FISCAL YEAR 2017
FEDERAL TRADE COMMISSION
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 3

TABLE OF CONTENTS

INTRODUCTION 5

About This Report 7

How This Report Is Organized 8

The FTC At-A-Glance 9

Message from the Chair 10

MANAGEMENT’S DISCUSSION AND ANALYSIS 13

Agency and Mission Information 15

Performance Highlights 20

Management Assurances 32

Forward Looking Information 36

Financial Highlights 37

FINANCIAL SECTION 49

Message from the Chief Financial Officer 51

Inspector General’s Transmittal Letter for Audit Report 52

Report of Independent Auditors 53

Principal Financial Statements 59

Notes to the Financial Statements 65

OTHER INFORMATION 85

Summary of Financial Statement Audit and Management Assurances 87

Summary of the Top Management and Performance Challenges 

Identified by the Office of Inspector General 88

Payment Integrity 90

Civil Monetary Penalty Adjustment for Inflation Implementation Reporting Act Details 91

APPENDICES 93

Appendix A: Acronyms 95

Appendix B: Contact Information and Acknowledgements 97
FEDERAL TRADE COMMISSION
INTRODUCTION

FISCAL YEAR 2023
FEDERAL TRADE COMMISSION
INTRODUCTION

FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 7

ABOUT THIS REPORT

The Federal Trade Commission’s (FTC) fiscal year (FY) 2023 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 2023 APR will be combined

with the FY 2025 Annual Performance Plan (APP) and included in the FY 2025 Congressional Budget Justification

The combined APP and APR will be available at https://www.ftc.gov/about-ftc/budget-strategy/budgetperformance-financial-reporting along with other performance document

CERTIFICATE OF 

EXCELLENCE

The FTC received the Association of 

Government Accountants’ Certificate 

of Excellence in Accountability 

Reporting for its FY 2022 AFR. The

FY 2022 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 2022

presented to the

Ann M. Ebberts, MS, PMP

Chief Executive Officer, AGA

Andrew Lewis, CGFM, CPA

Chair, CEAR Board

Federal Trade Commission

Certificate of Excellence in

Accountability Reporting®

BEST-IN-CLASS AWARD

in the Agency Financial Report for fiscal year 2022

in recognition of

presented to the

Ann M. Ebberts, MS, PMP

Chief Executive Officer, AGA

Andrew Lewis, CGFM, CPA

Chair, CEAR Board

Federal Trade Commission

understandable financial statement footnotes
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

INTRODUCTION

8

APPENDICES

FISCAL YEAR 2023

OTHER

INFORMATION

FISCAL YEAR 2023

FISCAL YEAR 2023

FINANCIAL

SECTION

HOW THIS REPORT IS ORGANIZED

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

supplemental appendices

1. MANAGEMENT’S DISCUSSION AND ANALYSIS

The Management’s Discussion and Analysis is required supplementary information 

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

information. This section includes agency mission and organization, performance

goals and highlights, management assurances on internal controls, and financial 

highlights

2. FINANCIAL SECTION

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

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

accompanying notes

3. OTHER INFORMATION

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

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

management assurances, payment integrity information, and a schedule of civil 

monetary penalties’ adjustments for inflation

4. APPENDICES

Appendix A lists the acronyms cited throughout this report. Appendix B provides

contact information and acknowledgements

FISCAL YEAR 2023

MANAGEMENT’S

DISCUSSION 

AND ANALYSIS
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 9

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. Example

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 80 other laws

PROFILE 

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

n The agency’s estimated full-time equivalent utilization in FY 2023 was 1,217

n Total new budget authority for FY 2023 was $430 million, which included $70 million in general fund 

appropriations and $360 million in spending authority from offsetting collections

HEADQUARTERS 

The FTC established its headquarters at 600 Pennsylvania Avenue, N.W., with President Franklin D. Rooseve

laying the cornerstone himself. Roosevelt remarked, “May this permanent home of the Federal Trade Commission

stand for all time as a symbol of the purpose of the government to insist on a greater application of the golden 

rule to conduct the corporation and business enterprises in their relationship to the body politic.” Listen to

Franklin D. Roosevelt’s speec

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.
10 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MESSAGE FROM THE CHAIR

Congress created the FTC to protect Americans from unlawful business 

practices and to foster a vibrant economy fueled by fair competition and 

an empowered, informed public. In fiscal year 2023, the FTC continued

prioritizing vigorous enforcement while also finding efficiencies to help us 

stretch our scarce resources

On the consumer protection side, the agency continued to fight fraud and 

deception in the marketplace. This year, the FTC joined more than 100 federal and

state law enforcement partners in Operation Stop Scam Calls, which included five 

new FTC actions against illegal telemarketing calls, as well as 180 enforcement 

actions brought by our partners. The FTC also secured its largest penalty ever

awarded for violation of an FTC rule against Epic Games. In total, the agency filed

43 complaints in federal district court, obtained 61 permanent injunctions, and 

returned $285.4 million in redress from defendants to consumers. That amount o

redress is especially significant given that the FTC can no longer use Section 13(b) 

of the FTC Act to obtain monetary redress and disgorgement. This legal authority

had previously been the primary tool that the Commission used to return money to 

consumers.

On the competition side, we have moved to challenge major unlawful deals 

and anticompetitive conduct in critical sectors of the economy, including 

pharmaceuticals, healthcare, energy, mortgage technology, industrial goods, and 

payment networks. The Commission also took a series of actions challenging

noncompete provisions in employment contracts, which harm workers, consumers, 

and competition. In addition, the FTC brought 23 competition enforcement actions

during the year. In six of those matters, the agency initiated federal court or

administrative litigation. In the other 17 matters, the Commission issued consent

orders to remedy harm to consumers, or the parties abandoned or restructured 

their transactions in response to the Commission’s investigation

Outside of law enforcement, the agency proposed a rule in January that would 

eliminate noncompete clauses from employment contracts. Our proposal follows

extensive research showing that noncompete clauses harm competition in labor 

markets, creating mismatches between workers and firms and depressing wages 

even for those workers not directly covered by noncompete clauses. In July, we

published a draft revision of the merger guidelines, the enforcement manual that 

Lina M. Khan

Chair
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 11

MESSAGE FROM THE CHAIR

the FTC and Justice Department use to analyze deals. Informed by over 5,000 public comments and several listening

sessions with market participants across the country, the updates are designed to reflect the realities of how businesses 

grow and compete in today’s economy

FINANCIAL MANAGEMENT 

The FTC takes very seriously its commitment to responsibly stewarding public resources entrusted to the agency by 

American taxpayers and Congress. The agency’s FY 2023 independent financial audit yielded our 27th 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. 33

MANAGEMENT AND PERFORMANCE CHALLENGES 

The Office of Inspector General (OIG) identified four management and performance challenges this year: (1) securing 

information systems and networks from destruction, data loss, or compromise; (2) addressing challenges to FTC 

litigation; (3) successfully managing merger transactions; and (4) combatting increasingly sophisticated imposter scams 

and enhancing the public’s awareness of them. In addition, the OIG highlighted the FTC’s oversight of the Horseracing

Integrity and Safety Authority as a “watch list” item that, while not a serious management challenge, still requires attention

Agency management agrees that these are important challenges and concurs with the IG’s assessment of our progress in 

addressing these challenges (see p. 88)

The Commission is committed to vigorously enforcing the law to protect all Americans and to working with federal and 

state government partners to deliver on the FTC’s mandate

Lina M. Khan, Chair 

November 15, 2023
FEDERAL TRADE COMMISSION
FISCAL YEAR 2023

MANAGEMENT’S

DISCUSSION 

AND ANALYSIS
FEDERAL TRADE COMMISSION
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 15

MANAGEMENT’S DISCUSSION AND ANALYSIS

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 th

world. The FTC performs its mission using 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 fueled by fair competition and an 

empowered, informed public.

MISSION 

Protecting the public from deceptive or unfair business 

practices and from unfair methods of competition 

through law enforcement, advocacy, research, and 

education

WHAT WE DO 

Our work to protect consumers and 

promote competition touches the economic 

life of every American. We are the only federa

agency that deals with consumer protection and 

competition issues in broad sectors of the economy

Every day we:

n Pursue strong and effective law 

enforcement against deceptive, unfair, and 

anticompetitive business practices; 

n Create and share practical, plainlanguage educational programs 

for consumers and businesses; 

n Advance consumers’ interests by sharing 

our expertise with federal and state legislatures 

and U.S. and international government agencies

n Develop policy and research tools 

through workshops conferences, and hearings

OUR ORGANIZATION 

The FTC is headed by a Commission composed of 

five Commissioners, nominated by the President and 

confirmed by the Senate, each serving a staggered 

seven-year term. No more than three Commissioners

may be from the same political party. The President

designates one Commissioner to act as Chair who is 

given the responsibility for the administration of the 

Commission.Lina M. Khan was sworn in as Chair on

June 15th, 2021. The two current Commissioners are

Rebecca Slaughter and Alvaro Bedoya.

