The guidelines will help the 

enforcement agencies identify and challenge harmful vertical mergers by detailing 

the techniques and main types of evidence used to predict whether vertical 

mergers may substantially lessen competition, and likewise will help businesses and 

antitrust practitioners through increased transparency into the agencies’ analytical 

framework for evaluating vertical transactions 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 23

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 2020 Results: In FY 2020, the FTC saved consumers, on average, approximately $46 per dollar devoted to its 

nonmerger enforcement program Nonmerger actions in the healthcare, pharmaceutical, and consumer services 

industries contributed to that total, and when coupled with modest reductions in program spending, allowed the 

agency to again meet the target for this performance goal 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

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

$40.00 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 

FTC SUES PHARMACEUTICAL COMPANY FOR MONOPOLIZATION

The Commission authorized staff to seek a permanent injunction and equitable monetary relief to halt an 

elaborate anticompetitive scheme to preserve a monopoly for a life-saving drug According to the complaint, 

the FTC alleges that after acquiring the rights to Daraprim, the gold standard treatment for toxoplasmosis, 

Vyera Pharmaceuticals immediately raised the price 4100% and engaged in a series of unlawful tactics, including 

distributional restraints and interference with FDA-mandated 

bioequivalence testing to prevent generic entry into the market 

The complaint further charges that Vyera signed data blocking 

agreements to deny generic pharmaceutical firms access to the data 

needed to assess whether development of an alternative treatment 

is worth pursuing Toxoplasmosis is a potentially fatal parasitic 

infection that is particularly threatening for individuals with 

compromised immune systems, such as HIV/AIDS and cancer 

patients or recipients of organ transplants This matter is currently 

pending in federal court 
MANAGEMENT’S DISCUSSION AND ANALYSIS

24 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

FTC CO-HOSTS INTERNATIONAL COMPETITION NETWORK ANNUAL CONFERENCE 

The FTC continues to be an 

engaged leader at the International 

Competition Network (ICN), 

one of the most important fora for 

promoting convergence toward sound 

international antitrust policies and practices In September, the FTC co-hosted (with the Department of Justice, 

Antitrust Division) the ICN Annual Conference, which is the largest gathering of competition agency leaders 

and members of the competition community from around the world The conference promoted international 

cooperation and convergence, highlighting the FTC’s (and broader U S competition community’s) expertise and 

thought leadership, including through the involvement of senior FTC antitrust officials, respected academics, 

and economists The FTC serves as an active member of the ICN Steering Group, originating new areas for 

ICN discussion, including a project on the intersection of competition, consumer protection, and privacy 

enforcement and policy The FTC also leads the ICN’s implementation efforts, developing and managing 

the network’s strategy and promotion of ICN work products Looking forward, the FTC will lead the ICN’s 

“2020Vision” project, a top-to-bottom review of the ICN to ensure the ICN’s continued effectiveness as the 

network enters its third decade 

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 2020 Results: In FY 2020, the FTC cooperated on 29 international enforcement matters FTC staff engaged 

in substantive case cooperation with 13 agencies, including those of Australia, Brazil, Canada, China, the European 

Union, Germany, Israel, Japan, Mexico, New Zealand, Singapore, South Africa, and the United Kingdom The FTC 

and its counterpart agencies reached compatible outcomes in all cases completed during the fiscal year While the 

FTC will continue to strive for 100 percent success, the target reflects the possibility of inconsistent outcomes, 

particularly as additional antitrust agencies assert their jurisdiction and as more agencies prosecute cases based on 

unilateral conduct theories 

FY 2016

Actual

FY 2017

Actual

FY 2018

Actual

FY 2019

Actual

FY 2020

Actual

FY 2020

Target

FY 2020 

Status

100% 96% 98% 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 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 25

GOAL 3: ADVANCE THE FTC’S PERFORMANCE THROUGH 

EXCELLENCE IN MANAGING RESOURCES, HUMAN CAPITAL, AND 

INFORMATION TECHNOLOGY

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 The index is 

compiled from questions across three sub-factors: Leaders Lead, Supervisors, and Intrinsic Work Experience 

• Leaders Lead: Employees’ perceptions of leadership’s integrity as well as leadership behaviors such as 

communication and workforce motivation 

• Supervisors: Interpersonal relationship between worker and supervisor, including trust, respect, and support 9

• Intrinsic Work Experience: Employees’ feelings of motivation and competency relating to their role in the 

workplace 9

FY 2020 Results: Due to the ongoing pandemic, the Office of Personnel Management postponed the launch of the 

FEVS Survey from May 2020 until September 2020 Results from the survey, normally available in October, are not 

expected to be released until December 2020 

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% Data Not 

Available

Government 

average +10 

points

To be 

determined

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 

FTC LAUNCHES E-FILING SYSTEM FOR HART-SCOTT-RODINO (HSR) MERGER FILINGS 

In response to the COVID-19 pandemic, in March 2020 the Federal Trade Commission suspended acceptance 

of hard copy and DVD HSR filings and seamlessly developed 

and launched a temporary electronic filing system and related 

operating procedures This system represents a first step in 

the eventual launch of a permanent, cloud-based electronic 

filing solution, which will reduce costs for both the FTC and 

Antitrust Division of the Department of Justice as well as 

filing parties and their counsel 
MANAGEMENT’S DISCUSSION AND ANALYSIS

26 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

AGENCY MISSION CHALLENGES

In today’s increasingly complex economy, the FTC 

stands as a champion for competition and consumers 

For example, when consumers and businesses encounter 

difficulties with financial scams, deceptive or fraudulent 

advertising, or unfair or deceptive practices related 

to privacy and data security, the FTC is prepared to 

respond with vigorous law enforcement Similarly, when 

consumers are harmed by anticompetitive business 

practices in key sectors of our economy like technology 

and health care, the FTC steps forward, bringing to bear 

its full complement of enforcement and policy tools 

Agency mission challenges are presented as they 

relate to the agency’s strategic goals: Strategic Goal 1 

(Protect Consumers) and Strategic Goal 2 (Maintain 

Competition) A reference to the most applicable 

strategic objectives is also provided, so readers may 

refer to descriptions of related performance targets and 

actual results 

Management’s assessment was performed independently 

from the process by which the Inspector General (IG) 

identified management and performance challenges (see 

Other Information Section) Management concurs with 

the IG-identified challenges and assessment of agency 

progress in addressing the challenges 

STRATEGIC GOAL 1: PROTECT CONSUMERS

Pursuant to the agency’s Protect Consumers goal, the 

FTC will continue to prioritize the following challenges: 

protecting Americans from fraud, including in the 

financial services marketplace; protecting consumers as 

technology evolves; protecting consumer privacy and 

improving data security, including combating identity 

theft; and addressing emerging advertising issues and 

targeting deceptive advertising 

PROTECTING AMERICANS FROM FRAUD:

Fraud can potentially affect all consumers and businesses 

The FTC will continue its enforcement efforts to stop 

fraud, focusing on those instances that cause or are likely 

to cause the greatest consumer harm The FTC continues 

to receive consumer complaints about imposter scams 

in which the perpetrators pose as government agencies, 

legitimate technical support companies, family members, 

or other trusted entities Certain scams, such as those 

involving business and income opportunities, pose an 

even greater risk to consumers from lower income or 

underserved communities 

The FTC will continue to work closely with other 

enforcement authorities and stakeholders to stop 

scammers and other unfair and deceptive business 

practices during the COVID-19 pandemic The FTC 

will continue to send warning letters to companies and 

individuals to ensure they are not engaging in unfair or 

deceptive practices relating to the crisis, and the FTC 

will also continue to bring enforcement actions against 

companies that make false claims related to COVID-19 

The FTC will maintain a focus on frauds targeting 

specific populations, including military consumers, 

seniors, non-English-speaking consumers, communities 

of color, and small businesses Con artists continue to 

target the most vulnerable consumers and consumers 

in financial distress This unlawful conduct can have 

severe consequences for consumers who can least afford 

it Therefore, the FTC will continue to pursue law 

FTC WINS LARGEST LAND FRAUD CASE AGAINST SANCTUARY BELIZE

The FTC won a $120 2 million judgment against the primary Sanctuary Belize defendants, successfully putting 

an end to the largest land fraud case in FTC history The defendants, including Andris Pukke (the primary 

defendant in the FTC’s Ameridebt case), sold lots in a purported luxury development in remote southern Belize 

to U S retirees In truth, the development was little more than 

a jungle with few, if any, amenities After a four-week trial, the 

court held all of the trial defendants liable on all counts; found 

judgment in the amount of $120 2 million; found Pukke and 

his business partner in contempt for violations of the Ameridebt 

order; and stated that Pukke will receive a complete real estate 

ban and a telemarketing ban, while the other defendants will 

receive telemarketing bans and partial real estate bans 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 27

enforcement actions to stop deceptive or other unlawful 

conduct in mortgage, student loan, and other debt relief 

services; payday lending; debt collection; and financing 

transactions The FTC will also prioritize education for 

these populations 

The FTC will continue to coordinate closely with other 

federal agency partners to ensure that consumers are 

protected in the financial marketplace, and to avoid 

duplicative efforts between agencies Through the FTC’s 

Business Center at business.ftc.gov and other outreach 

efforts, the FTC will continue to offer educational 

materials to help consumers and businesses—especially 

small businesses—understand and comply with 

consumer protection laws and avoid becoming victims of 

fraud (Objectives 1 1, 1 2, and 1 3)

PROTECTING CONSUMERS AS TECHNOLOGY 

EVOLVES:

Technology provides many benefits to consumers, 

including choice, convenience, and increased access 

to goods, services, and information However, it also 

enables new vehicles for fraudulent, deceptive, and unfair 

practices in the marketplace The FTC will continue 

its focus on the consumer protection issues associated 

with the use of emerging technology, including a 

careful consideration of the costs and benefits of new 

business practices and the importance of fostering 

innovation The FTC will take enforcement actions 

against deceptive practices that appear in new formats 

and new media (e g , apps, games, streaming videos, and 

social networks) The FTC held a public workshop to 

examine voice cloning technologies, which enable users 

to make near-perfect reproductions of a real person’s 

voice “You Don’t Say: An FTC Workshop on Voice 

Cloning Technologies” examined both the benefits and 

potential misuses of voice cloning technologies For 

example, voice cloning could be used to help people 

who have lost the ability to speak to communicate using 

technology that simulates a cloned version of their 

own voice These same technologies, however, could be 

misused by scammers to impersonate others In addition, 

the FTC will continue to monitor consumer complaints 

about Internet Service Providers (ISPs) and will take 

appropriate action against deceptive ISP advertising or 

other unfair or deceptive ISP practices The FTC will 

continue to conduct research on emerging technologies 

to assist with enforcement actions, inform policy, and 

educate consumers 

Consumers and law enforcers face challenges resulting 

from technological advances that facilitate the use 

of illegal robocalls and make it easier for fraudsters 

perpetrating telemarketing scams to hide their 

location The FTC will continue its law enforcement 

efforts, and will continue to work with consumer 

groups, telecommunications industry representatives, 

technologists, policymakers, and other stakeholders 

to develop solutions to halt illegal robocalls and other 

telemarketing practices that violate the Telemarketing 

Sales Rule The FTC and Federal Communication 

Commission will continue their coordinated efforts to 

combat illegal robocalls and promote innovative solutions 

to protect consumers (Objectives 1 1, 1 2, and 1 3)

PROTECTING CONSUMER PRIVACY AND 

IMPROVING DATA SECURITY:

The FTC will continue to take a leading role in efforts 

to protect consumers from unfair or deceptive practices 

related to the security and privacy of their personal 

FTC STOPS ADVOCARE PYRAMID SCHEME 

Multi-level marketer AdvoCare International and its former 

CEO, Brian Connolly, agreed to pay $150 million and be banned 

from the multi-level marketing business to resolve FTC charges 

that the company operated an illegal pyramid scheme that 

deceived consumers into believing they could earn significant 

income as “distributors” of its health and wellness products 

Two top promoters, Carlton and Lisa Hardman, also settled 

charges that they promoted the illegal pyramid scheme and 

misled consumers about their income potential, agreeing to a 

multi-level marketing ban and a judgment of $4 million that will 

be suspended when they surrender substantial assets The FTC 

complaint also charged two other top AdvoCare promoters 
MANAGEMENT’S DISCUSSION AND ANALYSIS

28 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

information, while preserving the many benefits that 

technological advances offer The agency will stop unfair 

and deceptive consumer privacy and data security 

practices through law enforcement and will promote 

strong and balanced privacy and security protections 

through policy initiatives on a range of topics The FTC 

hosted its fifth annual PrivacyCon event to highlight 

the latest research trends in consumer privacy and data 

security The event focused on the privacy of health 

data collected, stored, and transmitted by mobile 

applications (“apps”) 