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

The Bureau of Competition (BC) seeks to prevent 

anticompetitive mergers and other anticompetitive 

business practices in the marketplace. By enforcing

the antitrust laws, the Bureau promotes competition 

and protects consumers' freedom to choose goods 

and services in an open marketplace at a price and 

quality that fit their needs

The Bureau of Consumer Protection's (BCP) mandate 

is to protect consumers against unfair, deceptive or 

fraudulent practices. The Bureau enforces a variety

of consumer protection laws enacted by Congress, 

as well as trade regulation rules issued by the 

Commission. Its actions include individual company

and industry-wide 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
16 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

The work of the bureaus is aided by several 

additional offices: 

The Regional Offices work with the Bureaus of 

Competition and Consumer Protection to conduct 

investigations and litigation, provide advice to state 

and local officials on the competitive implications of 

proposed actions, recommend cases, provide local 

outreach services to consumers and businesspersons, 

and coordinate activities with local, state, and regional 

authorities

The Office of Congressional Relations works closely 

with members of Congress and their staffs. The office

informs Commissioners and FTC staff of Capitol Hill 

issues and policies, and helps provide information 

on legislation of interest to the Commission. It also

coordinates the preparation of both Congressional 

testimony and responses to Congressional inquiries 

concerning FTC policies and programs

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

educate, and engage consumers and businesses 

through media and digital technologies and in 

collaboration with our internal partners to advance 

consumer protection and competition. The office is the

primary point of contact for all news media inquiries

The Office of the Chief Privacy Officer manages the 

FTC’s internal privacy program and is responsible 

for ensuring that the Commission complies with all 

applicable privacy laws and guidance. The Office of

the Chief Privacy Officer identifies the privacy risks, 

controls, and mitigating solutions when making 

decisions involving the collection, use, sharing, 

retention, disclosure and destruction of personally 

identifiable information. It is also responsible for

investigating and mitigating privacy incidents, 

supporting the FTC mission with an evolving privacy 

program, and promoting a culture of privacy among 

FTC staff, contractors, and third parties

The Office of Policy Planning assists the Commission 

to develop and implement long-range competition 

and consumer protection policy initiatives and advises 

staff on cases raising new or complex policy and legal 

issues. One of the Office of Policy Planning's primary

roles involves advocacy, submitting filings supporting 

competition and consumer protection principles to 

state legislatures, regulatory boards, and officials; 

state and federal courts; other federal agencies; and 

professional organizations. The Office also organizes

public workshops and issues reports on cuttingedge competition and consumer protection topics, 

addressing questions of substantive antitrust law, 

industry-specific practices, and significant national and 

international policy debates.

The Office of International Affairs leads and 

coordinates the FTC’s work in international antitrust, 

consumer protection, and technical assistance 

projects. The FTC works with competition and

consumer protection agencies around the world to 

promote cooperation and convergence toward best 

practices.

Rebecca Kelly 

Slaughter

Commissioner

Sworn in: May 2, 2018

Lina M. Khan

Chair

Sworn in: June 15, 2021

Alvaro Bedoya

Commissioner

Sworn in: May 16, 2022
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 17

MANAGEMENT’S DISCUSSION AND ANALYSIS

The Office of the Secretary oversees prompt 

processing of all matters presented to the 

Commission, supports the Commission decisionmaking process, and ensures it operates efficiently

The office also responds to most Congressional and 

White House correspondence raising constituent 

issues

The Office of Technology assists the Commission 

by strengthening and supporting law enforcement 

investigations and actions, advising and engaging with 

FTC staff and the Commission on policy and research 

initiatives, and engaging with the public and relevant 

experts to understand trends and to advance the 

Commission’s work.

The Office of the General Counsel is the Commission's 

chief legal officer and adviser. The office represents

the Commission in court and provides legal counsel to 

the Commission, the three bureaus, and other offices

The Office of the Executive Director is responsible 

for the administration and management of the 

Commission through four organizations, which 

manage the Commission’s human capital, information 

technology, financial management, 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 Workplace Inclusivity and Opportunity

ensures that the Federal Trade Commission maintains 

a work environment that is free from all forms of illegal 

discrimination, including reprisal and harassment, and 

processes complaints of discrimination

For more information about the agency’s components, 

visit the FTC’s Bureaus and Offices webpage
18 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

FEDERAL TRADE COMMISSION ORGANIZATIONAL CHART

Office of the

Executive Director

David B Robbins

Regions

Bureau of

Competition

Henry Liu

Bureau of

Consumer 

Protection

Samuel Levine

Chair

Lina M. Khan

Chief of Staff

Elizabeth Wilkins

Commissioner

Vacant

Office of the

General Counsel

Anisha Dasgupta

Bureau of

Economics

Aviv Nevo

Commissioner

Vacant

Commissioner

Alvaro Bedoya

Office of

Congressional Relations

Jean Bumpus

Office of

Public Affairs

Douglas Farrar

Office of Workplace 

Inclusivity and Opportunity 

Monique Fortenberry

Office of

International Affairs

Maria Coppola

Office of

Policy Planning

Elizabeth Wilkins

Office of Technology 

Stephanie Nguyen

Office of

the Secretary

April Tabor

Office of

Administrative Law Judges*

D. Michael Chappel

Commissioner

Rebecca Kelly 

Slaughter

Office of

Inspector General*

Andrew Katsaros

Office of the Chief 

Privacy Officer 

John Krebs

* An independent organization within the FTC
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 19

MANAGEMENT’S DISCUSSION AND ANALYSIS

The agency is headquartered in Washington, DC, and operates with seven regions across the US, with two 

offices located in the Western Region. The graphic below illustrates the locations of the FTC region

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
20 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

PERFORMANCE HIGHLIGHTS 

The FTC has chosen to produce an AFR and a 

separate Annual Performance Report (APR) for FY 

2023. The APR will be included as part of the FTC’s

Congressional Budget Justification and will also be 

available on the FTC’s website

This section explains the FTC’s strategic and 

performance planning framework and summarizes 

the key performance goals. The performance results

described in this report enable the FTC to administer 

its programs, gauge their success, and make 

adjustments necessary to improve program quality for 

the public.

STRATEGIC AND PERFORMANCE 

PLANNING FRAMEWORK 

The FTC’s Annual Performance Report is structured 

around three strategic goals and supporting 

objectives as established in the FTC Strategic Plan 

FY 2022-2026. The FTC’s strategic goals, objectives,

strategies, and performance metrics articulate what 

the agency intends to accomplish to meet its mission, 

demonstrate the highest standards of stewardship, 

and improve the management functions vital to core 

mission success

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

strategic goals

STRATEGIC GOALS OBJECTIVES

GOAL 1: Protect the public from unfair 

or deceptive acts or practices in the 

marketplace.

Net Costs: $203 million*

*$218 million in costs 

- $15 million in revenue

 $203 million

1.1 Identify, investigate, take actions against, and deter unfair or 

deceptive acts or practices that harm the public. 

1.2 Connect with individuals, communities, and businesses 

to provide practical knowledge, guidance, and tools, and to 

learn about key challenges and opportunities for future FTC 

engagement. 

1.3 Collaborate with domestic and international partners to 

enhance consumer protection. 

1.4 Support equity for historically underserved communities 

through the FTC’s consumer protection mission. 

GOAL 2: Protect the public from 

unfair methods of competition in 

the marketplace and promote fair 

competition.

Net Costs: $27 million*

*$200 million in costs 

- $173 million in revenue

 $27 million

2.1 Identify, investigate, and take actions against anticompetitive 

mergers and business practices. 

2.2 Engage in research, advocacy, and outreach to promote public 

awareness and understanding of fair competition and its benefits. 

2.3 Collaborate with domestic and international partners to check 

unfair methods of competition.

2.4 Support equity for historically underserved communities 

through the FTC’s competition mission. 

GOAL 3: Advance the FTC’s effectiveness 

and performance. 

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

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

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

costs that are clearly attributable to a specific goal.

3.1 Optimize resource management, space, and administrative 

programs. 

3.2 Cultivate a high-performing, diverse, inclusive, and engaged 

workforce. 

3.3 Optimize information management.

Note: Net Costs represent the resources used to achieve strategic goals and signify the relative efficiency and costeffectiveness of agency programs/operations. The FTC does not divide net costs by objectiv
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 21

MANAGEMENT’S DISCUSSION AND ANALYSIS

PERFORMANCE MEASUREMENT 

REPORTING PROCESS 

Bureau and Office representatives serve as 

Performance Measure Reporting Officials (PMROs), 

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

publicly-reported performance metrics. 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 metric 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 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 reporting 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 and 

details 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 Strategic Plan FY 2022-2026, the FTC has 

established 43 performance metrics and targets for 

assessing program performance against agency 

strategic goals and objectives. This report documents

the performance of six of those metrics, which may 

be considered key performance metrics 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 2023 against established targets for the 

FTC’s seven key performance metrics. 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 2023 targets on five key performance 

metrics, did not meet the target on one metric, and did 

not have a target on one metric

LEGEND FOR UPCOMING TABLES 

✔ Signifies that the target was met or exceeded 

X Signifies that the target was not met 
22 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

STRATEGIC GOAL 1: PROTECT THE PUBLIC FROM UNFAIR OR DECEPTIVE 

ACTS OR PRACTICES IN THE MARKETPLACE. 

The FTC uses a multi-pronged interdisciplinary approach to protect the public from unfair and deceptive 

practices in the marketplace. The FTC conducts investigations, sues companies and people that violate the

law, develops rules to protect the public, and educates consumers and businesses about their rights and 

responsibilities. The agency also collects reports about a host of consumer issues, including fraud, identity theft,

financial matters, and Do Not Call violations. The FTC makes these reports available to law enforcement agencies

worldwide

METRIC 1.1.1: Amount of money returned to the public or forwarded to the U.S. Treasury 

resulting from FTC enforcement actions.

Description: This metric 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 w

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 usef

indicator that the FTC is targeting the right defendants

1

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023

Target

FY 2023

Status

$971.1 

million $5.65 billion $562.1 million 

$639.8 

million

$342.1 

million $65 million ✔

Note on Metric 1.1.1: The FTC formerly reported these numbers as a three-year rolling average. The

results for each fiscal year are now being reported without averaging. The amount of money returned

to the public and the U.S. Treasury has declined in recent years in part due to the Supreme Court’

2021 decision in AMG Capital Management v. FTC, which held that the FTC does not have the ability

to obtain monetary relief pursuant to Section 13(b) of the FTC Act. For further discussion, see the OIG’s

second management challenge on page 88.

1 Calculation/Formula: Sum of refund payments issued by the FTC and cashed by consumers, plus the amount of redress payments 

issued to consumers by defendants and third parties, 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 penal

OPERATION STOP SCAM CALLS 

The FTC and more than 100 federal and state law enforcement partners 

nationwide, including the attorneys general from all 50 states and the District 

of Columbia, announced a new crackdown on illegal telemarketing calls

involving more than 180 actions targeting operations responsible for billions of 

calls to U.S. consumers. The joint federal and state initiative, “Operation St

Scam Calls,” is part of the Commission’s ongoing efforts to combat the scourge 

of illegal telemarketing, including robocalls. The initiative not only targets

telemarketers and the companies that hire them but also takes action against 

lead generators who deceptively collect and provide consumers’ telephone 

numbers to robocallers and others, falsely representing that these consumers 

have consented to receive calls. The effort also targets Voice over Internet

Protocol (VoIP) service providers who facilitate illegal robocalls, which often originate overseas
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 23

MANAGEMENT’S DISCUSSION AND ANALYSIS

METRIC 1.1.2: Total consumer savings compared to the amount of FTC resources allocated to 

consumer protection law enforcement.

Description: This metric 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

2

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023

Target

FY 2023

Status

$13.00 in 

consumer 

savings per 

$1 spent 

$12.70 in 

consumer 

savings per 

$1 spent 

$12.90 in 

consumer 

savings per 

$1 spent 

$9.40 in 

consumer 

savings per 

$1 spent 

$7.10 in 

consumer 

savings per 

$1 spent 

$7.00 in 

consumer 

savings per 

$1 spent 

✔

Note on Metric 1.1.2: The FTC formerly reported these numbers as a three-year rolling average. The results for

each fiscal year are now being reported without averaging. The amount of consumer savings has declined in

recent years in part due to the Supreme Court’s 2021 decision in AMG Capital Management v. FTC, which held that

the FTC does not have the ability to obtain monetary relief pursuant to Section 13(b) of the FTC Act. For further

discussion, see the OIG’s second management challenge on page 88

2 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 is 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 is 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 are 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
24 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

PROTECTING CONSUMERS FROM NON-CONSENSUAL SUBSCRIPTIONS AND FROM 

VIOLATIONS OF THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT RULE 

The FTC filed a complaint charging Amazon.com with engaging

in a years-long effort to enroll consumers into its Prime program 

without their consent while knowingly making it difficult for 

consumers to cancel their subscriptions to Prime. The FTC alleges

that Amazon has knowingly duped millions of consumers into 

unknowingly enrolling in automatically-renewing Amazon Prime 

subscriptions by using manipulative, coercive, or deceptive userinterface designs known as “dark patterns.” The FTC also alleges

that consumers who attempted to cancel Prime were faced with 

multiple obstacles to actually accomplish the task of cancelling

In another law enforcement action against Amazon.com, the

company has agreed to pay a $25 million civil penalty, overhaul 

its deletion practices, and implement stringent privacy safeguards 

in order to settle charges that the company violated the Children’s Online Privacy Protection Act Rule 

(COPPA Rule) and deceived parents and users of the Alexa voice assistant service about its data deletion 

practices. According to the complaint filed by the DOJ on behalf of the FTC, Amazon prevented parents from

exercising their deletion rights under the COPPA Rule, kept sensitive voice and geolocation data for years, 

and used it for its own purposes, while putting data at risk of harm from unnecessary access

FORTNITE VIDEO GAME MAKER EPIC GAMES TO PAY MORE THAN HALF A 

BILLION DOLLARS 

The FTC secured agreements requiring Epic Games, creator 

of the popular video game Fortnite, to pay a total of $520 million 

in relief over allegations the company violated the Children’s 

Online Privacy Protection Act (COPPA) and deployed design tricks, 

known as dark patterns, to dupe millions of players into making 

unintentional purchases. The FTC’s action against Epic involves

two separate record-breaking settlements. As part of a proposed

federal court order filed by DOJ on behalf of the FTC, Epic will 

pay a $275 million monetary penalty for violating the COPPA Rule, 

which is the largest penalty ever obtained for violating an FTC rule

Additionally, in a first-of-its-kind provision, Epic will be required 

to adopt strong privacy default settings for children and teens, 

ensuring that voice and text communications are turned off by 

default. Under a separate administrative order, Epic will pay $245 million to refund consumers for its dark

pattern and billing practices, which is the FTC’s largest refund amount in a gaming case.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 25

MANAGEMENT’S DISCUSSION AND ANALYSIS

REPORT ON CONSUMER ISSUES AFFECTING AMERICAN INDIAN AND ALASKA 

NATIVE COMMUNITIES 

The FTC engaged in national outreach and education efforts to gain a 

broader understanding of the particular consumer protection challenges 

American Indian and Alaska Native (AI/AN) communities experience 

and how the FTC may work to further support these communities. This

effort included listening to and collaborating with sources trusted in AI/

AN communities as well as analyzing consumer reports from AI/AN 

individuals to the FTC. The Consumer Issues Affecting American Indian

and Alaska Native Communities Report, submitted to Congress in March 

2023, provides details on the consumer issues identified through these 

efforts. The report includes a summary of some of the numerous law

enforcement actions and recent notices of proposed rulemaking relating 

to consumer abuses identified as impacting AI/AN communities. The

report also describes the FTC’s actions to better reach and respond 

to the needs of AI/AN populations, including launching ftc.gov/NativeAmerican, a website that serves a

landing page for consumer and business education resources related to the topics identified in the report.

A Report to Congress

March 15, 2023

Consumer Issues

Affecting American Indian

and Alaska Native

Communities

METRIC 1.2.1: Rate of consumer satisfaction with FTC consumer education websites. (a) 

Mobile; (b) Desktop.

Description: Consumer and business education serves as an important and vital resource in fighting against 

deception and unfair practices. Well-informed consumers are better able to recognize and report fraud, and

well-informed business owners know where the FTC draws the line. This metric gauges the effectiveness,

helpfulness, and usability of the FTC’s consumer education website and includes the customer satisfaction 

scores for consumer.ftc.g

3

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023

Target

FY 2023

Status

(a) N/A

(b) 77.7 

(a) N/A 

(b) 76.2 

(a) N/A 

(b) 72.9

(a) 73.5 

(b) 73.4 

(a) 73.4 

(b) 74.9 

Average 

satisfaction 

rate = 

(a) 72.1 

(b) 69.7 

✔

3 Calculation/Formula: When visiting consumer.ftc.gov consumers are given the option to complete a short survey to provid

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 ForeSe
26 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

STRATEGIC GOAL 2: PROTECT THE PUBLIC FROM UNFAIR METHODS 

OF COMPETITION IN THE MARKETPLACE AND PROMOTE FAIR 

COMPETITION. 

The FTC’s efforts to prevent and police unfair methods of competition focus on preventing anticompetitive 

mergers and business practices through enforcement. The FTC also engages in policy research and

development, advocacy, and education to deter anticompetitive practices and encourage federal, state, and 

local governments to evaluate the effects of their policies on fair competition. The FTC advances these goals

internationally by fostering enforcement and policy convergence and through case cooperation with counterpart 

foreign enforcement authorities. This work is critical to protect and strengthen free and open markets – the

cornerstone of a vibrant economy

METRIC 2.1.1: Total consumer savings and other measurable benefits generated by antitrust 

enforcement.