The agency will bring appropriate enforcement actions 

against entities that violate the Children’s Online 

Privacy Protection Act (COPPA) Rule The FTC held 

a workshop examining the COPPA Rule in light of 

evolving business practices and new technology in the 

marketplace The agency will continue to participate 

in interagency groups, promote self-regulatory efforts, 

provide technical assistance to Congress on draft 

legislation, and participate in international privacy 

initiatives In addition, the agency will continue to 

support the development of the digital economy through 

cross-border data flows and the Asia-Pacific Economic 

Cooperation/Cross Border Privacy Rules 

Identity theft exacts a heavy financial and emotional 

toll from its victims The FTC will continue to assist 

the millions of Americans victimized each year 

through data security breaches and other means The 

FTC will continue to be the repository for identity 

theft complaints and make them available to federal 

criminal law enforcement agencies The agency’s trained 

counselors will continue to advise identity theft victims 

who call our toll-free number about rights and remedies 

available to them under federal law The FTC’s website, 

IdentityTheft gov, is the federal government’s onestop resource to help consumers report and recover 

from identity theft IdentityTheft gov highlights useful 

resources and connects identity theft victims to federal 

agencies and other organizations that are critical to 

the recovery process IdentityTheft gov allows visitors 

to create a customized plan based on their specific 

experiences The Internal Revenue Service (IRS) 

continues to allow consumers to report identity theft to 

the IRS electronically through the FTC’s IdentityTheft 

gov website Starting in October 2019, many members 

of the military received access to free electronic credit 

monitoring, which can help them spot identity theft The 

agency also will continue to train local law enforcement 

to spot and prosecute identity theft, and will update 

educational materials (Objectives 1 1, 1 2, and 1 3)

In addition, the Bureau of Consumer Protection’s Office 

of Technology Research and Investigation is monitoring 

and conducting research on emerging technologies 

That research assists with the Commission’s consumer 

protection efforts on enforcement, consumer education, 

and policymaking 

ADDRESSING EMERGING ADVERTISING ISSUES 

AND TARGETING DECEPTIVE ADVERTISING:

Digital media has opened new avenues for companies 

to communicate with consumers, and the format of 

advertisements continues to evolve Like all advertising, 

digital marketing must comply with the law, including 

deceptive advertising that appears in new formats (e g , 

apps, games, videos, and social networks) The FTC will 

take enforcement action against deceptive advertisements 

that appear in new formats and new media (e g , apps, 

FTC BRINGS FIRST CASE AGAINST DEVELOPERS OF “STALKING” APPS 

The FTC barred Retina-X Studios, the developers of three “stalking” apps, from selling apps that monitor 

consumers’ mobile devices unless they take certain steps to ensure the apps will only be used for legitimate 

purposes This is the first case the FTC has brought against a “stalking” 

app The FTC alleged that Retina-X and its owner, James N Johns, Jr , 

developed three mobile device apps that allowed purchasers to monitor 

the mobile devices on which they were installed, without the knowledge 

or permission of the device’s user Retina-X sold more than 15,000 

subscriptions to all three stalking apps before the company stopped 

selling them in 2018 The settlement resolves allegations that these apps 

compromised the privacy and security of the consumer devices on which 

they were installed 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 29

games, videos, and social networks) The FTC also will 

evaluate the use of online reviews of products or services, 

including the use of fabricated reviews, undisclosed 

material connections with reviewers, prohibitions on 

negative reviews, or unsubstantiated testimonials, and 

take action as appropriate Companies are increasingly 

blending advertising with news, entertainment, or 

editorial content in digital media If consumers do not 

recognize and understand the difference between the 

advertising and other content, they may be deceived 

The FTC, therefore, will continue to examine consumer 

protection issues raised by sponsored content, “native” 

advertising that looks like surrounding non-commercial 

content, and endorsements 

The FTC released a new publication for online 

influencers that explains when and how influencers 

must disclose sponsorships to their followers The new 

guide, “Disclosures 101 for Social Media Influencers,” 

provides influencers with tips from FTC staff about 

what triggers the need for a disclosure and offers 

examples of both effective and ineffective disclosures 

The FTC will continue to address deceptive advertising 

of health products, such as homeopathic products and 

dietary supplements The agency will focus on disease 

prevention and treatment claims; claims related to 

COVID-19; claims aimed at baby boomers, seniors, 

and military members; and claims exploiting emerging 

health threats The FTC also will continue to focus its 

law enforcement efforts on misleading environmental 

marketing claims and will educate businesses about the 

FTC’s Guides for the Use of Environmental Marketing 

Claims (“Green Guides”) Additionally, the FTC 

will continue to focus its law enforcement efforts on 

companies that falsely claim their products were made in 

the United States and will educate businesses about how 

to comply with the Made in USA standard (Objectives 

1 1, 1 2, and 1 3)

STRATEGIC GOAL 2: MAINTAIN 

COMPETITION

Pursuant to the agency’s Maintain Competition 

goal, the FTC will continue to prioritize promoting 

competition and preventing anticompetitive conduct in 

many areas of the economy, including the health care 

and pharmaceutical sectors, technology, retail markets, 

and the energy industry The agency will also work to 

promote sound competition policy at the international 

level and will continue advocating for procompetitive 

outcomes before federal courts, state legislatures, and 

other governmental agencies 

In enforcing the antitrust laws, the FTC analyzes 

mergers and acquisitions filed under the Hart-ScottRodino (HSR) premerger notification program, 

and monitors the marketplace for non-reportable 

transactions that might raise competitive concerns The 

FTC takes action against those mergers that are likely 

to reduce or eliminate competition, and that are unlikely 

to generate sufficient benefits to consumers to outweigh 

the competitive harm The FTC is vigilant in identifying 

instances of unlawful monopolization or attempted 

monopolization, or instances in which two or more firms 

seek to coordinate in an attempt to stifle competition 

in order to raise prices, reduce the quality or choice of 

goods and services, or reduce innovation 

REINVIGORATED EMPHASIS ON TECHNOLOGY: 

The ubiquity of technology, and the fast pace at which 

it evolves, are crucial marketplace challenges FTC 

antitrust investigations involve increasingly complicated 

FTC RULE PROVIDES FOR FREE CREDIT MONITORING FOR MILITARY SERVICE MEMBERS 

Starting in October 2019, many members of the military received 

access to free electronic credit monitoring, which can help them 

spot identity theft In response to a new FTC Rule implementing 

a 2018 law, the nationwide credit reporting agencies—Equifax, 

Experian, and TransUnion—are providing free electronic credit 

monitoring services to active duty service members and National 

Guard members Credit monitoring services can alert consumers to 

mistakes or problems with their credit reports that might stem from 

the unauthorized use of their personal information to obtain credit 
MANAGEMENT’S DISCUSSION AND ANALYSIS

30 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

high-technology markets, such as online platforms, 

computer hardware and software, electronic components, 

and devices used in manufacturing To address these 

ongoing challenges, the Commission established the 

Technology Enforcement Division in 2019 to bolster 

and focus the agency’s efforts to maintain competition 

given the unique antitrust issues raised by these dynamic 

markets 

Antitrust and competition policy matters in the 

technology marketplace were a primary focus of the 

Commission’s 21st Century Hearings initiative, and are 

likewise the focus of a 6(b) study, announced in FY 2020 

aimed at helping the Commission better understand 

large technology firms’ acquisition activities, particularly 

of nascent or potential competitors, and how the firms 

FTC MOVES TO BLOCK ANTICOMPETITIVE MERGERS 

Coal Mining: In February 2020, the FTC challenged a 

proposed joint venture between Peabody Energy Corporation 

and Arch Coal, the two largest coal-mining companies in the 

United States According to the complaint, the joint venture 

would have eliminated head-to-head competition between 

the companies for thermal coal in the Southern Powder River 

Basin This product is a key input for power-generating utilities 

that provide electricity to millions of Americans Following 

a two-week trial, the federal district court granted the FTC’s 

request for a preliminary injunction, and the parties abandoned the joint venture shortly thereafter 

Philadelphia Area Hospitals: In February 2020, the FTC challenged a proposed merger between Jefferson 

Health and Albert Einstein Healthcare Network, two leading providers of inpatient general acute care hospital 

and rehabilitation services in the Philadelphia area According to the complaint, the merger would have 

eliminated the head-to-head competition that drives improvements in quality and service, upgraded facilities, 

and investment in technology and innovation for hospitals in and around Philadelphia, resulting in the parties 

controlling around 50 percent of the general acute care services in each of the alleged geographic markets This 

matter is currently pending in federal court 

DNA Sequencing Platforms: In December 2019, the FTC challenged Illumina’s proposed acquisition of Pacific 

Biosciences of California (PacBio) In its complaint, the FTC alleged that Illumina was seeking to unlawfully 

maintain its monopoly in DNA sequencing platforms by extinguishing PacBio as a nascent competitive threat 

PacBio had recently made significant technological advancements in its product, increasing its accuracy and 

lowering its cost, that made it a closer alternative to Illumina than ever before The parties abandoned the 

acquisition after the FTC filed its complaint 

Police Body Cameras: In January 2020, the FTC challenged Axon Enterprise’s consummated acquisition of its 

body-worn camera systems competitor VieVu Before the acquisition, the two companies competed to provide 

body-worn camera systems to large, metropolitan police departments across the United States According 

to the complaint, Axon’s May 2018 acquisition reduced competition in an already concentrated market The 

Commission has entered a consent agreement with VieVu’s parent company, Safariland, while the action against 

Axon is currently pending 

Shaving Razors: In February 2020, the Commission moved to stop the proposed acquisition of Harry’s by 

Edgewell Personal Care, the maker of Schick brand razors According to the complaint, the deal would have 

eliminated a disruptive and innovative rival that has driven down prices and spurred innovation in the otherwise 

duopolistic U S market for men’s and women’s wet shave razors Harry’s launched as an internet-only, direct-toconsumer wet shave brand, and in 2016, entered into brick-and-mortar retail stores The parties abandoned the 

acquisition in the face of the FTC’s challenge 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 31

report those activities to the FTC and DOJ Antitrust 

Division The Commission will continue to use what 

it learns from these initiatives to inform policy and 

enforcement priorities in the technology space in the 

future (Objectives 2 1 and 2 2)

PROMOTING COMPETITION IN HEALTH CARE 

AND PHARMACEUTICAL MARKETS:

The high cost of health care, which continues to account 

for a significant share of the gross domestic product, is 

a matter of ongoing concern for consumers, businesses, 

and taxpayers To ensure that consumers receive the 

benefits of competitive health care markets, antitrust 

enforcement and advocacy in this sector are top priorities 

for the Commission 

The FTC will continue to focus resources on challenging 

pharmaceutical monopolization schemes, including 

anticompetitive reverse payment patent settlement 

agreements Branded and generic drug manufacturers 

use these agreements to delay generic competition As 

the U S Supreme Court explained in FTC v. Actavis, 

“there is reason for concern that settlements taking 

this form tend to have significant adverse effects on 

competition ” Similarly, the Commission will continue 

to investigate other anticompetitive conduct, such as 

sham litigation, the abuse of government regulatory 

processes, or unnecessary restricted distribution schemes 

to delay generic entry into pharmaceutical markets Such 

practices deny consumers access to lower priced generic 

drugs The FTC reviews, investigates, and challenges 

these harmful practices where appropriate The FTC 

will monitor developments related to pharmaceuticals to 

treat COVID-19 to identify any conduct that potentially 

harms competition 

The FTC also prioritizes stopping anticompetitive 

health care mergers that could lead to higher costs 

or reduced quality, including those involving health 

care providers and pharmaceutical and medical device 

companies This also includes examining mergers for 

anticompetitive effects in labor markets, which could 

harm workers in the form of reduced wages, benefits, 

and working conditions In recent years, the FTC 

has required significant divestitures in a large number 

of pharmaceutical transactions and has successfully 

challenged in court several anticompetitive mergers 

between hospitals or other health care providers 

Beyond enforcement, the FTC utilizes its full range 

of policy and advocacy tools to promote competition 

in health care markets For example, the FTC has 

advocated against state legislation that attempts to 

immunize competing hospitals and other health care 

providers from federal antitrust laws when they merge 

or engage in certain forms of collaboration The FTC is 

also studying whether mergers consummated in states 

where this type of legislation was enacted to determine 

whether they have resulted in competitive harm In the 

FTC’s view, state efforts to immunize such conduct are 

unnecessary because procompetitive collaboration that 

would benefit consumers is permitted by federal antitrust 

law Therefore, these statutes effectively immunize 

conduct that likely would restrain competition and result 

in higher health care prices for consumers, without 

generating offsetting benefits 

The FTC also engages in research and scholarship 

and convenes hearings, workshops, and conferences, 

to better understand and keep apprised of health care 

and pharmaceutical market dynamics (Objectives 2 1 

and 2 2)

FTC CHALLENGES CONSENT ORDER VIOLATIONS

In July 2020, the agency brought a civil penalty action against Alimentation Couche-Tard (ACT) and a former 

affiliate, CrossAmerica Partners LP (CAPL) The companies agreed to pay $3 5 million in civil penalties to settle 

charges that they violated a 2018 consent order requiring the divestiture of 

10 retail fuel stations in Minnesota and Wisconsin prior to consummating 

their acquisition of 380 such stations in 10 states from Holiday Companies 

According to the complaint, ACT and CAPL failed to divest stations in 9 of 

the 10 markets subject to the order, failed to maintain the viability of assets 

to be divested in the Hibbing, Minnesota market, and filed inaccurate and 

incomplete compliance reports 
MANAGEMENT’S DISCUSSION AND ANALYSIS

32 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

PREVENTING ANTICOMPETITIVE ACTIVITY IN 

THE ENERGY INDUSTRY: 

The agency continues to monitor closely energy markets 

to identify and challenge anticompetitive mergers and 

conduct In recent years, the Commission has brought 

several merger and conduct enforcement actions in 

the energy sector, resulting in multiple divestitures 

and other relief to maintain competition The FTC 

also continuously examines price movements and 

other activity through its Gasoline and Diesel Price 

Monitoring Project, a tool that can help identify 

anticompetitive conduct such as illegal agreements 

among competitors, agreements between manufacturers 

and product dealers, and monopolization that may 

undermine the benefits of competition 

The FTC regularly issues reports on the factors that 

influence the prices American consumers pay for gas 

In compliance with the Energy Policy Act of 2005, the 

FTC issued its fourteenth annual Ethanol Market report 

in 2018, which concluded that the market is 

less concentrated than it was fourteen years ago 

(Objectives 2 1 and 2 2)

FTC BEGINS TWO 6(B) STUDIES, REQUIRES DOCUMENT PRODUCTION FROM COMPANIES 

In FY 2020, the FTC commenced three “6(b)” studies Section 6(b) of the 

FTC Act gives the FTC authority to obtain documents and information 

from companies as part of its research work 

For the first study, the Commission issued orders to six e-cigarette 

manufacturers seeking information to study the companies’ sales, 

advertising, and promotional methods from 2015-2018 The FTC study 

will complement similar FTC studies on cigarettes and smokeless tobacco 

products, and will assist the Commission, policy makers, and the public to 

better understand the rapidly growing e-cigarette market 

The second study follows the June 2019 public workshop on certificates of public advantage (COPAs) The FTC 

issued orders to study the effects of COPAs on prices, quality, access, and innovation of healthcare services 

The COPA study sent five health insurance companies and two health systems orders seeking information on 

aggregated patient billing and discharge data, health system employee wage data, and other information relevant 

for analyzing the health systems’ prices, quality, and innovation This study will collect information over the next 

several years to help FTC staff conduct retrospective analyses 

For the third study, the Commission issued 6(b) orders against large technology firms’ acquisition activities The 

Commission ordered Alphabet/Google, Amazon com, Apple, Facebook, and Microsoft to provide information 

and documents on the terms, scope, structure, and purpose of transactions that each company consummated 

between Jan 1, 2010 and Dec 31, 2019 The technology company orders will help the FTC deepen its 

understanding of large technology firms’ acquisition activity, including how these firms report their transactions 

and whether large tech companies are making potentially anticompetitive acquisitions of nascent or potential 

competitors that fall below HSR filing thresholds 

MAINTAINING ROBUST COMPETITION IN RETAIL 

AND CONSUMER GOODS MARKETS:

Retail and consumer goods markets directly impact the 

wallet of every American consumer The FTC focuses 

significant resources on identifying and challenging 

mergers and conduct likely to harm competition in these 

critical markets These actions preserve competition, 

which benefits consumers by keeping prices down, 

improving quality and service, and expanding innovation 

and consumer choice In recent years, the Commission 

has successfully challenged several retail and consumer 

goods and services mergers, including proposed retail 

pharmacy, food product, and entertainment market 

transactions, as well as several supermarket acquisitions 

As in other sectors, the FTC also continues to study 

evolving competitive dynamics that affect how 

consumers shop for products they want to buy The 

retail sector, perhaps more than most, has been reshaped 

through advances in technology, including behavioral 

advertising, predictive analytics, and big data—three 

transformative innovations discussed in recent 

Commission hearings (Objectives 2 1 and 2 2)
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 33

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 to 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 2020 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, FTC’s 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 FTC’s technology modernization initiative Risks 

related to maintaining operations during the COVID-19 

pandemic and the potential disrupting of the agency’s 

mission have also been noted 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 2020 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 DATA Act control 

assessments and OMB-directed Internal Control 

Over Reporting (ICOR) 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 Chairman 

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 Chairman’s assurance statement that follows is 

supported by the processes and reviews described above, 

which were performed in FY 2020 Management 

assurance tables appear in the Other Information 

section 
MANAGEMENT’S DISCUSSION AND ANALYSIS

34 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

CHAIRMAN’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, 2020, 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

Joseph Simons 

Chairman

October 31, 2020
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 35

SUMMARY OF MATERIAL WEAKNESS AND 

NONCONFORMANCES

As noted in the Chairman’s FMFIA Statement of 

Assurance, the FTC has no material weaknesses or 

nonconformances to report for FY 2020 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 

2020, the FTC executed the retirement of one system, 

the conversion of one system to Authorization to Use 

(ATU), and the performance of one assessment and 

authorization effort The FTC currently has seven 

systems authorized to operate (ATO) The FTC 

leverages seventeen Federal Risk and Authorization 

Management Program (FedRAMP) 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 2020, the 

FTC processed 3,306 invoices totaling $90 3 million 

that were subject to prompt payment Of these invoices, 

97 2 percent were paid on time During FY 2020, the 

FTC paid a total of $2,203 92 in interest penalties, or 

0 0024 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 FTC relied on the Department 

of the Interior’s Interior Business Center (IBC) for 

servicing the agency’s financial management system’s 

needs As part of the agency’s efforts to continue to 

refine and improve its operations and to ensure it 

employs the most effective mix of services that will 

provide the most value to taxpayers, the FTC changed its 

financial services provider and entered into an agreement 

with the Department of the Treasury’s Administrative 

Resource Center (ARC) for the FTC’s core financial 

management systems needs beginning in FY 2020 

The IBC continues to provide only personnel and 

payroll support services for the FTC, which it has been 

providing for the agency since 1998 

The FTC has gained several efficiencies in its financial 

management operations in the first fiscal year with the 

new service provider Under ARC, the FTC continues 

to use Oracle Federal Financials (OFF) release 12 2 as 

its core financial management system but shifted to the 

Oracle Business Intelligence (OBI) 12c (release 12 1 1 4) 

reporting platform, gaining additional functionalities to 

perform visual analytics and create interactive dashboards 
MANAGEMENT’S DISCUSSION AND ANALYSIS

36 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

and alerts that aid in more informed management 

decisions ARC’s implementation of OFF fully 

integrates with the Invoice Processing Platform, allowing 

the FTC to fully utilize this secure and centralized 

program to automate invoice collection, validation, and 

approval workflows The agency also changed its travel 

management system to Concur Government Edition 

and its contract writing system to the Procurement 

Information System for Management, which is more 

widely used by Federal Government agencies and has 

many more contract writing functions than the Contract 

Lifecycle Management system the FTC used prior to 

FY 2020 These systems are also highly integrated with 

both OFF and OBI, allowing the FTC to perform 

more targeted analytics to assess the effectiveness and 

efficiency of its financial management operations that 

ultimately contribute to its mission success 

The agency 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 operations and reporting In 

addition, the agency will work with the Department 

of the Treasury to implement G-invoicing, the longterm sustainable solutions 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 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 2020, 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 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 37

FINANCIAL HIGHLIGHTS

INTRODUCTION

The FTC’s accounting practices continue to be accurate 

and transparent, directly supporting the agency’s dual 

mission to protect consumers and promote competition, 

and consistently demonstrating the FTC’s commitment 

to responsible stewardship of resources and sound 

financial operations For the 24th 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 

non-entity 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, 2020 AND 2019

(Dollars in Millions) FY 2020 FY 2019 % Change

Entity Assets

Fund balance with Treasury $ 114 $ 122 -7%

General property, plant, and equipment 25 30 -17%

Total Entity Assets 139 152 -9%

Non-Entity Assets

Fund balance with Treasury 677 266 155%

Accounts receivable 628 616 2%

Total Non-Entity Assets 1,305 882 48%

Total Assets $ 1,444 $ 1,034 40%

Entity Liabilities

Employee related liabilities 30 24 25%

Accounts payable and other 12 14 -14%

Total Entity Liabilities 42 38 11%

Non-Entity Liabilities

Redress collections not yet disbursed 677 266 155%

Liability for amounts to be collected 628 616 2%

Total Non-Entity Liabilities 1,305 882 48%

Total Liabilities $ 1,347 $ 920 46%

Cumulative results of operations 97 114 -15%

Total Net Position 97 114 -15%

Total Liabilities and Net Position $ 1,444 $ 1,034 40%
MANAGEMENT’S DISCUSSION AND ANALYSIS

38 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

BALANCE SHEET – ENTITY

Entity assets totaled $139 million, or 10 percent of all 

FTC assets, as of September 30, 2020, a decrease of $13 

million, or 9 percent, from the FY 2019 total of $152 

million 

The Fund Balance with Treasury (FBwT) of $114 

million comprises $35 million that is temporarily 

unavailable for expenditure and $79 million available 

to the FTC to make expenditures and pay liabilities, 

for a total decrease of $8 million, or 7 percent, from the 

FY 2019 total of $122 million At the end of FY 2020, 

the FTC’s FBwT contained $32 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 $32 million, 

$6 million was temporarily reduced by the FY 2013 

sequestration 

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

$25 million, which consists of $22 million in leasehold 

improvements, $1 4 million in equipment, and $1 1 

million in software Of the total PP&E, $22 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 $5 million compared 

to FY2019 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 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 has declined over the past two years 

as the FTC has incurred higher costs associated with 

expert witness contracts in addition to rising salaries and 

benefits costs 

Millions

$180

$160

$140

$120

$100

$80

$60

$40

$20

$0

FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

ENTITY ASSETS

FBwT PP&E

19 18 22

64 63 57

51

108

136

159

133 138 133 133

30 25

122

114

39

129
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 39

Entity liabilities totaled $42 million, or 3 percent of all 

FTC liabilities, as of September 30, 2020, and represent 

an 11 percent increase in liabilities from FY 2019 to 

FY 2020 

Employee-related liabilities of $30 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 $12 

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 This was evident in FY 2011, when 

purchases of information technology hardware and 

software were accrued near the end of the fiscal year 

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 2020 

year-end payroll accrual included 13 days of unpaid 

wages, which is 2 more days than the FY 2019 year-end 

payroll accrual of 11 days of unpaid wages The uptick 

in employee-related liabilities in FY 2020 is attributable 

to the additional payroll accrual The $2 million decrease 

in Accounts payable and other liabilities is primarily 

due to a probable contingent liability of $843 thousand 

recorded at the end of FY 2019 that was paid during 

FY 2020 

BALANCE SHEET - NON-ENTITY

Non-entity assets totaled $1,305 million, or 90 percent 

of all FTC assets, as of September 30, 2020 This 

represents an increase of $423 million, or 48 percent, 

from the FY 2019 total of $882 million 

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

liabilities The $628 million net accounts receivable 

balance is offset by the $628 million liability for amounts 

to be collected, while the $677 million FBwT is offset by 

the $677 million liability for redress collections 

The FY 2020 ending net accounts receivable balance of 

$628 million reflects amounts to be paid to the FTC 

from court-ordered judgments in the consumer redress 

program This represents a $12 million increase in net 

accounts receivable from the FY 2019 total of $616 

million The majority of the receivables balance for both 

fiscal years consists of a 2018 judgment against AbbVie, 

Inc for $494 million (79 percent of the ending FY 2020 

balance) A federal district court ruled that AbbVie used 

sham litigation to illegally maintain its monopoly over 

the testosterone replacement drug Androgel, and ordered 

$494 million in monetary relief to consumers who 

were overcharged for Androgel as a result of AbbVie’s 

conduct This court order represents the largest monetary 

award ever in a litigated FTC antitrust case Although 

the award was reversed on September 30, 2020, by the 

United States Court of Appeals for the Third Circuit, 

$40

$30

$20

$10

$0

Employee-related liabilities

ENTITY LIABILITIES

Accounts payable and other liabilities

FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

Millions

14

11

9 10

12 12 13 13

11

24

19

18 18

17

20

21 21 22

16

30
MANAGEMENT’S DISCUSSION AND ANALYSIS

40 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

the FTC is retaining the receivable because the reversal 

is not yet final and remains with the Court of Appeals 

Additionally, the bond securing the judgment remains 

outstanding 

The remaining ending net accounts receivable balance of 

$134 million primarily consists of amounts to be paid to 

the FTC from the following cases: AMG Services, Inc ,

for a payday lending scheme that deceived consumers; 