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

taking action against potentially anticompetitive mergers and business conduct. The number reported is a fiveyear “rolling average” (average of the current year and four prior year totals

4

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023

Target

FY 2023

Status

$4.87 billion $2.68 billion $2.84 billion $3.19 billion $3.14 billion $2.40 billion ✔

4 Calculation/Formula: 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 in the relevant geographic/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 and nonmerger activity in 

that year

FTC SETTLES WITH SURESCRIPTS IN ILLEGAL MONOPOLIZATION CASE 

In July 2023, the FTC filed a stipulated order to settle charges

that health information technology company Surescripts engaged 

in exclusionary conduct to maintain a monopoly in violation of the 

antitrust laws. The proposed order, filed with the federal court,

resolves the FTC’s pending action against Surescripts, after the 

district court granted the FTC’s motion for partial summary judgment 

and encouraged the parties to engage in settlement discussions

According to the FTC’s April 2019 complaint, Surescripts employed 

illegal vertical and horizontal restraints in order to maintain its 

monopoly of the routing and eligibility of e-prescribing markets

These markets involve technology used by physicians to route 

electronic prescriptions and health care providers to electronically 

determine patient eligibility and insurance coverage, respectively. The order prohibits Surescripts from

imposing loyalty or exclusivity requirements on its routing and eligibility customers, including through allunit discounting, and bars the company from using non-compete agreements with employees that would 

prevent them from working for a competitor
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 27

MANAGEMENT’S DISCUSSION AND ANALYSIS

METRIC 2.1.2: Total consumer savings and other measurable benefits generated by antitrust 

enforcement compared to resources spent.

Description: This metric reports the estimated consumer savings and other measurable benefits that the 

Commission saved consumers by taking action against potentially anticompetitive mergers and business 

conduct compared to the amount spent on the merger and nonmerger programs. The amount reported is a

five-year “rolling average” (average of the current year and four prior year totals)

5

FY 2019 

Actual

FY 2020 

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023

Target

FY 2023

Status

$66.00 in 

consumer 

savings per 

$1 spent 

$34.40 in 

consumer 

savings per 

$1 spent 

$35.50 in 

consumer 

savings per 

$1 spent 

$38.20 in 

consumer 

savings per 

$1 spentt

$34.10 in 

consumer 

savings per 

$1 spent 

$35.00 in 

consumer 

savings per 

$1 spent 

X

5 Calculation/Formula: Estimated consumer savings generated under metric 2.1.2 are divided by the amount of resources spen

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 

and nonmerger activity in that year

ENSURING COMPETITION IN MORTGAGE TECHNOLOGY MARKETS

The FTC approved a settlement to resolve antitrust 

concerns surrounding Intercontinental Exchange’s 

(ICE) proposed $13.1 billion acquisition of Black Knight. 

ICE and Black Knight are the nation’s two largest 

providers of home mortgage loan origination systems 

(LOS) and product pricing and eligibility engines (PPE)

The Commission alleged that the original merger 

would drive up costs, reduce innovation, and reduce 

lenders’ choices. LOS software is used to manage

the documents and workflow required to generate 

a mortgage, and PPE systems are used by lenders 

to obtain the best interest rates for prospective 

homebuyers. ICE’s Encompass LOS competes headto-head with Black Knight’s Empower platforms, and the firms also compete for the sale of a host of related

services, including PPE. The proposed settlement ensures Black Knight’s divestiture of Empower and 

Optimal Blue, two businesses that provide critical services in the mortgage origination process, and secures 

other concessions to promote the success of the divested businesses
28 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

FTC MOVES TO PROTECT WORKERS FROM HARMFUL NONCOMPETE 

RESTRICTIONS 

The Commission issued a series of three orders to 

Ardagh Group, O-I Glass and Anchor Glass Container 

Corp., and a fourth to security services firms Prudential

Security and Prudential Command, forcing each firm 

to drop noncompete restrictions in their employment 

contracts. According to the complaints, the companies

illegally imposed noncompete restrictions on workers in 

positions ranging from security services to manufacturing 

to engineering that barred them from seeking or accepting 

work with another employer or operating a competing 

business after leaving the companies. According to the

FTC’s complaints, these provisions harm workers through 

lower wages, reduced benefits, and less favorable working 

conditions, and harm businesses by limiting available 

labor, preventing competitors from entering or expanding their businesses. Combined, these noncompete

provisions inhibited the employment opportunities of thousands of workers

FTC REQUIRES MASTERCARD TO STOP BLOCKING THE USE OF COMPETING DEBIT 

PAYMENT NETWORKS 

In May 2023, the FTC approved a final order ending the 

illegal business tactics Mastercard employed to force 

merchants to route debit card payments through its 

payment network and requiring Mastercard to stop blocking 

the use of competing debit payment networks. Debit card

payment networks are used by more than 80 percent of 

American adults and process $4 trillion in purchases each 

year and continue to grow via new payment media such 

as Apple Pay, Google Pay, and Samsung Wallet. These

networks transmit payment information between pointsof-sale and banking institutions, transferring approvals 

or denials back to the merchant. Networks compete for

the business of banks that issue debit cards and for the 

business of merchants who accept debit card payments, 

and charge processing fees for the service. In an effort to

increase competition among these networks, Congress 

enacted the Durbin Amendment to the Dodd-Frank Act in 2010, requiring banks to enable at least two 

unaffiliated networks on every debit card, giving merchants a choice in which network to use for each 

transaction, and barring payment networks from restricting the use of other networks. According to the

complaint, Mastercard set policies that blocked merchants from routing ecommerce transactions using 

Mastercard-branded debit cards saved in e-wallets to alternative payment networks.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 29

MANAGEMENT’S DISCUSSION AND ANALYSIS

METRIC 2.2.2: Number of cases for which Bureau of Economics (BE) economists prepared to 

testify as expert witnesses in FTC antitrust enforcement actions.

Description: This metric is the number of cases for which BE economists (including economists, financial 

analysts, research analysts, statisticians, and other BE staff) prepared to testify as expert witnesses in FTC 

antitrust enforcement actions. This number is a measure of BE expertise developed through economic research

related to competition analysis and represents not only the expertise of the testifying expert, but also the 

expertise of the BE economists and other staff that are supporting that expert

6

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023 

Target

FY 2023

Status

N/A N/A N/A 5 5 Baseline N/A

6 Calculation/Formula: The metric will be calculated as the number of cases during the fiscal year for which a BE economist 

prepared to be a testifying expert for an antitrust enforcement action. The term “BE economist” refers to all BE staff members,

including economists, financial analysts, research analysts, and statisticians

ENSURING COMPETITION IN PHARMACEUTICAL MARKETS 

The FTC approved a settlement with Amgen to address 

the potential competitive harm that would result from 

Amgen’s $27.8 billion acquisition of Horizon Therapeutic

In moving to block the deal, the FTC alleged that the deal 

would allow Amgen to leverage its portfolio of blockbuster 

drugs to entrench the monopoly position of Horizon drugs 

Tepezza and Krystexxa, used in the treatment of thyroid 

eye disease and chronic refractory gout, respectively. The

complaint alleges that Amgen has a history of using rebates 

on its high-volume drugs through cross-market bundling 

which may make it impossible for smaller rivals developing 

competing drugs to compete, discouraging market entry

Under the proposed settlement, Amgen is prohibited from 

bundling an Amgen product with either Tepezza or Krystexxa. In addition, Amgen may not condition any 

product rebate or contract terms related to an Amgen product on the sale or positioning either one of these 

drugs. Amgen also is barred from using any product rebate or contract term to exclude or disadvantage any

product that would compete with Tepezza or Krystexxa. 
30 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

UPDATING THE MERGER GUIDELINES 

Since first releasing merger guidelines in 1968, the DOJ and the 

FTC have updated the merger guidelines a number of times. The

merger guidelines document describes and guides the agencies’ 

review of mergers and acquisitions to determine compliance 

with federal antitrust laws.This year saw the release of a new

draft update of the merger guidelines. The goal of the update

is to better reflect how the agencies determine a merger’s effect 

on competition in the modern economy and evaluate proposed 

mergers under the law. Following the release, a 60-day public

comment period was held, as well as three public workshops. The

agencies are currently reviewing the public feedback

The following thirteen guidelines form the foundation of the draft 

document: 

n Mergers should not significantly increase concentration in 

highly concentrated markets.

n Mergers should not eliminate substantial competition 

between firms.

n Mergers should not increase the risk of coordination.

n Mergers should not eliminate a potential entrant in a concentrated market

n Mergers should not substantially lessen competition by creating a firm that controls products or services 

that its rivals may use to compete

n Vertical mergers should not create market structures that foreclose competition.

n Mergers should not entrench or extend a dominant position

n Mergers should not further a trend toward concentration

n When a merger is part of a series of multiple acquisitions, the agencies may examine the whole series

n When a merger involves a multi-sided platform, the agencies examine competition between platforms, 

on a platform, or to displace a platform

n When a merger involves competing buyers, the agencies examine whether it may substantially lessen 

competition for workers or other sellers

n When an acquisition involves partial ownership or minority interests, the agencies examine its impact on 

competition

n Mergers should not otherwise substantially lessen competition or tend to create a monopoly.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 31

MANAGEMENT’S DISCUSSION AND ANALYSIS

STRATEGIC GOAL 3: ADVANCE THE FTC’S EFFECTIVENESS AND 

PERFORMANCE. 