Jeremy Lee Marcus, et al (Helping America Group)

for allegedly selling phony debt relief and credit repair 

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

deceptive “trial” memberships for bogus governmentgrant and money-making schemes; Liberty Publishers 

Service, Inc for a deceptive newspaper subscription 

scheme; Stark Law, LLC d/b/a Stark Recovery for 

deceptive and abusive collections practices; MOBE 

(“My Online Business Education”) for administering 

fraudulent business education programs; Online Trading 

Academy (OTA) for administering deceptive investment 

training programs; and Belizean Bank for charges that 

it assisted various related entities (the Sanctuary Belize 

Enterprise, or SBE) in deceiving U S consumers as part 

of a deceptive scheme to sell property Thirty additional 

matters account for the remainder of the balance 

The FY 2020 ending FBwT for consumer redress of 

$677 million is being held temporarily by the FTC until 

it is distributed to consumers, other harmed parties, 

or redress third party administrators (for distribution 

to consumers on behalf of the FTC), or disgorged 

to Treasury (if consumer redress is not practicable) 

The increase of $412 million in FBwT consists of 

$549 million in collections offset by $137 million in 

disbursements Significant collections during FY 2020 

include $175 million from Progressive Leasing to settle 

charges it misled consumers about the true price of its 

leasing plans; $150 million from AdvoCare International 

L P to settle charges it operated an illegal pyramid 

scheme; $50 million from The University of Phoenix, 

Inc to resolve allegations of deceptive advertising; and 

$40 million from First Data Merchant Services, LLC

to settle charges that it knowingly processed credit card 

transactions for scams targeting hundreds of thousands 

of consumers 

Also during FY 2020, the FTC made a number of 

redress disbursements to consumers Among these, 

the FTC disbursed $35 million to harmed parties 

from a 2019 settlement with Office Depot, Inc , and a 

software provider for allegedly tricking customers into 

buying millions of dollars’ worth of computer repair and 

technical services; $16 million from a 2018 settlement 

with Jeremy Lee Marcus, et al (Helping America 

Group) to consumers who lost money to a debt relief 

scam; $12 million to harmed parties from the judgement 

against I Works, Inc , et al for deceptive “trial” 

memberships for bogus government-grant and moneymaking schemes; and $9 million from a 2018 settlement 

with AWS, LLC, et al (FBA Stores) to consumers who 

lost money to a business coaching services scam These 

disbursements account for more than 50 percent of the 

$137 million disbursements made in FY 2020 to harmed 

consumers 

FBwT and other collected amounts,

Offset by an equal liability for 

Redress collections not yet disbursed

Accounts receivable, and

Equal liability offset for amounts 

to be collected

FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

$900

$800

$700

$600

$500

$400

$300

$200

$100

$0

NON-ENTITY ASSETS & LIABILITIES

Millions

84 85 66

135

751

796

432

359

266

677

616

11 31 25

65 43

99

70

599

628
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 41

Historic trends of FBwT for consumer redress are 

primarily driven by a few select 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 

.

OCT-19 DEC-19 MAR-20 JUN-20 SEP-20

$800

$700

$600

$500

$400

$300

$200

Millions

NON-ENTITY ASSETS - FUND BALANCE WITH TREASURY

FY 2020 ACTIVITY

A

B

C

D

E H

K

L N O

P S

Q R T

I J

M

F G
MANAGEMENT’S DISCUSSION AND ANALYSIS

42 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

FY 2020 Non-Entity Fund Balance with Treasury Timeline Activity

$265.4M Beginning Balance - FY 2020 Non-Entity Fund Balance with Treasury

A $150.0M AdvoCare 

International, L.P.

Collected $150M from a 2020 settlement against Advocare International, 

L.P., for deceiving consumers into believing they could earn significant 

income as “distributors” of its health and wellness products.

B $30.0M Career Education 

Corporation

Collected $30M from a 2019 settlement against Career Education Corp. for 

using deceptive lead generators to market its schools.

C $13.7M I Works, Inc., et al.

Collected $13.7M from a settlement stemming from 2010 charges against I 

Works, Inc. et al., which operated deceptive “trial” memberships and bogus 

government-grant and money-making schemes.

D $16.4M

Jeremy Lee Marcus, 

et al. (Helping 

America Group)

Collected $16.4M from a 2018 settlement against a group of defendants 

known as Helping America Group that sold phony debt relief services.

E $7.2M AWS, LLC, et al. 

(FBA Stores)

Collected $7.2M from a 2018 settlement against FBA Stores and related 

companies who falsely claimed their “Amazing Wealth System” would enable 

people to create a profitable online business selling products on Amazon.

F $50.0M The University of 

Phoenix, Inc.

Collected $50M from a 2020 settlement of allegations the University 

of Phoenix, Inc. used deceptive advertisements that falsely touted their 

relationships and job opportunities with companies such as AT&T, Yahoo!, 

Microsoft, Twitter, and The American Red Cross. Under the settlement The 

University of Phoenix, Inc. will pay $50 million in cash as well as cancel $141 

million in debts owed to the school by students who were harmed by the 

deceptive ads.

G

($34.3M) Office Depot, Inc.

Disbursed $34.3M (541,247 refund checks) to individuals who allegedly were 

tricked by Office Depot, Inc. and a software provider into buying computer 

repair products and services. Refunds are a result of a 2019 settlement.

H ($6.9M) Telestar Consulting, 

Inc.

Disbursed $6.9M (13,181 refund checks) to small businesses, non-profits, and 

government agencies targeted by an office supply telemarketing scam that 

charged them for products they did not order. Refunds are a result of a 2017 

settlement.

I $4.0M Neurometrix, Inc.

Collected $4M from a 2020 settlement of allegations Neurometrix Inc. made 

deceptive claims that the electrical nerve stimulation devise called Quell 

treated pain throughout the body when placed below the knee. 

J $7.0M Fashion Nova, Inc.

Collected $7M from a 2020 settlement of FTC charges that Fashion Nova did 

not properly notify consumers and give them a chance to cancel their orders 

when it failed to ship merchandise in a timely manner, and it illegally used 

gift cards to compensate consumers for unshipped merchandise instead of 

providing refunds.

K $175.0M Progressive Leasing

Collected $175M from a 2020 settlement of allegations Progressive Leasing 

mislead consumers about the true price of its leasing plans. 

L $6.7M RevenueWire, Inc.

Collected $6.7M from a 2020 settlement of FTC charges RevenueWire, Inc. 

laundered credit card payments for, and assisted and facilitated, two tech 

support scams previously sued by the FTC

M ($12.7M) I Works, Inc., et al.

Disbursed $12.7M ($147,333 refund checks) to individuals who lost money to 

a deceptive “trial” memberships and bogus government-grant and moneymaking schemes in 2010. Refunds are a result of settlement(s) from FTC’s 

2010 charges against I Works, Inc. et al.
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 43

FY 2020 Non-Entity Fund Balance with Treasury Timeline Activity

N $40.3M First Data Merchant 

Services LLC

Collected $40.3M from a 2020 settlement of FTC charges that First Data 

Merchant Services, LLC processed payments and laundered, or assisted 

laundering of credit card transactions for scams that targeted hundreds of 

thousands of consumers.

O $5.7M AlliedWallet, Inc.

Collected $5.7M from a 2019 settlement of FTC .charges that AlliedWallet, 

Inc. assisted numerous scams by knowingly processing fraudulent 

transactions to consumers’ accounts.

P ($8.7M) Triangle Media 

Corporation

Disbursed $8.7M (187,425 refund checks) to consumers who signed up 

online for “risk-free” trial offers, but were then charged full price and 

enrolled in expensive continuity plans without their knowledge. Refunds are 

a result of a 2019 settlement.

Q ($16.3M)

Jeremy Lee Marcus, 

et al. (Helping 

America Group)

Disbursed $16.3M (27,083 refund checks) to consumers who lost money to 

a debt relief scam. Refunds are a result of a 2018 settlement.

R ($9.1M) AWS, LLC, et al. 

(FBA Stores)

Disbursed $9.1M (13,348 refund checks) to customers who paid for the 

“Amazing Wealth System.” Refunds are a result of a 2018 settlement.

S ($3.9M) Neurometrix, Inc.

Disbursed $3.9M (70,142 refund checks) to consumers who bought Quell, 

a wearable devise that supposedly would treat chronic pain throughout 

the body when placed below the knee. Refunds are a result of a 2020 

settlement.

T $10.0M Age of Learning, Inc. 

(ABCmouse)

Collected $10M from a 2020 settlement of FTC charges that online 

children’s education company Age of Learning, Inc., which operates 

ABCmouse, made misrepresentations about cancellations and failed to 

disclose important information to consumers, leading tens of thousands 

of people to be renewed and charged for memberships without proper 

consent.

($12.4M) Net of other collections $32.8M and disbursing ($45.2M) activities, related to over 180 additional 

matters.

$677.1M Ending Balances – FY 2020 Non-Entity Fund Balance with Treasury 
MANAGEMENT’S DISCUSSION AND ANALYSIS

44 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

Significant Contributors to the FY 2020 Non-Entity Fund Balance with 

Treasury Ending Balance

$175M Progressive 

Leasing

$175M held by the FTC from a 2020 settlement of allegations Progressive Leasing 

mislead consumers about the true price of its leasing plans. 

$150M AdvoCare 

International, L.P.

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

consumers into believing they could ear significant income as "distributors" of its 

health and wellness products.

$50M The University of 

Phoenix, Inc.

$50M held by the FTC from a 2020 settlement of allegations The University of 

Phoenix, Inc. used deceptive advertisements that falsely touted their relationships 

and job opportunities with companies such as AT&T, Yahoo!, Microsoft, Twitter, 

and The American Red Cross. Under the settlement The University of Phoenix, 

Inc. will pay $50 million in cash as well as cancel $141 million in debts owed to the 

school by students who were harmed by the deceptive ads.

$49M Reckitt Benckiser 

INC

$49M held by the FTC from a 2019 settlement of allegations Reckitt Benckiser, Inc. 

violated antitrust laws through a deceptive scheme to thwart lower-priced generic 

competition to its branded drug Suboxone.

$40M AMG Services INC

$40M held by the FTC from a 2016 judgment (and earlier settlements) against 

AMG Services, Inc., a payday lending scheme that deceived consumers across the 

country and illegally charged them undisclosed and inflated fees. As of the end of 

FY 2019, the FTC has collected $548M from the defendants and disbursed $508M 

to harmed consumers.

$40M

First Data 

Merchant 

Services LLC

$40M held by the FTC from a 2020 settlement of FTC charges that First Data 

Merchant Services, LLC processed payments and laundered, or assisted laundering 

of credit card transactions for scams that targeted hundreds of thousands of 

consumers.

$173.1M The remaining FBWT balance consists of funds held by the FTC from 139 separate matters.

$677.1M Ending Balance - FY 2020 Non-Entity Fund Balance with Treasury
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 45

STATEMENT OF NET COST

STATEMENT OF NET COST SUMMARY

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(Dollars in Millions) FY 2020 FY 2019 % Change

Protecting Consumers:

Gross costs $ 195 $ 194 1%

Less: earned revenue (13) (12) 8%

Protecting Consumers 182 182 0%

Maintain Competition:

Gross costs $ 167 $ 151 11%

Less: earned revenue (102) (131) -22%

Maintaining Competition 65 20 225%

Net Cost of Operations $ 247 $ 202 22%

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 $247 million in FY 2020, which consists of $362 

million in gross costs offset by $115 million in earned 

revenue 

The FY 2020 net cost of operations for the Protect 

Consumers strategic goal is $182 million, consisting 

of $195 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 2020 net cost of operations for the Maintain 