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

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

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

efficient and more agile agency

Metric 3.2.1: Annual score on the FEVS Employee Engagement Index 

Description: This metric tracks the Employee Engagement Index of the Federal Employee Viewpoint Survey 

(FEVS), an annual survey of federal employees conducted by the Office of Personnel Management. 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 based on

FEVS questions that assess three sub-factors: perceptions of agency leadership, relationships between workers 

and supervisors, and feelings of motivation and competency

7

FY 2019 

Actual

FY 2020

Actual

FY 2021

Actual

FY 2022

Actual

FY 2023

Actual

FY 2023 

Target

FY 2023

Status

84% 87% 74% 74% 79%

Governmentwide 

Average = 

72% 

✔

7 Calculation/Formula: The FEVS Employee Engagement Index measures conditions important to supporting employee 

engagement through responses to 20 questions across the three sub factors. The Office of Personnel Management, which

manages the FEVS, calculates an agency Index score based on responses to these 20 questions

FTC SUES TO BLOCK MERGER BETWEEN HEALTHCARE ADVERTISING RIVALS 

In July 2023, the FTC issued a complaint seeking to block the 

world’s largest health care data provider, IQVIA Holdings, from 

acquiring Propel Media. According to the complaint, the proposed

acquisition would give IQVIA a leading position in the market 

for programmatic advertising for health care products (namely 

prescription drugs) to doctors and other health care professions 

and would incentivize IQVIA to withhold key information to 

discourage entry into the market by potential rival companies. IQVIA

and Propel are two of the top three providers of these services, 

known as demand-side platforms, which specifically target health care professionals with advertising for 

pharmaceutical drugs and other products. The complaint alleges that the proposed deal would eliminate

head-to-head competition between the two firms, driving up prices and reducing quality and choice. This

matter is pending in federal court
32 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

MANAGEMENT ASSURANCES 

IMPLEMENTATION OF THE FEDERAL 

MANAGERS’ FINANCIAL INTEGRITY ACT 

(FMFIA) 

The FTC’s Enterprise Risk Management (ERM) and 

internal controls are integral to managing daily 

operations and carrying out activities that achieve 

strategic goals and objectives. Internal controls

are part of all agency systems and processes

Senior management holds managers accountable 

for documenting, assessing, and improving these 

controls in order to provide efficient and effective risk 

management, program operations, high-quality data, 

and accurate reporting as well as program compliance 

with applicable laws and regulations

The FTC’s Senior Management Council (SMC) 

provides oversight to the Senior Assessment Team 

(SAT) activities and is instrumental in the strategic 

direction and mitigation strategies for the Agency’s 

most significant risks. The SAT plans and executes the

Agency’s enterprise risk and internal control program 

activities to include fraud reduction initiatives. This

includes assessing and improving compliance with 

applicable guidance (e.g., Office of Management an

Budget Circular A-123, Management Responsibilities 

for Enterprise Risk Management and Internal Control), 

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 2023 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 fraud and 

other risks related to successful mission performance

The profile listed risks regarding the FTC’s ability 

to address increasingly sophisticated scam tactics 

against consumers, challenges to FTC litigation which 

reduces the agency’s ability to obtain monetary 

relief for those harmed by deceptive or unfair 

business practices, or unfair methods of competition.

In addition, the profile includes the complexity 

and unpredictable nature of market competition 

investigations requiring expert witnesses, impacts of 

budget constraints as they influence litigation options 

for the consumer protection mission, and the schedule 

risk and cost risk associated with the FTC’s technology 

initiatives to include improving and positioning the 

agency to detect advanced persistent threats to its 

systems and data. Risks related to managing record

and sensitive information along with the volume 

of merger transactions 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 2023 included executing an annual segment of 

the multi-year internal control assessment plan, 

monitoring existing risk registers, identifying and 

analyzing risk, assessing entity level controls, 

and monitoring corrective actions, as well as 

performing 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 FTC 

Chair evaluated several sources of information. These

included results of ERM activities, information from 

independent audits or reviews performed by the Office 

of Inspector General (OIG), (e.g., Federal Informatio

Security Management Act review), the Government 

Accountability Office (GAO), independent audits of 

service providers’ operations and financial systems 

(e.g., reviews conducted in accordance with Statemen

on Standards for Attestation Engagements (SSAE 

No. 18)), and other relevant evaluations and control

assessments

The Chair’s assurance statement below is supported 

by the processes and reviews described above, which 

were performed in FY 2023. Management assurance

tables appear in the Other Information section
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 33

MANAGEMENT’S DISCUSSION AND ANALYSIS

UNITED STATES OF AMERICA

Federal Trade Commission

WASHINGTON, D.C. 20580

Office of the Chair

CHAIR’S FMFIA STATEMENT OF ASSURANCE

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

effective risk management, internal control and financial management systems that meet the objectives

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

In accordance with the requirements of the Office of Management and Budget (OMB) Circular A-123, 

Management’s Responsibility for Enterprise Risk Management and Internal Control, the FTC conducted 

its annual assessment of the effectiveness of the organization’s internal controls to support effective and 

efficient programmatic operations, reliable financial reporting, and compliance with applicable laws and

regulations; and whether the financial management system conforms to applicable financial systems

requirements. 

Based on the results of this assessment, the FTC provides an unmodified assurance that its internal 

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

with applicable laws and regulations as of September 30, 2023, were operating effectively and that no 

material weaknesses were found in the design or operation of our internal controls. Some reporting 

officials identified areas for improvement in their individual assessments, which are being addressed 

internally and are not of a material nature.

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

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

conform with the Federal Financial Management Improvement Act of 1996 (FFMIA), applicable 

financial systems requirements, applicable Federal accounting standards and the U.S. Standard General

Ledger at the transaction level.

Signed 

Lina M. Khan 

Chair

October 31, 2023 
34 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

SUMMARY OF MATERIAL WEAKNESS AND 

NONCONFORMANCES 

As noted in the Chair’s FMFIA Statement of Assurance, 

the FTC had no material weaknesses in internal 

control, material noncompliance with applicable laws 

and regulations, nor substantial nonconformance with 

federal financial management system requirements 

to report for FY 2023. No material weaknesses or

significant nonconformances have been identified, 

nor any existing unresolved weaknesses requiring 

corrective action

FEDERAL INFORMATION SECURITY 

MANAGEMENT ACT (FISMA) 

As mandated by FISMA, the agency continues to 

maintain an effective information security program 

to manage information technology in accordance 

with OMB Circular A-130 requirements and National 

Institute of Standards and Technology (NIST) guidance

The FTC currently has six systems authorized to 

operate (ATO). The FTC leverages twenty-five

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 o

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 Treasur

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 that federal 

agencies automatically pay interest to vendors when 

a payment is not timely and report how much interest 

was paid each year because of late payments. In

FY 2023, the FTC processed 3,254 invoices totaling 

$103.0 million that were subject to prompt paymen

Of these invoices, 99.5 percent were paid on tim

During FY 2023, the FTC paid a total of $732 in interest 

penalties, or 0.000711 percent of the total dollar

amount invoiced

AGENCY FINANCIAL MANAGEMENT 

SYSTEMS STRATEGY 

The FTC’s overall strategy for its financial management 

systems is to ensure that the systems provide 

accurate, reliable, and timely information for 

management decision-making, maintain effective 

internal controls, and comply with applicable laws 

and regulations. It is also critical that the financial

management systems support both operational 

efficiency and effectiveness in meeting the agency’s 

strategic goals.

Through FY 2019, the Department of the Interior’s 

Interior Business Center (IBC) provided financial 

management system services for the FTC. Beginning

in FY 2020, the FTC moved its needs for financial 

management systems and support services to the 

Department of the Treasury’s Administrative Resource 

Center (ARC) to improve operational efficiencies and 

effectiveness. The IBC continues to provide personnel

and payroll support services for the FTC, which it has 

been providing for the agency since 1998

The FTC uses the Oracle Federal Financials (OFF) 

system as its core financial management system 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 35

MANAGEMENT’S DISCUSSION AND ANALYSIS

and the Oracle Business Intelligence (OBI) reporting 

capabilities to produce timely reports that support 

agency requirements. The FTC also uses several

systems that integrate with OFF to support agency 

operations, including the Invoice Processing Platform 

(IPP) for efficient and secure processing of invoices, 

the Concur Government Edition (CGE) to manage 

travel transactions, and the Procurement Information 

System for Management (PRISM) for contract actions.

Since migrating to the new shared services provider, 

the agency continued its efforts to maintain and 

enhance financial management systems to promote 

operational effectiveness, efficiency, reliability, and 

timeliness of data to support the agency’s strategic 

goals. The FTC redesigned and improved several

financial management business processes and 

procedures and developed new tools and reports 

to assess its financial management operations that 

ultimately contribute to its mission success

The FTC recognizes the importance of financial 

management systems and oversight as part of serving 

as a good steward of taxpayer dollars entrusted to it

Accordingly, in FY 2023, the FTC continued to work 

to refine its financial management processes and 

procedures to optimize the performance of operations 

and reporting.

FEDERAL CIVIL PENALTIES INFLATION 

ADJUSTMENT ACT OF 1990 

As established by statutory civil penalty provisions, 

the FTC has jurisdiction to charge civil penalties for 

violations specified in the FTC Act and several other 

laws the Commission is responsible for administering 

and enforcing. The FTC adjusts these civil penalty

amounts for cost of living, as required by Federal Civil 

Penalties Inflation Adjustment Act of 2015

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

authority for the penalty, adjustment dates, and 

current penalty amount can be found in the Other 

Information section of this report

FRAUD REDUCTION DATA ANALYTICS ACT 

The Fraud Reduction and Data Analytics Act of 2015 

was passed to improve federal agency financial and 

administrative controls and procedures to assess and 

mitigate fraud risks, and to improve Federal agencies’ 

development and use of data analytics for the purpose 

of identifying, preventing, and responding to fraud, 

including improper payments.

During FY 2021, the FTC expanded its fraud risk 

program, strengthened the agency’s processes, and 

improved internal controls to prevent, detect, and 

mitigate fraud risks. The FTC continued to expand its

fraud program in FY 2023 and consistently monitors 

how it assesses fraud risk

ANTIDEFICIENCY ACT 

The Antideficiency Act prohibits federal agencies 

from spending or obligating funds in excess of 

amounts and purposes approved by Congress, and 

from accepting voluntary services. The FTC‘s funds

controls and continuing reviews of funds usage and 

availability ensure it complies with requirements of the 

Antideficiency Act.

FTC CONTINUES TO CRACK DOWN ON JUNK FEES AND DISCRIMINATORY 

PRACTICES 

The FTC took action against auto dealer Passport Automotive Group

for deceiving consumers by tacking hundreds to thousands of dollars 

in illegal junk fees onto car prices and for discriminating against Black 

and Latino consumers with higher financing costs and fees. The

FTC’s complaint alleges that Black and Latino consumers paid on 

average about $291 and $235, respectively, more in interest than nonLatino White consumers did. It further alleges that Black and Latino

consumers paid on average an extra fee 24 percent and 42 percent 

more often, respectively, than non-Latino White consumers. Passport,

its president, and its vice president paid more than $3.3 million to settle

the FTC’s lawsuit, which was used to refund consumers harmed by Passport’s conduct
36 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

FORWARD LOOKING INFORMATION 

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

protect the public from deceptive or unfair business 

practices and from unfair methods of competition 

through law enforcement, advocacy, research, and 

education

The FTC recognizes the four Management Challenges 

identified by the Inspector General (IG) and agrees 

that these are critically important areas to focus on 

and to improve in FY 2024. These challenges are

Securing Information Systems and Networks from 

Destruction, Data Loss, or Compromise; Addressing 

Challenges to FTC Litigation; Successfully Managing 

Merger Transactions; and Combating Increasingly 

Sophisticated Imposter Scams and Enhancing the 

Public’s Awareness of Them

In FY 2023 the FTC took numerous steps to address 

these challenges and will continue to do so going 

forward into FY 2024. Regarding the securing of our

information systems, the agency continues to prioritize 

zero-trust architecture implementation, however, given 

potential resource constraints, anticipates that this 

work may extend beyond FY 2024.

To continue addressing challenges to FTC litigation 

from the loss of 13(b) authority after the Supreme 

Court decision in AMG Capital Management v. FTC,

the agency has focused enforcement efforts on cases 

that involve rule violations for which they can obtain 

monetary relief directly in federal court under Section 

19(a)(1) and cases involving order violations for which 

the FTC can obtain monetary relief in the form of a 

compensatory contempt sanction. This strategy has

led to hundreds of millions of dollars in judgements 

obtained, but overall amounts returned to consumers 

each year are still lower than those obtained by 

agency law enforcement prior to the AMG case

FY 2023 was the fourth year the FTC received financial 

management services from the Department of the 

Treasury’s Administrative Resource Center (ARC)

Since migrating to the new shared services provider, 

the agency is continuing its efforts to maintain and 

enhance financial management systems to promote 

operational effectiveness, efficiency, reliability, and 

timeliness of data to support the agency’s strategic 

goals. In FY 2023, the FTC leveraged reporting tools

to automate several financial management business 

processes. In FY 2024, we will continue efforts to

document end-to-end business processes and 

identify opportunities to improve

FTC OBTAINS JUDGMENT AGAINST PRINCIPALS AND CELEBRITY ENDORSERS OF 

REAL ESTATE INVESTMENT TRAINING PROGRAM 

As a result of a lawsuit filed by the FTC and the Utah Division of Consumer 

Protection, the principals of a Utah-based real estate investment 

training company, Response Marketing Group, will pay $15 million and 

be banned from selling money-making opportunities under a court 

order they have agreed to. The settlement comes on the heels of a

federal district court judge in Utah granting partial summary judgment 

to the FTC and Utah’s Division of Consumer Protection on many of the 

deceptive claims alleged in the complaint. The settlement includes two

of Response Marketing’s affiliates, Nudge and BuyPD, along with the 

four individuals who the complaint alleges were the actual owners of 

Response Marketing and Response Marketing’s President. In addition,

two real estate celebrities, Scott Yancey and Dean R. Graziosi, who endorsed the training have agreed to

separate settlements that require them to pay $1.7 million. The settlements with Graziosi and Yancey are th

FTC’s first monetary settlements with celebrity endorsers.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 37

MANAGEMENT’S DISCUSSION AND ANALYSIS

FINANCIAL HIGHLIGHTS 

INTRODUCTION 

The FTC’s accounting practices continue to be 

accurate and transparent, directly supporting the 

agency’s mission to protect the public from deceptive 

or unfair business practices and from unfair methods 

of competition through law enforcement, advocacy, 

research and education. For the 27th 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 Accepte

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&

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, 2023 AND 2022

(Dollars in Millions) FY 2023 FY 2022 % Change

Entity Assets

Fund balance with Treasury $ 162 $ 312 -48%

General property, plant, and equipment,net 16 20 -20%

Total Entity Assets 178 332 -46%

Non-Entity Assets

Fund balance with Treasury 649 205 217%

Accounts receivable 40 45 -11%

Total Non-Entity Assets 689 250 176%

Total Assets $ 867 $ 582 49%

Entity Liabilities

Employee related liabilities 23 23 0%

Accounts payable and other 14 13 8%

Total Entity Liabilities 37 36 3%

Non-Entity Liabilities

Redress collections not yet disbursed 649 205 217%

Liability for amounts to be collected 40 45 -11%

Total Non-Entity Liabilities 689 250 176%

Total Liabilities $ 726 $ 286 154%

Total unexpended appropriations 3 21 -86%

Total cumulative results of operations 138 275 -50%

Total Net Position 141 296 -52%

Total Liabilities and Net Position $ 867 $ 582 49%
38 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

BALANCE SHEET – ENTITY 

Entity assets totaled $178 million, or 20 percent of all 

FTC assets, as of September 30, 2023, a decrease of 

$154 million, or 46 percent, from the FY 2022 total of 

$332 million

The Fund Balance with Treasury (FBwT) of $162 

million decreased by $150 million, or 48 percent, 

from the FY 2022 total of $312 million. At the end of

FY 2022, the FTC’s FBwT contained $172 million in 

temporarily unavailable offsetting collections (fees 

from the FTC’s National Do Not Call Registry and 

Premerger notification filings) that exceed the amount 

authorized to offset the FTC’s appropriation. In FY 2023

the FTC received authority to return the $172 million 

in temporarily unavailable offsetting collections to 

Treasury

General property, plant, and equipment (PP&E), net 

of accumulated depreciation/amortization, is $16 

million, which consists of $15 million in leasehold 

improvements, and $1 million in equipment and 

software. Total PP&E has decreased by $4 million,

compared to FY 2022. This decrease is primarily due

to asset disposals and the continued depreciation/

amortization of assets

The annual trend in the FTC’s entity assets reflects 

a short-term increase in the amount of PP&E during 

FY 2014 for the relocation of staff to office space at 

Constitution Center. Upon completion, over $46 million

had been spent on capitalized assets. Since these

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

has decreased, primarily due to depreciation and 

amortization. FBwT increased significantly between FY

2020 and FY 2022 due to large increases in the volume 

of Premerger fee collections. These increased fee

collections resulted in offsetting collections amounts 

above what Congress authorized for retention and use 

to pay for necessary expenses of the agency. These

amounts were precluded from obligation and in 

FY 2023, the FTC received authority and returned $172 

million in prior excess collections to Treasury

Millions

$400

$350

$300

$250

$200

$150

$100

$50

$0

ENTITY ASSETS

FBwT PP&E

FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23

312

162

114

233

133 138 133 133 129 122

64 63 57 51 39

25 30 22 20 16
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 39

MANAGEMENT’S DISCUSSION AND ANALYSIS

Entity liabilities totaled $37 million, or 5 percent of 

all FTC liabilities, as of September 30, 2023, which 

represents an increase of $1 million from FY 2022

Entity liabilities normally have a smaller range of 

fluctuation in comparison to entity assets. Accounts

payable balances fluctuate based on the dollar 

amount and volume of capitalized purchases as well 

as the timing between the receipt of goods and the 

disbursement to the vendors. Accounts payable have

increased by $1 million in FY 2023 from the prior year 

due to a higher expense accrual for unbilled activity at 

the end of the fiscal year. Employee-related liabilities

fluctuate based on the full-time employee count 

and the timing of the payroll disbursement cycle. In

FY 2020 and FY 2021 the FTC had 13 and 14 days of 

unpaid wages accrued. While in FY 2022 and 2023

the FTC had 6 and 7 days of unpaid wages accrued, 

resulting in a significant decrease in employeerelated liabilities. These liabilities consist of accrued

payroll and benefits, accrued annual leave wages 

earned by employees but not yet paid, and workers 

compensation liabilities under the Federal Employees 

Compensation Act (FECA)