Competition strategic goal is $65 million, consisting 

of $167 million in gross costs offset by $102 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 increase in the overall gross costs is primarily 

attributable to higher expenses for personnel salaries 

and benefits Total payroll expenses have increased from 

$204 million in FY 2019 to $218 million in FY 2020 

This results from a 2 6 percent general schedule increase 

in employee salaries and a rise in pension and postretirement benefit expenses 

Rent expenses have increased by nearly $2 million in FY 

2020 from the prior year due to higher property taxes 

on commercially-owned space and a General Services 

Administration (GSA) billing adjustment in September 

2020 of $561 thousand in additional expenses for space 

improvement between FY 2018 and FY 2019 for the 

FTC’s leased space at the Constitution Center Finally, 

revenues for premerger notification filings have declined 

and resulted in a $28 million decrease in revenues from 

premerger filing fees, ultimately raising the net cost of 

operations 
MANAGEMENT’S DISCUSSION AND ANALYSIS

46 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

FTC NET COST OF OPERATIONS VS. BENEFIT 

TO CONSUMERS

The FTC had gross costs of $362 million in FY 2020, 

offset by $115 million in earned revenue, resulting in a 

total net cost of operations of $247 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 2020, the FTC returned $137 million 

in non-entity collections to consumers and the U S 

Treasury General Fund Redress disbursements to 

harmed consumers during FY 2020 totaled $130 million 

with an additional $7 million in disgorgements to 

Treasury Civil Penalty collections returned to Treasury 

totaled $4,854 million This is primarily due to the 

substantial $5 billion civil penalty settlement that the 

FTC and the DOJ reached with Facebook related to 

allegations that the company violated its 2012 FTC 

privacy order by deceiving users about their ability to 

control the privacy of their personal information The 

DOJ retained 3 percent, or $150 million, of the total 

settlement All civil penalties collected by the FTC are 

transferred to the General Fund of the U S Government 

at the end of the fiscal year 

Throughout FY 2020, the FTC saved consumers an 

estimated $2 1 billion* through its merger and nonmerger competition law enforcement actions and an 

estimated $1 4 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 2020, the FTC provided an 

estimated total of $8 4 billion in benefits to consumers 

When this benefit is compared to the $247 million 

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

returning an estimated $34 in FTC-provided benefits to 

consumers 

Other benefits to consumers*

$8.4 Billion

COST vs BENEFIT 

FTC Net Cost of Operations

$247 Million

For every $1 of the FTC’s cost there is an estimated $34 in benefits provided to the consumer

Non-entity funds 

disbursed to 

claimants, third party 

administrators, and 

he General Fund of 

he U.S. Government

$137 Million

FTC’S IMPACT 

ON 

THE CONSUMER

These estimates were calculated based on performance t

measures 1.1.3 (consumer savings from consumer protection t

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

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 47

STATEMENT OF CUSTODIAL ACTIVITY

CONDENSED STATEMENT OF CUSTODIAL ACTIVITY

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(Dollars in Millions) FY 2020 FY 2019 % Change

Revenue Activity:

Sources of collections:

Premerger filing fees (net of refunds) $ 101 $ 129 -22%

Civil penalties and fines 4854 147 3202%

Consumer redress 7 2 250%

Total cash collections 4,962 278 1685%

Total Custodial revenue $ 4,962 $ 278 1685%

Disposition of Collections:

Transferred to others:

Treasury general fund $ 4,861 $ 149 3162%

Department of Justice 101 129 -22%

Total Disposition of Collections $ 4,962 $ 278 1685%

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 Fees collected under the 

HSR premerger notification program are distributed 

equally to the FTC and the Antitrust Division of 

the DOJ Premerger filing fees are determined by the 

value and size of parties contemplating a merger The 

FTC’s revenue of $101 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 increase in custodial revenues and 

transfers in FY 2020 is a result of the substantial 

civil penalty settlement that the FTC and the DOJ 

reached with Facebook in the amount of $5 billion 

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 their personal information In addition to 

the historic monetary penalty, the 2019 settlement 

includes unprecedented new restrictions on Facebook’s 

business operations and requires Facebook to restructure 

its approach to privacy from the corporate boardlevel down The order further establishes strong new 

mechanisms to ensure that Facebook executives are 

accountable for the decisions they make about privacy, 

and that those decisions are subject to meaningful 

oversight 

The $5 billion penalty against Facebook is the largest 

ever imposed on any company for violating consumers’ 

privacy and one of the largest penalties ever assessed by 

the U S government for any violation Of the $5 billion 

total, the DOJ retained 3 percent, or $150 million, of the 

total settlement amount as an offsetting collection in its 

working capital fund All civil penalties collected by the 

FTC are transferred to the General Fund of the U S 

Government at the end of the fiscal year 
MANAGEMENT’S DISCUSSION AND ANALYSIS

48 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 2020 Congressional Budget Justification, 

pages 3-4, “Appropriations Language Provisions”) 

The FTC’s budget authority is derived from a direct 

appropriation and offsetting collections 

In FY 2020, the FTC received $332 million in new 

budget authority, representing a $21 million increase 

from the FY 2019 amount The FY 2020 budget 

authority comprised $217 million in general fund 

appropriations plus $115 million in spending authority 

from offsetting collections, consisting of $101 million 

from fees collected for premerger notification filings 

under the Hart-Scott-Rodino Antitrust Improvements 

Act of 1976, $13 million from fees collected for the 

National Do Not Call Registry, and $1 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 65 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 $217 million, 

which is less than 1/10 of 1 percent of the total nondefense discretionary spending for FY 2020 

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 20 percent or $56 million change from FY 2010 ($276 

million) to FY 2020 ($332 million) 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 49

General fund

appropriation

$168 Million

Offsetting

collection

$143 Million

General fund

appropriation

$217 Million

Offsetting

collection

$115 Million

NEW BUDGET AUTHORITY

FY 2020 - $332 MILLION

FY 2019 - $311 MILLION

The constraints from stagnant financial resources 

are further magnified by increasing costs and rising 

expectations from the American public During this 

same time period, for example, consumer complaints to 

the FTC rose by over 100 percent, and premerger filings 

rose by over 75 percent, among other measures of the 

FTC’s increased workload 

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 

Spending on expert witnesses rose in FY 2020 from 

the previous year Costs for experts in litigation matters 

continue to pose significant challenges on the FTC’s 

limited budgetary resources and those costs 

Visit the FTC’s Consumer Sentinel Network Data 

and Visualization page to learn more about complaints 

received by the FTC and view interactive dashboards on 

data collected 

Visit the Do Not Call FY 2020 Data Book to learn more 

about the Do Not Call program 
MANAGEMENT’S DISCUSSION AND ANALYSIS

50 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

140%

120%

100%

80%

60%

40%

20%

0%

 FY10 FY11 FY12 FY13 FY14 FY15 FY16 FY17 FY18 FY19 FY20

Consumer complaints received (data only FTC budget (excludes one-time 

through 2019) funds for a building move)

Mergers reported (data only through 2019) FTC employees 

OMB cost factor inflation

PERCENTAGE CHANGE IN CONSUMER COMPLAINTS, MERGERS, 

AND FTC RESOURCES SINCE 2010

+123%

+81%

+19.8%

+20%

+0.4%

THE FTC’S FY 2020 OBLIGATIONS:

In FY 2020, the FTC received $332 million in new 

budget authority and also authority to obligate $14 7 

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 $349 million in FY 2020 This was an increase 

of $18 million, or 5 percent, compared to new obligations 

in FY 2019 The increase in obligations incurred in 

FY 2020 was mainly attributable to higher payroll costs 

as well as higher spending for rent, communications, 

and utilities Payroll spending has increased by 6 9 

percent to $218 million in FY 2020 from $204 million 

in FY 2019 This is the result of the 2 6 percent pay 

raise for FY 2020, a rise in pension and post-retirement 

benefit expenses, and higher cost factors associated with 

employee benefits Rent expenses paid to GSA have 

increased over the past few years due to inflation and 

a rise in property taxes on commercially-leased space 

Higher obligations for communications and utilities are 

related to software licenses and wireless communications 

Finally, the FTC incurred higher obligations in FY 2020 

for expert witness support services 
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 51

FY 2020 FTC OBLIGATIONS BY CATEGORY 

$218.3M

Payroll (compensation and benefits)

$7.1M

Other (printing, supplies, 

transportation, PP&E)

$21.4M

Expert Witness 

$31.3M

Rent, Comm, Utilities

$71.3M

Other Contractual Services 

Total obligations incurred during FY 2020: $349M

Historically the FTC’s obligations by category 

have remained relatively steady when expressed as a 

percentage of all obligations incurred during a particular 

fiscal year Between FY 2015 and FY 2020, there were 

several notable changes 

• Expert witness obligations increased from $14 2 

million in FY 2015 to $18 4 million in FY 2018 

before declining to $8 6 million in FY 2019 and 

subsequently rising in FY 2020 to $21 3 million 

The services of these expert witnesses are critical to 

the successful investigation and litigation of merger 

cases Expert witness obligations have increased most 

significantly and also fluctuate most dramatically; 

this directly results from 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 $11 1 million in FY 2015 to $2 58 million 

in FY 2020, or a decrease from 3 5 percent of total 

obligations in FY 2015 to 0 7 percent in FY 2020 

• Payroll costs have increased steadily each year over 

the past five years, starting at $188 1 million in FY 

2015 and growing to $218 3 million in FY 2020, 

representing an increase of 16 percent over six years 

The increase is mostly a result of pay raises and 

increases in benefits costs 
MANAGEMENT’S DISCUSSION AND ANALYSIS

52 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 

Federal Trade Commission

Agency 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.

Website Congressional Justification of Budget (CJ)

https://www.ftc.gov/ https://www.ftc.gov/cj 

Budgetary Resources for FY 2020

FY 2020 data reported through September 30, 2020

$354.3 Million

This is 0.0% of the total U.S. federal budgetary resources for FY 2020.
MANAGEMENT’S DISCUSSION AND ANALYSIS

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 53

FINANCIAL MANAGEMENT INDICATORS FOR FY 2020

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) 97.2%

Percentage interest penalties paid to total dollars invoiced .0024%

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 FY 2020 financial statements have been prepared 

from the books and records of the agency in accordance 

with OMB Circular A-136, financial reporting 

requirements, as amended The financial statements 

represent the financial position and results of operations 

of the agency pursuant to the requirements of Title 31 

of the U S Code Section 3515(b) While these 

statements have been prepared from the agency’s books 

in accordance with GAAP for federal entities and the 

formats prescribed by the OMB, the statements are in 

addition to the financial reports used to monitor and 

control budgetary resources, which are prepared from the 

same books and records These statements should be read 

with the understanding that they are for a component of 

the U S government, a sovereign entity 

FINANCIAL

SECTION
FINANCIAL SECTION

56 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

David Rebich

Chief Financial Officer

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

2020 The AFR provides financial and high-level program performance 

information to enable the FTC’s stakeholders to understand and evaluate our 

achievements relative to our mission and resources 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 2020, the FTC has achieved, for the twenty-fourth consecutive year, an 

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

this accomplishment, and this is no simple task, especially in a year as challenging 

as FY 2020 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 Implemented a new suite of financial systems that accompanied the change 

in financial shared service providers, from the Interior Business Center to the 

Administrative Resource Center (ARC),

n Updated the FTC risk profile to identify and monitor risk associated with 

operation during the COVID-19 pandemic,

n Maintained a high level of performance while having 100% staff telework,

n Closed six Corrective Action Plans (CAPs) in FMO, and collaborated within 

the agency to close an additional 15 CAPs, and

n Monitored Fraud Risk by collecting and analyzing related fraud control data 

from FTC program areas, and remediated two Fraud Risk areas previously 

identified 

One of the most significant improvements to the FTC’s financial management 

capability is the successful migration of Shared Service Providers from the 

Department of the Interior’s Business Center to the Department of the 

Treasury’s ARC for the agency’s financial, travel, and acquisition systems and 

services In 2018, FMO leadership determined that the FTC had to become 

more efficient when implementing OMB and Treasury mandated reporting 

requirements and financial systems The FTC initiated the conversion during 

FY 2019 and completed the conversion to start Fiscal Year 2020 with ARC as 

the FTC’s shared service provider The conversion was extremely successful, and 

MESSAGE FROM THE CHIEF FINANCIAL 

OFFICER
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 57

we have already seen some of the expected efficiencies 

and cost savings During 2020, we built upon the 

conversion efforts and began a systematic review of all 

FMO processes to ensure we are being both efficient and 

effective in our partnership with ARC 

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 13, 2020
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58 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

1

MEMORANDUM

November 13, 2020

FROM: Andrew Katsaros

Inspector General

TO: Joseph J. Simons, Chairman

Commissioner Noah Joshua Phillips 

Commissioner Rohit Chopra

Commissioner Rebecca Kelly Slaughter

Commissioner Christine S. Wilson

SUBJECT: Report on Audit of the FTC’s FY 2020 and 2019 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 2020 and 2019. We commend the FTC for attaining an 

unmodified (clean) opinion for the 24th 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, 2020 and 2019, and to provide reports on

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

required the audit to be performed in accordance with U.S. generally accepted government 

auditing standards, Office of Management and Budget audit guidance, and the Government 

Accountability Office’s Financial Audit Manual.

In its audit, Brown & Company found:

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

2019, are presented fairly, in all material respects, in accordance with U.S. generally accepted 

accountingprinciples;

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

procedures performed; and

• no reportable noncompliance for fiscal year 2020 with provisions of applicable laws, 

regulations, contracts, and grant agreements tested.

Brown & Company is responsible for the attached auditor’s report dated November 13, 2020, and 

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

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 59

2

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

and regulations.

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.

Attachment
FINANCIAL SECTION

60 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

Inspector General 

Federal Trade Commission 

Washington, D.C. 

In our audits of the fiscal years 2020 and 2019 financial statements of the Federal Trade Commission 

(FTC), we found:

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

2019, 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 2020 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 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, 2020, and 2019; 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. We

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

opinions. 

Management’s Responsibility 

FTC’s management is responsible 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.

INDEPENDENT AUDITOR’S REPORT 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 61

2 

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, 2020, and 2019, 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.
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62 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 of

forming 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 FTC’s financial statements, we considered FTC’s internal control over

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

procedures related to FTC’s internal control over financial reporting in accordance with U.S. generally

accepted government auditing standards.

Management’s Responsibility

FTC’s 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, 2020, in accordance with U.S. generally accepted government auditing standards, we

considered the FTC’s internal control over financial reporting as a basis for 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 FTC’s internal 

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

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

deficiencies or material weaknesses. We did not consider all internal controls relevant to operating

objectives, such asthose controls relevant to preparing performance information and ensuring efficient 

operations.

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.

3 
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4 

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 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 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’s management is responsible for complying with laws, regulations, contracts, and grant 

agreements applicable to FTC. 

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 2020 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 
FINANCIAL SECTION

64 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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.

This report is intended solely for the information and use of the management of FTC, OMB, and the U.S. 

Congress, and is not intended to be, and should not be, used by anyone other than these specified parties.

5 
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www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 65

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 
FINANCIAL SECTION

66 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

BALANCE SHEET

AS OF SEPTEMBER 30, 2020 AND 2019

(DOLLARS IN THOUSANDS)

2020 2019

Assets (Note 2):

Intragovernmental:

Fund balance with Treasury (Note 3) $ 790,507 $ 387,310

Accounts receivable, Net (Note 4) 69 85 

Advances and prepayments 153 205 

Total intragovernmental assets 790,729 387,600 

Accounts receivable, Net (Note 4) 628,049 616,549 

General property, plant, and equipment, Net (Note 5) 25,604 30,053 

Total Assets $ 1,444,382 $ 1,034,202 

Liabilities (Notes 6 and 7):

Intragovernmental:

Accounts payable $ 830 $ 737 

Other liabilities (Note 7) 2,708 2,395 

Total intragovernmental liabilities 3,538 3,132 

Accounts payable 11,724 12,529 

Accrued redress due to claimants 628,026 616,306 

Undisbursed redress collections (Note 14) 677,109 265,432 

Other liabilities (Note 7) 27,272 23,087 

Total Liabilities 1,347,669 920,486 

Net Position (Note 1(p)):

Unexpended appropriations - - 

Cumulative results of operations 96,713 113,716 

Total Net Position 96,713 113,716 

Total Liabilities and Net Position $ 1,444,382 $ 1,034,202

The accompanying notes are an integral part of these statements.
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 67

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(DOLLARS IN THOUSANDS)

2020 2019

Strategic Goal 1: Protect Consumers:

Intragovernmental costs $ 50,640 $ 49,532 

Public costs 144,239 144,606 

Gross costs, protect consumers 194,879 194,138 

Intragovernmental earned revenue (5) (2)

Public earned revenue (12,470) (12,029)

Earned revenue, protect consumers (12,475) (12,031)

Net Cost, Protect Consumers 182,404 182,107 

Strategic Goal 2: Maintain Competition:

Intragovernmental costs 43,486 38,447 

Public costs 123,863 112,242 

Gross costs, maintain competition 167,349 150,689 

Intragovernmental earned revenue (848) (963)

Public earned revenue (101,580) (129,585)

Earned revenue, maintain competition (102,428) (130,548)

Net Cost, Maintain Competition 64,921 20,141 

Net Cost of Operation $ 247,325 $ 202,248 

The accompanying notes are an integral part of these statements.
FINANCIAL SECTION

68 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(DOLLARS IN THOUSANDS)

2020 2019

Unexpended Appropriations:

Beginning balance $ - $ - 

Budgetary Financing Sources:

Appropriations received 216,966 168,228

Appropriations used (216,966) (168,228)

Total budgetary financing sources - - 

Total Unexpended Appropriations - - 

Cumulative Results of Operations:

Beginning balance $ 113,716 $ 135,361

Budgetary Financing Sources:

Appropriations used 216,966 168,228

Other Financing Sources:

Imputed financing and other 13,356 12,375 

Total financing sources 230,322 180,603

Net cost of operations (247,325) (202,248) 

Net change (17,003) (21,645)

Cumulative Results of Operations 96,713 113,716 

Net Position (Note 1(p)) $ 96,713 $ 113,716

The accompanying notes are an integral part of these statements.
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 69

STATEMENT OF BUDGETARY RESOURCES

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(DOLLARS IN THOUSANDS)

2020 2019

Budgetary Resources: 

 Unobligated balance, brought forward, October 1 $ 15,027 $ 22,817 

 Recoveries of unpaid prior year obligations 7,114 12,241 

 Other changes in unobligated balance 125 177 

 Unobligated balance from prior year budget authority, net 22,266 35,235 

 Appropriations 216,966 168,228 

 Spending authority from offsetting collections 115,117 142,566 

Total Budgetary Resources $ 354,349 $ 346,029 

Status of Budgetary Resources: 

 New obligations and upward adjustments (total) (Note 10) $ 349,380 $ 331,002 

 Unobligated balance, end of year: 

 Apportioned, unexpired accounts 2,742 7,455 

 Unapportioned, unexpired accounts 2,227 7,572 

 Unexpired unobligated balance, end of year 4,969 15,027 

 Unobligated balance, end of year (total) 4,969 15,027 

Total Budgetary Resources $ 354,349 $ 346,029 

Outlays, Net: 

 Outlays, gross $ 340,159 $ 318,179

 Actual offsetting collections (115,028) (142,690)

 Outlays, net 225,131 175,489 

 Distributed offsetting receipts (6,705) (2,283)

 Agency outlays, net $ 218,426 $ 173,206 

The accompanying notes are an integral part of these statements.
FINANCIAL SECTION

70 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

STATEMENT OF CUSTODIAL ACTIVITY

FOR THE YEARS ENDED SEPTEMBER 30, 2020 AND 2019

(DOLLARS IN THOUSANDS)

Protect 

Consumers

Maintain 

Competition 2020 2019

Revenue Activity (Note 13):

Sources of collections:

Premerger filing fees (net of refunds) $ - $ 101,573 $ 101,573 $ 129,585 

Civil penalties and fines 4,854,148 - 4,854,148 146,745 

Consumer redress 6,969 - 6,969 1,778 

Other miscellaneous receipts 34 - 34 190 

Total cash collections 4,861,151 101,573 4,962,724 278,298 

Accrual adjustments (236) - (236) (202) 

Total Custodial Revenue $ 4,860,915 $ 101,573 $ 4,962,488 $ 278,096 

Disposition of Collections (Note 13):

Transferred to others:

Treasury general fund $ 4,861,151 $ - $ 4,861,151 $ 148,713 

Department of Justice - 101,573 101,573 129,585

Amounts yet to be transferred (236) - (236) (202) 

Total Disposition of Collections $ 4,860,915 $ 101,573 $ 4,962,488 $ 278,096 

Net Custodial Activity $ - $ - $ - $ -

The accompanying notes are an integral part of these statements.
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 71

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 

(FTC) 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 Fund

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 ) 

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 14, Consumer 

Redress Activities ) 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): Fees 

collected for premerger notification filings under the 

HSR Act are 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) (See Note 

1(q), 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 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 and collections for the consumer 

redress program for which redress to consumers is not 

practicable are recorded in this account 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 
FINANCIAL SECTION

72 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 2020) 

Transactions are recorded on both an accrual and 

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 single fund to account for salaries and all 

necessary expenses Further, there are limited intraentity transactions with any other fund (e g , deposit 

fund) that would require eliminating entries to present 

consolidated statements Accordingly, the 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 accrued 

separately from the accounts payable accrual 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 2020 Congressional 

Budget Justification, pages 3-4, “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 a direct appropriation and 

offsetting collections The FTC accounts for budget 

authority in its General Fund account (29X0100) 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 

For fiscal years 2020 and 2019, the FTC had no 

classified activities 
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www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 73

(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, civil 

monetary penalties, and the portion of fees collected for 

premerger notification filings that are distributed to the 

DOJ in a subsequent period 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 fund, 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 

(Treasury or DOJ), 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 Statement of Federal Financial Accounting 

Standards (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 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-purpose 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 
FINANCIAL SECTION

74 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 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, 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 

2020, the annual contribution limit is $19,500 and 

employees age 50 and over may contribute an additional 

$6,500 in catch-up 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 CSRS-participating 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 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 75

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 

16, 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 16, 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 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) Contingent Liabilities

Contingent liabilities are liabilities that may be incurred 

by the FTC depending on the outcome of an uncertain 

future event, such as pending or threatened litigation 

Contingencies are classified into three categories: 

probable, reasonably possible, and remote A contingency 

is considered probable when the future confirming 

events are likely to occur Probable contingent liabilities 

are recognized in the financial statements provided the 

amount can reasonably be estimated Contingencies 

are reasonably possible when the chance of the future 

confirming event occurring is more than remote but 

less than probable Reasonably possible contingencies 

are disclosed in the notes to the financial statements, as 

well as probable contingencies that cannot reasonably be 

estimated Remote contingencies are not recognized in 

the financial statements or disclosed in the notes to the 

financial statements (See Note 9, Commitments and 

Contingencies )

(p) Net Position 

The portion of the FTC’s budget authority funded by a 

direct appropriation is fully expended during the year 

Therefore, there is no unexpended appropriation balance 

in net position at the end of the year (See Statement of 

Changes in Net Position ) 

Cumulative results of operations represent the net 

results of operations since the agency’s inception, the 

cumulative amount of prior period adjustments, the 

remaining book value of capitalized assets, and future 

funding requirements 

(q) 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 
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76 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 While HSR and DNC fees relate to 

the major strategic goals of the FTC, these fees are not 

related to specific costs incurred 

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 

(r) 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 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 77

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 consist of amounts held temporarily in deposit 

funds for the consumer redress program and collections 

of premerger filing fees held in clearing/suspense funds 

that will be transferred out in a subsequent period 

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, 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 

 Clearing funds - premerger filing fees - - - 

 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 

Entity and non-entity assets consisted of the following as of September 30, 2019: 

(Dollars in thousands) 2019

Entity

2019 

Non-Entity

2019

Total

Intragovernmental:

 Fund balance with Treasury:

 General funds $ 121,563 $ - $ 121,563 

 Deposit funds - consumer redress - 265,432 265,432

 Clearing funds - premerger filing fees - 315 315

 Accounts receivable, net 85 - 85

 Advances and Prepayments 205 - 205

Total intragovernmental assets 121,853 265,747 387,600 

 Accounts receivable, net 7 616,542 616,549

 Property, plant and equipment, net 30,053 - 30,053

Total Assets $ 151,913 $ 882,289 $ 1,034,202 
FINANCIAL SECTION

78 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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, 2020, and 2019 In terms of the 

relationship to the budget, the FTC’s Fund balance with 

Treasury (FBwT) 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 unavailable-unapportioned balance is the result 

of recoveries of prior-year obligations that exceed 

apportioned amounts The unavailable - excess offsetting 

collections balance of $26,004 thousand are HSR fees 

collected above the yearly congressional authorized 

amount to collect and spend 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 The cash position of the 

Consumer Redress deposit fund has increased by 

more than $411 million as displayed on the line NonBudgetary Fund Balance with Treasury 

Fund balance with Treasury consisted of the following as of September 30, 2020 and 2019:

(Dollars in thousands) 2020 2019

Status of Fund Balance with Treasury:

 Unobligated balance:

 Available - apportioned $ 2,742 $ 7,455

 Unavailable - unapportioned 2,227 7,572 

 Unavailable - excess offsetting collections 26,004 26,004 

 Unavailable - temporary reduction 6,450 6,450 

 Total Unobligated balance: 37,423 47,481 

 Obligated balance not yet disbursed 75,975 74,082 

 Non-budgetary fund balance with Treasury 677,109 265,747 

Total Status of Fund Balance with Treasury $ 790,507 $ 387,310
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 79

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 nonentity liabilities Agency accounts receivable balances for 

both FY 2020 and FY 2019 do not include any amounts 

associated with criminal restitution 

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 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, 

2020 Accumulated unrecognized interest on receivables 

deemed uncollectible totaled $27,110 thousand and 

$11,655 thousand as of September 30, 2020, and 2019 

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 

Accounts receivable, net consisted of the following as of September 30, 2019:

(Dollars in thousands) Gross

Receivables 

Allowance for

Uncollectible

Accounts 

 2019 Net

 Entity Accounts Receivable: 

 Intragovernmental $ 85 $ - $ 85

 With the public 9 (2) 7 

 Total entity accounts receivable 94 (2) 92 

 Non-Entity Accounts Receivable: 