$35

$30

$25

$20

$15

$10

$5

$0

Employee-related liabilities

ENTITY LIABILITIES

Accounts payable and other liabilities

FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23

Millions

12

14

12

13 13 13

11 11

30

17

20

21 21 22

24

11

31

14

23 23
40 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

BALANCE SHEET - NON-ENTITY 

Non-entity assets totaled $689 million, or 80 percent 

of all FTC assets, as of September 30, 2023. This

represents an increase of $439 million, or 176 percent, 

from the FY 2022 total of $250 million. This increase is

primarily attributed to an increase in non-entity fund 

balance with treasury, shown in further detail in the 

charts on the next page

Non-entity assets are equal to, and offset by, nonentity liabilities. The $40 million net accounts

receivable balance is offset by the $40 million liability 

for amounts to be collected, while the $649 million 

FBwT is offset by the $649 million liability for redress 

collections

The FY 2023 ending net accounts receivable balance 

of $40 million reflects amounts to be paid to the 

FTC from court-ordered judgments in the consumer 

redress program. This represents a $5 million decrease

in net accounts receivable from the FY 2022 total of 

$45 million.

The remaining ending net accounts receivable 

balance of $40 million consists of amounts to be 

paid to the FTC from the twenty four cases in the 

consumer redress program. One case is the Sanctuary

Belize Litigation for involvement in the allegedly 

deceptive sale of real estate properties in Belize to U.

consumers

NON-ENTITY ASSETS & LIABILITIES

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

FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23

$800

$700

$600

$500

$400

$300

$200

$100

$0

Millions

135

751 796

432

359

266

677

628

65 43

99 70

599 616

51

385

205

649

45 40
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 41

MANAGEMENT’S DISCUSSION AND ANALYSIS

FY 2023 Non-Entity Fund Balance with Treasury Timeline Activity

$204.7M Beginning Balance - FY 2022 Non-Entity Fund Balance with Treasury

A $3.3M Passport Automotive 

Group, Inc.

Collected $3.3M from a 2022 settlement with auto dealer Passport Automotive Group. The 

FTC alleged that Passport Automotive Group deceived consumers by tacking hundreds to 

thousands of dollars in illegal junk fees onto car prices and for discriminating against Black and 

Latino consumers with higher financing costs and fees. 

B $62.0M Opendoor Labs, Inc.

Collected $62.0M from a 2022 settlement with Opendoor Labs, Inc. The FTC alleged that 

Opendoor cheated potential home sellers by tricking them into thinking that they could make 

more money selling their home to Opendoor than on the open market using the traditional sales 

process. 

C ($2.9M) Warrior Trading, Inc.

Disbursing $2.9M (20,402 payments) to consumers who paid thousands of dollars for Warrior 

Trading’s investment programs for misleading and unrealistic claims to sell a day trading 

“system” that would show consumers “how to make a profit in the markets but the system failed 

to pay off and the vast majority of customers lost money trading—in some cases thousands 

of dollars—on top of the thousands they paid Warrior Trading. Refunds are a result of a 2022 

order.

D $100.0M Vonage

Collected $100M from a 2022 settlement that stopped internet phone service provider Vonage 

from imposing junk fees and creating obstacles to those who try to cancel their service and 

often continued to illegally charge them even after they spoke to an agent directly and requested 

cancellation. 

E $2.8M DK Automation

Collected $2.8M from a 2022 order against DK Automation and its owners, for using unfounded 

claims of big returns to entice consumers into moneymaking schemes involving Amazon 

business packages, business coaching, and cryptocurrency to “generate passive income on 

autopilot” but few consumers ever made money from these schemes. 

F $3.0M Credit Karma, LLC

Collected $3.0M from a 2023 settlement with Credit Karma that settled charges that the credit 

services company deployed dark patterns to misrepresent that consumers were “pre-approved” 

for credit card offers when in many instances, the consumer did not qualify for these credit cards. 

G ($2.4M) RagingBull.com

Disbursing $2.4M (9,862 PayPal payments) back to consumers who paid subscription fees to 

the online stock trading site RagingBull.com, who used bogus earnings claims to trick people 

into paying for investment strategies and then trapped them into hard-to-cancel subscription 

plans with costly fees. Refunds are a result of a 2022 settlement.

OCT-22 DEC-22 MAR-23 JUN-23 SEP-23

FY 2023 NON-ENTITY ASSETS - FUND BALANCE WITH TREASURY

 TIMELINE ACTIVITY

O S P K

G

C

D E

L

J

F

H I

.

$700

$600

$500

$400

$300

$200

$100

0

Billions

B

A

M N

Q R T
42 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

FY 2023 Non-Entity Fund Balance with Treasury Timeline Activity

H $3.1M Elegant Solutions, Inc.

Collected $3.1M from a 2020 order against Elegant Solutions, Inc for falsely claiming that 

consumers’ loans would be forgiven or their payments reduced to a specific amount, and that 

defendants would take over servicing of consumers loans and apply most or all of consumers’ 

monthly payments to pay down their student loans. 

I $4.9M First American Payment 

Systems, LP

Collected $4.9M from a 2022 order against First American Payment Systems and two of its 

sales affiliates for making false claims about fees and cost savings to lure merchants, many of 

whom had limited English proficiency. Once merchants were enrolled, the defendants withdrew 

funds from their accounts without their consent and made it difficult and expensive for them to 

cancel the service. 

J $245.0M Epic Games, Inc. 

Collected $245M from a 2023 settlement with Epic Games, the maker of the Fortnite video 

game to settle charges that the company used dark patterns to trick players into making 

unwanted purchases and let children rack up unauthorized charges without any parental 

involvement. 

K ($3.3M) Passport Automotive 

Group, Inc.

Disbursing $3.3M (18,000 payments) to customers of Passport Auto, a Washington D.C.-area 

auto dealer that deceived consumers by tacking hundreds to thousands of dollars in illegal junk 

fees onto car prices and for discriminating against Black and Latino consumers with higher 

financing costs and fees. Refunds are a result of a 2022 settlement.

L ($3.3M) Arete Financial Group

Disbursed $3.3M (37,800 payments) to consumers who were harmed by Arete Financial Group, 

a student loan debt relief operation that tricked consumers into making illegal upfront payments 

by pretending to be affiliated with the U.S. Department of Education and falsely promising 

student loan debt relief; but instead pocketed the customer payments and never provided the 

promised relief. Refunds are a result of a 2022 settlement. 

M $8.5M Nudge, LLC 

Collected $8.5M from a 2023 settlement with Nudge, LLC a Utah-based real estate investment 

training company as well as two of the primary real estate celebrities who also endorsed the 

training which the FTC alleged used false promises to sell consumers a series of expensive real 

estate investment training programs.

N $9.0M American Financial 

Benefits Center, et al. 

Collected $9M from a 2020 settlement with Ameritech Financial. The FTC alleged Ameritech 

Financial misled consumers about lowering their student loan debt by falsely claiming that 

consumers were eligible for federal programs that would permanently reduce their monthly debt 

payments to a fixed low amount or result in total loan forgiveness. 

O $5.8M Ring, LLC 

Collected $5.8M from a 2023 settlement with home security camera company Ring. The FTC 

alleged that Ring compromised its customers’ privacy by allowing any employee or contractor 

to access consumers’ private videos and by failing to implement basic privacy and security 

protections, enabling hackers to take control of consumers’ accounts, cameras, and videos.

P $4.4M HomeAdvisor, Inc. 

Collected $4.4M from a 2023 order against Denver-based HomeAdvisor, Inc. a company 

affiliated with Angi, formerly known as “Angie’s List” to resolve allegations that they company 

used a wide range of deceptive and misleading tactics in selling home improvement project 

leads to service providers, including small businesses operating in the “gig” economy.