 Consumer redress 2,556,346 (1,940,040) 616,306 

 Civil penalties 1,029 (793) 236 

 Total non-entity accounts receivable 2,557,375 (1,940,833) 616,542 

Total Accounts Receivable $ 2,557,469 $ (1,940,835) $ 616,634 
FINANCIAL SECTION

80 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

NOTE 5—GENERAL PROPERTY, PLANT, AND 

EQUIPMENT, NET 

The following represents the FTC’s capital assets and 

accumulated depreciation as of September 30, 2020, and 

2019 No asset impairments were recognized in either 

year The accumulated depreciation has increased by 

$3,547 thousand while the current year depreciation and 

amortization expense is $5,587 thousand, as presented 

in Note 16 “Reconciliation of Net Operating Cost and 

Net Budgetary Outlays ” Asset disposals account for the 

difference between the depreciation and amortization 

expense and the higher accumulated depreciation Assets 

disposed of include laptops, software applications, 

chillers and condensers (leasehold improvements), and a 

web application delivery controller Total net book value 

of assets written off during FY 2020 is $617 thousand 

Asset purchases during the last 12 months total $1,755 

thousand and include a physical access control system, 

perpetual software licenses, furniture, and an integrated 

closed circuit television system 

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 

Property, plant, and equipment, net consisted of the following as of September 30, 2019:

Asset Class

(Dollars in thousands)

Service 

Life

Acquisition 

Value

Accumulated 

Depreciation/

Amortization

Net 

Book Value

Equipment 5-20 years $ 21,298 $ (18,249) $ 3,049

Leasehold improvements 15 years 46,301 (20,563) 25,738 

Software 5 years 21,367 (20,101) 1,266 

Total Property, Plant, and Equipment $ 88,966 $ (58,913) $ 30,053 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 81

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, accrued annual leave, and 

contingencies 

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:

Accrued Civil Penalties due to Treasury - offsetting 

liability to non-entity accounts receivable for civil 

penalties, net, that upon collection will be payable to the 

General Fund of the U S Government 

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, 2020 and 

September 2019:

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2020 Total

Intragovernmental Liabilities:

FECA liability $ 380 $ - $ 380 

Accrued Civil Penalties and Receipts Due to Treasury - - - 

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 

Contingencies - - - 

Deposits in Clearing Funds - - - 

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 

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2019 Total

Intragovernmental Liabilities:

FECA liability $ 449 $ - $ 449

Accrued Civil Penalties and Receipts Due to Treasury - 236 236

Total Intragovernmental Liabilities 449 236 685 

Non-Federal Liabilities:

Accrued leave 12,617 - 12,617 

Actuarial FECA 2,548 - 2,548 

Undisbursed redress collections - 265,432 265,432

Accrued redress due to claimants - 616,306 616,306

Contingencies 843 - 843 

Deposits in Clearing Funds - 315 315 

Total Non-Federal Liabilities 16,008 882,053 898,061 

Total Unfunded Liabilities 16,457 882,289 898,746

Liabilities Covered by Budgetary Resources 21,740 

Total Liabilities $ 920,486
FINANCIAL SECTION

82 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

NOTE 7—OTHER LIABILITIES

As of September 30, 2020, and 2019, components of amounts reported on the Balance Sheet as Other 

Intragovernmental Liabilities and Other Liabilities along with a categorization of current versus non-current are 

as follows:

Other liabilities consisted of the following as of September 30, 2020:

(Dollars in thousands) 2020

Non-Current

2020

Current

2020

Total

Other intragovernmental liabilities:

Accrued employee benefits $ - $ 2,328 $ 2,328 

FECA liability 380 - 380 

Accrued Civil Penalties and Receipts Due to 

Treasury - - - 

Total Other Intragovernmental Liabilities: 380 2,328 2,708 

Other Non-Federal liabilities:

Accrued payroll and benefits - 8,552 8,552 

Accrued leave 16,278 - 16,278 

Actuarial FECA 2,442 - 2,442 

Contingencies - - - 

Deposits in clearing funds - - - 

Total Other Non-Federal Liabilities 18,720 8,552 27,272 

Total Other Liabilities $ 19,100 $ 10,880 $ 29,980 

Other liabilities consisted of the following as of September 30, 2019:

(Dollars in thousands) 2019

Non-Current

2019

Current

2019

Total

Other intragovernmental liabilities:

Accrued employee benefits $ - $ 1,710 $ 1,710

FECA liability 449 - 449 

Accrued Civil Penalties and Receipts Due to 

Treasury - 236 236 

Total Other Intragovernmental Liabilities: 449 1,946 2,395 

Other Non-Federal liabilities:

Accrued payroll and benefits - 6,764 6,764

Accrued leave 12,617 - 12,617 

Actuarial FECA 2,548 - 2,548

Contingencies 843 - 843

Deposits in clearing funds - 315 315

Total Other Non-Federal Liabilities 16,008 7,079 23,087 

Total Other Liabilities $ 16,457 $ 9,025 $ 25,482 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 83

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, warehouse storage, 

laptops, and software Total short-term lease obligations 

are $1,688 thousand as of September 30, 2020 Future 

minimum lease payments on contracts with remaining 

terms in excess of one year are presented in the tables 

below 

Future minimum lease payments due under leases of government-owned 

property for the fiscal year ended September 30, 2020:

Fiscal Year 2020

(Dollars in thousands)

2021 $ 8,274 

2022 8,232 

2023 8,084 

2024 8,096 

2025 8,108 

Thereafter 31,434 

Total Future Minimum Lease Payments $ 72,228 

Future minimum lease payments due under leases of commercial-owned 

property for the fiscal year ended September 30, 2020:

Fiscal Year 2020

(Dollars in thousands)

2021 $ 15,054 

2022 15,779 

2023 15,769 

2024 7,403 

2025 1,905 

Thereafter 7,191 

Total Future Minimum Lease Payments $ 63,101 
FINANCIAL SECTION

84 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

NOTE 9—COMMITMENTS AND 

CONTINGENCIES 

The FTC is subject to potential liabilities in various 

administrative proceedings, legal actions, and claims 

brought against the agency In the opinion of legal 

counsel and the FTC management, there are no 

“probable” or “reasonably possible” contingencies 

as of September 30, 2020 that will require funding 

through the FTC’s budget Furthermore, there are no 

pending probable or reasonably possible claims where 

the probable loss cannot be estimated Accordingly, 

no obligations are recorded in the agency’s financial 

statements in relation to contingent liabilities 

Tort claims against federal agencies are administered 

and resolved by the DOJ with amounts necessary for 

resolution funded through the U S Treasury Judgment 

Fund The Judgment Fund was enacted by Congress in 

1956 as a permanent, indefinite appropriation for the 

payment of claims that did not have another funding 

source The recognition of claims to be funded through 

the Judgment Fund represents a claim against the federal 

government as a whole and should not be interpreted 

as claims against the assets of an agency The FTC has 

no contingent liabilities where the risk of loss is either 

probable or reasonably possible as of September 30, 2020 

that require funding through the U S Treasury Judgment 

Fund 

The following presents the FTC’s probable and 

reasonably possible legal contingencies with an estimated 

range of loss for FY 2020 and FY 2019 The contingent 

liability of $843 thousand recognized in FY 2019 was 

closed out during FY 2020 

Contingent Liabilities as of September 30, 2020: 

(Dollars in thousands) Accrued 

Liabilities

Estimated Range of Loss

Lower End Upper End

FY 2020:

Legal Contingencies:

Probable - - - 

Reasonably Possible - - - 

Contingent Liabilities as of September 30, 2019:

(Dollars in thousands) Accrued 

Liabilities

Estimated Range of Loss

Lower End Upper End

FY 2019:

Legal Contingencies:

Probable 843 843 1,700 

Reasonably Possible - - - 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 85

NOTE 10—APPORTIONMENT CATEGORIES OF OBLIGATIONS INCURRED: DIRECT VS. 

REIMBURSABLE OBLIGATIONS

Obligations incurred consisted of the following for the fiscal years ended September 30, 2020 and 

2019:

(Dollars in thousands) 2020 2019

Obligations Incurred:

Category A - direct obligations $ 348,513 $ 330,033

Category B - reimbursable obligations 867 969

Total Obligations Incurred $ 349,380 $ 331,002

Category A – direct obligations represent amounts 

obligated in carrying out the FTC’s normal on-going 

operations The source of funding for these obligations 

is an annual appropriation, offsetting collections, and 

unobligated funds brought forward from previous years 

These funds are made available by the OMB through 

quarterly (Category A) apportionments 

Category B – reimbursable obligations represent 

amounts obligated in fulfilling interagency agreements 

when the FTC is the provider of services The source of 

funding for these obligations is reimbursements collected 

from other federal agencies to cover the FTC’s costs in 

fulfilling the agreement 

The FTC does not have any activity exempt from 

apportionment or apportioned under Category AB 

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 2021 President’s Budget, which 

contains FY 2019 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 2019 Statement of Budgetary Resources and 

the FY 2019 actual amounts as reported in the FY 2021 

President’s Budget; however, the Statement of Budgetary 

Resources includes Distributed Offsetting Receipts, 

which are excluded from the President’s Budget The 

FY 2022 Budget of the United States Government is 

not available to compare FY 2020 actual amounts to 

the FY 2020 Statement of Budgetary Resources The 

expected availability for this report is February 2021 on 

the OMB’s website 
FINANCIAL SECTION

86 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

NOTE 12—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 

Undelivered obligations consisted of the following as of September 30, 2020 and 2019:

(Dollars in thousands) 2020 2019

Non-Federal Undelivered Orders Unpaid $ 47,561 $ 46,393 

Federal Undelivered Orders Unpaid 5,574 6,329 

Federal Undelivered Orders Paid 153 205 

Total Federal Undelivered Orders 5,727 6,534 

Total Undelivered Orders $ 53,288 $ 52,927 

NOTE 13—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 The portion of collections designated for the 

DOJ is reported as a custodial activity As of September 

30, 2020 and 2019, the FTC collected $203,146 and 

$259,170 thousand in HSR premerger filing fees Onehalf of the amounts collected in each year was distributed 

to the DOJ, as shown on the Statement of Custodial 

Activity 

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 

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 

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 $6,969 thousand 

as of September 30, 2020 and $1,778 thousand as of 

September 30, 2019 

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 
FINANCIAL SECTION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 87

NOTE 14—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 $130,301 and $350,058 thousand 

as of September 30, 2020, and 2019 

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, 2020 

and 2019:

(Dollars in thousands) 2020 2019

Consumer Redress:

Fund Balance with Treasury

Beginning balance $ 265,432 $ 358,776

Collections 548,947 258,492 

Disbursements to claimants and third party administrators 

for redress, net (130,301) (350,058)

Disgorgements to Treasury, net (6,969) (1,778)

Total Fund Balance with Treasury, Ending $ 677,109 $ 265,432

Accounts Receivable, Net

Beginning balance $ 616,306 $ 598,515 

Net activity 11,720 17,791

Total Accounts Receivable, Ending $ 628,026 $ 616,306

NOTE 15—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 
FINANCIAL SECTION

88 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

NOTE 16—RECONCILIATION OF NET OPERATING COST AND NET BUDGETARY OUTLAYS

The reconciliation 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, 2020, and 2019 

Reconciliation of Net Operating Cost and Net Budgetary Outlays for the Years Ended 

September 30, 2020 and 2019:

FY 2020

Intragovernmental With the Public Total

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 

Deposits in Clearing Funds - Pre-Merger Refunds Due - 315 315 

Miscellaneous Receipts - (7,003) (7,003)

Total Components of Budgetary Outlays Not Part of Net Operating Cost 17 (4,950) (4,933)

Net Outlays (Calculated) $ 79,207 $ 139,219 $ 218,426 

Related Amounts on the Statement of Budgetary Resources (SBR)

Outlays, Gross $ 340,159 

Actual Offsetting Collections (115,028)

Outlays, Net (SBR) $ 225,131 

Distributed Offsetting Receipts (6,705)

Agency Outlays, Net (SBR) $ 218,426 

FY 2019

Intragovernmental With the Public Total

Net Operating Cost (SNC) $ 87,014 $ 115,234 $ 202,248

Components of Net Operating Cost Not Part of the Budgetary Outlays

Depreciation and Amortization - (8,435) (8,435)

Losses on Asset Dispositions - (509) (509)

Increase/(Decrease) in Assets 40 (11) 29

(Increase)/Decrease in Liabilities (881) (5,056) (5,937) 

Imputed Costs (12,375) - (12,375)

Total Components of Net Operating Cost Not Part of the Budgetary Outlays (13,216) (14,011) (27,227)

Components of Budgetary Outlays Not Part of Net Operating Cost

Purchases of Assets - 468 468

Deposits in Clearing Funds - Pre-Merger Refunds Due - (315) (315) 

Miscellaneous Receipts - (1,968) (1,968)

Total Components of Budgetary Outlays Not Part of Net Operating Cost - (1,815) (1,815)

Net Outlays (Calculated) $ 73,798 $ 99,408 $ 173,206 

Related Amounts on the Statement of Budgetary Resources (SBR)

Outlays, Gross $ 318,179

Actual Offsetting Collections (142,690)

Outlays, Net (SBR) $ 175,489 

Distributed Offsetting Receipts (2,283)

Agency Outlays, Net (SBR) $ 173,206 
OTHER

INFORMATION
OTHER INFORMATION

90 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

Summary of the Top Management 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 

The OIG made six recommendations in its FY 2019 FISMA report to assist the FTC in 

improving its security program in the areas of Risk Management, Configuration Management, 

Identity and Access Management, and Contingency Planning. Closing these recommendations 

and positioning the FTC to detect advanced persistent threats to its systems will help ensure that 

the FTC’s data and information are properly protected. 

2. Maintaining Mission Success During the COVID-19 Pandemic 

The FTC’s ability to continue to deliver on its dual missions of protecting consumers and 

promoting competition will be tested in new and challenging ways throughout the duration of 

this COVID-19 pandemic.

3. Understanding Fraudulent Identity Theft Complaints 

The FTC faces a significant challenge in addressing the number of potentially fraudulent 

complaints submitted to IdentityTheft.gov. An FTC analysis of the complaints received since 

January 2020 revealed significant patterns that strongly suggest the fraudulent use of the service. 

4. Costs of Expert Witness Services 

The escalating costs of expert witness services represents a significant and continuing risk to the 

FTC. Between FY 2015 and 2018, the cost of expert witness services rose from $9.3 million to 

$14.9 million, far outpacing the FTC appropriation increases in the same period. Aware of this 

rapid increase in costs, the FTC has designated its expert witness services as a “top risk” on the 

agency’s risk register. 

Watch List Item

Acquisition Planning and Contract Management 

Although the FTC’s Acquisitions Branch has recently addressed some of its most pressing issues, 

it must remain vigilant in maintaining the proper level of staff and resources and in following 

established processes to ensure proper oversight and management of contracts.

1

The entire FY 2020 report is available at https://www.ftc.gov/system/files/documents/reports/fy-2020-oig-reportftcs-top-management-challenges/oig_fy_2020_ftc_top_management_challenges_report_final_09282020.pdf
OTHER INFORMATION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 91

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
OTHER INFORMATION

92 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 a FY 2018 risk assessment for nine payment 

processes including payroll, procurement, redress 

payments to consumers, travel, purchase card, premerger 

filing fee refunds, training, and two miscellaneous 

payment processes Each payment program was defined 

by its own internal control framework 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 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 also performed a quantitative risk assessment 

and 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 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 Per OMB guidance and the result of FY 2018 

IPERIA risk assessments, no assessment was conducted 

during FY 2020 and the next is scheduled for FY 2021 

In addition, the FTC regularly conducts assessments 

over the internal controls over payment processes In 

2020, the FTC conducted a full assessment of controls 

over HR Payroll and Benefits, and limited assessments 

over Procure to Pay, Travel, and Purchase Card payment 

programs Each of these assessments identified and 

tested 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 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 costeffective 

FRAUD REDUCTION REPORT

During 2020, the FTC directed several efforts to 

implement the Fraud Reduction Data Analytics Act 

(FRDAA) of 2015 and made progress in implementing 

effective controls in financial and administrative 

processes, in implementing GAO’s principles for 

addressing fraud risk, and in implementing OMB’s 

Circular A123 leading practices for agencies 

This year, the FTC implemented several strategies and 

procedures, and took steps to prevent and detect fraud 

within the agency These actions included:

• Implementing OMB’s best practice to integrate 

fraud risk reduction activities within the agency’s 

Enterprise Risk Management (ERM) Program 
OTHER INFORMATION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 93

This included the CFO’s written designation of the 

ERM program manager as the agency official Fraud 

Risk Coordinator Responsibilities of the Fraud 

Risk Coordinator include: 1) coordinating agencywide efforts to identify, assess and respond to fraud 

risks; 2) implementing the collection and analysis of 

available data to support managers’ efforts to prevent, 

detect and respond to fraud risks; 3) conducting 

ongoing monitoring, audit and evaluations over fraud 

prevention, detection and response activities; and 

4) incorporating fraud risk management into the 

broader ERM framework 

• As a follow up to the work of the Fraud Risk Register 

Work Group in 2019, the Fraud Risk Coordinator 

performed data analyses of the internal controls over 

fraud in two fraud prone areas within the federal 

government 

o Monitoring of controls over the GSA 

Purchase Card Program, for high-risk 

purchases including those with items or 

merchant category codes normally prohibited, 

and purchases which require special 

authorizations/approvals 

o Monitoring of controls over payment of 

reimbursable travel benefits for indirect 

travel, where the federal traveler is either not 

traveling from or returning to their permanent 

duty station 

• The ERM program’s annual financial process 

assessment also confirmed the remediation of 

previously documented control weaknesses presenting 

vulnerabilities to fraud These included:

o The successful implementation of new cash 

management policies/procedures eliminating 

programs annually handling of more than 

$2 million of cash instruments during the 

collections process Cash collections are now 

delivered directly to the point of deposit 

o The successful strengthening of time and 

attendance approval processes to assure 

supervisor’s reliable certification of employee 

timesheets This has eliminated frequent 

overrides of that control 

During 2020, the ERM Program financial process 

assessments identified and tested controls that prevent 

and detect fraud in the following processes: Financial 

Reporting, Court Ordered Collections, Pre Merger 

Revenue, and Procure to Pay Additionally, the ERM 

Program conducted an assessment of controls over 

the Hart-Scott-Rodino Report to Congress (ICOR 

Assessment) which identified and tested controls that 

would prevent or detect improper external performance 

and compliance reporting 

Due to constraints on administrative capacity related 

to the global pandemic, the Fraud Risk Register 

Work Group did not meet in 2020 During 2021, 

FTC plans to strengthen and extend agency level 

fraud risk management and monitoring by leveraging 

its cross-programmatic Fraud Risk Register Work 

Group, increasing data collection and analysis, 

conducting additional audit and evaluations to identify 

vulnerabilities, and coordinating all of these activities 

within the overall ERM framework 

REAL PROPERTY

The FTC’s Office of the Chief Administrative Services 

Officer (OCASO) is responsible for managing the 

agency’s real property, which primarily consists of leased 

space and leasehold improvements OCASO ensures that 

the agency optimizes its space in order to cost efficiently 

achieve the agency’s mission The General Services 

Administration publishes real property data annually in 

the Federal Real Property Profile Management System 

Government-wide real property data are available to the 

public on the GSA’s website 
OTHER INFORMATION

94 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

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 are 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

The Clayton Act Section 7A(g)(1)

15 U.S.C 18a(g)(1)

premerger filing 

notification 

violations

1976 January 14, 2020 $ 43,280 BC Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Clayton Act Section 11(l)

15 U.S.C. 21(l)

Violations of 

cease and desist 

orders

1959 January 14, 2020 $ 22,994 BC Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The FTC Act Section 5(l)

15 U.S.C. 45(l)

unfair or 

deceptive acts 

or practices

1973 January 14, 2020 $ 43,280 BC and 

BCP

Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The FTC Act Section 5(m)(1)(A)

15 U.S.C. 45(m)(1)(A)

unfair or 

deceptive acts 

or practices

1975 January 14, 2020 $ 43,280 BC and 

BCP

Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The FTC Act Section 5(m)(1)(B)

15 U.S.C. 45(m)(1)(B)

unfair or 

deceptive acts 

or practices

1975 January 14, 2020 $ 43,280 BC and 

BCP

Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The FTC Act Section 10

15 U.S.C. 50

Failure to file 

required reports

1914 January 14, 2020 $ 569 BC and 

BCP

Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Webb-Pomerene 

(Export Trade) Act Section 

5 15 U.S.C. 65

Failure to 

file required 

statements

1918 January 14, 2020 $ 569 BC Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Wool Products Labeling Act 

Section 6(b) 15 U.S.C. 68d(b)

Failure to 

maintain 

required records 

1940 January 14, 2020 $ 569 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Fur Products Labeling Act 

Section 3(e)

15 U.S.C. 69a(e)

Failure to 

maintain 

required records 

1951 January 14, 2020 $ 569 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016
OTHER INFORMATION

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 95

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

The Fur Products Labeling Act 

Section 8(d)(2)

15 U.S.C. 69f(d)(2)

Failure to 

maintain 

required records 

1951 January 14, 2020 $ 569 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Energy Policy and 

Conservation Act

Section 333(a) 42 U.S.C. 6303(a)

Knowing 

violations

1975 January 14, 2020 $ 468 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Energy Policy and 

Conservation Act

Section 525(a) 42 U.S.C. 6395(a)

Recycled 

oil labeling 

violations

1975 January 14, 2020 $ 22,994 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Energy Policy and 

Conservation Act

Section 525(b) 42 U.S.C. 6395(b)

Willful violations 1975 January 14, 2020 $ 43,280 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Fair Credit Reporting Act 

Section 621(a)(2)

15 U.S.C. 1681s(a)(2)

Knowing 

violations

1996 January 14, 2020 $ 4,063 BCP Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Medicare Prescription Drug 

Improvement and Modernization 

Act of 2003 Public Law 108-173 

Section 1115(a) 21 U.S.C. 355 note

Non-compliance 

with filing 

requirements

2003 January 14, 2020 $ 15,301 BC Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016

The Energy Independence and 

Security Act of 2007 Section 814(a) 

42 U.S.C. 17304

Market 

manipulation 

or provision 

of false 

information to 

federal agencies

2007 January 14, 2020 $ 1,231,690 BC Federal Register 

Vol.85, January 

14, 2020, pages 

2014-2016
Appendices
APPENDICES
98 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

APPENDICES

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

ACT Alimentation Couche-Tard Inc.

AFR Agency Financial Report 

APP Annual Performance Plan 

APR Annual Performance Report 

ARC Administrative Resource Center

ATO Authorized To Operate

ATU Authorization to Use

BC Bureau of Competition 

BCP Bureau of Consumer Protection 

CAPL CrossAmerica Partners LP

CEAR Certificate of Excellence in Accountability Reporting

CFO Chief Financial Officer

COPA Certificates of Public Advantage

COPPA Children’s Online Privacy Protection Act 

CSRS Civil Service Retirement System 

DNC Do Not Call 

DOJ Department of Justice 

DOL Department of Labor 

DOT Department of Transportation

DQA Data Quality Appendix

ERM Enterprise Risk Management 

FASAB Federal Accounting Standards Advisory Board 

FBwT Fund Balance with Treasury 

FECA Federal Employees’ Compensation Act 

FEVS Federal Employee Viewpoint Survey

FedRAMP Federal Risk and Authorization Management Program 

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

FFMIA Federal Financial Management Improvement Act of 1996

FISMA Federal Information Security Management Act 

FMFIA Federal Managers’ Financial Integrity Act 

FMO Financial Management Office 

FRDAA Fraud Reduction Data Analytics Act

FTC Federal Trade Commission 

FTE Full-Time Equivalent 
APPENDICES

www.ftc.gov | Fiscal Year 2020 | Federal Trade Commission | Agency Financial Report 99

Acronym Definition

FY Fiscal Year 

GAAP Generally Accepted Accounting Principles 

GAO Government Accountability Office 

GSA General Services Administration 

HSR Hart-Scott-Rodino Act 

IBC Department of the Interior Business Center 

ICN International Competition Network

ICOR Internal Control Over Reporting

IG Inspector General 

IPERIA Improper Payments Elimination and Recovery Improvement Act 

IRS Internal Revenue Service

ISP Internet Service Provider

IT Information Technology 

NIST National Institute of Standards and Technology 

OBI Oracle Business Intelligence

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

PIO Performance Improvement Officer 

PMRO Performance Measure Reporting Official 

PP&E Property, Plant, and Equipment 

PPE Personal Protective Equipment

SAT Senior Assessment Team 

SBR Statement of Budgetary Resources 

SMC Senior Management Council

SSAE Statement on Standards for Attestation Engagements 

SSP Shared Service Provider

TAS Treasury Account Symbol 

TED Technology Enforcement Division

TSP Thrift Savings Plan

VOIP Voice Over Internet Protocol
100 Agency Financial Report | Federal Trade Commission | Fiscal Year 2020 | www.ftc.gov

APPENDICES

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: Molly Crawford and Vanessa Schlueter of the Office of the Chairman; George Adam, Chris 

Bryan, Monique Fortenberry, Kathryn Gillis, James Hale, Lonnie Johnson, Qi Li, Leonard Nadybal, Joseph O’Leska, 

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; Philip Runco and Catherine Wayne of the Office of Congressional 

Relations; Mary Harmison and Andrew Katsaros of the Office of the Inspector General; Russell Damtoft and Kristina 

Mulligan of the Office of International Affairs; Sarah Mackey of the Office of Policy Planning; and 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 

/FTCvideos

/federaltrade 

commission @FTC ftc.gov

www.ftc.gov