Q $7.8M BetterHelp, Inc. 

Collected $7.8M from a 2023 order against the online counseling service BetterHelp resolving 

allegations the firm shared consumers’ sensitive health data with third parties such as Facebook 

and Snapchat after promising to keep such data private. 

R $18.5M Publishers Clearing 

House, LLC

Collected $18.5M from a 2023 settlement with Publishers Clearing House (PCH). The FTC 

alleged that Publishers Clearing House uses “dark patterns” to mislead consumers about how to 

enter the company’s well-known sweepstakes drawings and made them believe that a purchase 

is necessary to win or would increase their chances of winning, and that their sweepstakes 

entries are incomplete even when they are not. The FTC also charges that the company 

has added surprise shipping and handling fees to the costs of products, misrepresented 

that ordering is “risk free,” used deceptive emails as part of its marketing campaign, and 

misrepresented its policies on selling users’ personal data to third parties prior to January 2019.

S ($9.1M) American Financial 

Benefits Center, et al.

Disbursed $9.1M (22,562 payments) in refunds to consumers who lost money to Ameritech 

Financial, a student loan debt relief scheme. Refunds are a result of a 2020 settlement. 

T $7.8M ZURIXX, LLC

Collected $7.8M from a 2022 settlement with Zurixx, LLC and its owners. The FTC And Utah 

Department of Commerce Division of Consumer Protection alleged that Zurixx, LLC, its owners, 

and a number of associated companies operated a real estate investment coaching scheme that 

sold live seminars and telephone coaching using false earnings claims that convinced tens of 

thousands of consumers to pay them thousands or tens of thousands of dollars.

 ($20.6M) Net of other activities: $107.4M collections - $128.0 disbursement, related to over 145 additional matters. 

$649.0M Ending Balances – FY 2023 Non-Entity Fund Balance with Treasury 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 43

MANAGEMENT’S DISCUSSION AND ANALYSIS

The Statement of Net Cost presents the FTC’s gross 

costs less earned revenue for the agency’s two 

primary strategic goals: Protect the public from unfair 

or deceptive acts or practices in the marketplace 

(Protect Consumers) and protect the public from 

unfair methods of competition in the marketplace 

and promote fair competition (Maintain Competition).

A third goal, advance the FTC’s effectiveness and 

performance, has its costs distributed to the other two 

strategic goals based on the percentage of dollars 

directly traceable to each goal. The FTC’s net cost of

operations was $230 million in FY 2023, which consists 

of $418 million in gross costs offset by $188 million in 

earned revenue

The FY 2023 net cost of operations for the Protect 

Consumers strategic goal is $203 million, consisting 

of $218 million in gross costs offset by $15 million in 

earned revenue, the majority of which is attributable 

to 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 2023 net cost of operations for the Maintain 

Competition strategic goal is $27 million, consisting 

of $200 million in gross costs offset by $173 million in 

earned revenue, which is primarily revenue from fees 

collected for premerger notification filings, with a small 

portion (approximately $1 million) from 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 premerger filing fees

are split evenly between the FTC and the DOJ upon 

collection

The $77 million increase in overall net cost of 

operations from FY 2022 to FY 2023 is primarily due 

to increases in year over year appropriations, coupled 

with reduced revenues from premerger filing fees

STATEMENT OF NET COST

STATEMENT OF NET COST SUMMARY

FOR THE YEARS ENDED SEPTEMBER 30, 2023 AND 2022

(Dollars in Millions) FY 2023 FY 2022 % Change

Protecting Consumers:

Gross costs $ 218 $ 193 13%

Earned revenue (15) (14) 7%

Net Cost, Protect Consumers 203 179 13%

Maintain Competition:

Gross costs $ 200 $ 166 20%

Earned revenue (173) (192) 10%

Net Cost, Maintain Competition 27 (26) 204%

Net Cost of Operations $ 230 $ 153 50%
44 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

FTC NET COST OF OPERATIONS VS. 

BENEFIT TO CONSUMERS 

The FTC had gross costs of $418 million in FY 2023, 

offset by $188 million in earned revenue, resulting in a 

total net cost of operations of $230 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 2023, the FTC returned $364 million in nonentity collections to consumers and the U.S. Treasur

General Fund.

Additionally, the FTC saved consumers an estimated 

$3.6 billion through its merger and non-merger

competition law enforcement actions and 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 2023, the FTC

provided an estimated total of $4.0 billion in benefits to

consumers. When this benefit is compared to the $230

million in net costs, it equates to an estimated $17 in 

FTC-provided benefits to consumers for every $1 of 

the FTC’s cost

*These estimates were calculated based on performance 

measures 1.1.2 (consumer savings from consumer protectio

law enforcement), 2.1.1 (consumer savings and othe

measurable benefits generated by antitrust enforcement)

For more details on measurement and data quality, see the 

FTC Data Quality Appendix

COST vs BENEFIT

For every $1 of the FTC’s cost there is an estimated $17 in benefits provided to the consumer

FTC’S IMPACT 

ON 

THE CONSUMER

Other benefits to consumers*

$3.6 Billion

Non-entity funds 

disbursed to 

claimants, third party 

administrators, and 

the General Fund of 

the U.S. Government

$364 Million

FTC Net Cost of Operations

$230 Million
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 45

MANAGEMENT’S DISCUSSION AND ANALYSIS

FTC BUDGETARY RESOURCES AND HOW THEY WERE USED 

collected for the National Do Not Call Registry, and 

$1 million from reimbursable work on behalf of other 

Federal agencies. Additionally, in FY2023 the FTC

received authority and returned $172 million in prior 

year collections in excess of previously established 

congressional limits.

Because current year offsetting collections up to the 

congressionally authorized amount are deducted from 

gross budget authority and outlays, only 16 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 $70 million, 

which is less than 1/10 of 1 percent of the total nondefense discretionary spending for FY 2023

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

The FTC’s budget authority is derived from a direct 

appropriation and offsetting collections.

New budget authority for FY 2023 is $430 million, 

which includes $70 million in a direct appropriation 

and $360 million in spending authority from offsetting 

collections. Offsetting collections consist of FY 2023

collections of $172 million from fees collected for 

premerger notification filings under the HSR Antitrust 

Improvements Act of 1976, $15 million from fees 

NEW BUDGET AUTHORITY

General Fund

Annual 

Appropriation

$70 Million

Offsetting

Collection

$360 Million

FY 2023 - $430 MILLION

General Fund

Annual 

Appropriation

$224 Million

Offsetting

Collection

$155 Million

FY 2022 - $379 MILLION
46 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

MANAGEMENT’S DISCUSSION AND ANALYSIS

THE FTC’S FY 2023 OBLIGATIONS: 

In FY 2023, the FTC received $430 million in new 

budget authority and authority to obligate $42 million 

in its unobligated balance brought forward in addition 

to $5 million in recoveries of prior-year obligations 

and $2 million in non-expenditure transfers. Pursuant

to these authorities, the FTC obligated $427.5 million

in FY 2023. This was an increase of $57.2 million

or 15 percent, compared to new obligations in FY 

2022. The increase in obligations incurred in FY 2023

was primarily attributable to higher costs for payroll 

(personnel salaries and benefits) and expert witnesses

Payroll spending has increased by 11 percent to 

$260 million in FY 2023 from $234 million in FY 2022

This is the result of increasing FTEs as a result of our 

increased appropriation and the 4.6 percent pay raise

for FY 2023. Obligations related to expert witness

support services have increased by 101% to $39 

million in FY2023 from $19.4 million in 2022. While th

FTC is committed to limiting costs for expert witness 

services, the agency continues to face pressure from 

resource constraints as it performs mission-critical 

work and maintains fair competition in increasingly 

complex and pervasive technology markets that raise 

unique antitrust considerations. Obligations for other

contractual services have increased by 8% to 

88 million in FY 2023 from 81 million in FY 2022

Spending on rent, communications, and utilities has 

increased by 6% to $33 million in FY 2023 from 31.5

million in FY 2022

FY 2023 FTC OBLIGATIONS BY CATEGORY

$259.7M

Payroll (compensation 

and benefits)

$7.6M

Other (printing, supplies, 

transportation, PP&E)

$39.0M

Other Contractual 

Services-Expert Witness

$33.4M

Rent, Comm, Utilities

$87.8M

Other Contractual Services

Total obligations incurred during FY 2023: $427.5M
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 47

MANAGEMENT’S DISCUSSION AND ANALYSIS

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.go

FINANCIAL MANAGEMENT INDICATORS FOR FY 2023 

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

OMB to monitor agencies’ financial management practices

DEBT MANAGEMENT

Eligible debt transferred to Treasury 100%

FUNDS MANAGEMENT

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

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

PAYMENT MANAGEMENT

Percentage invoices paid on time (per Prompt Payment Act) 99.5%

Percentage interest penalties paid to total dollars invoiced .000008%

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

billed travel account holders 100%

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

travel accounts 100%

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

LIMITATIONS OF FINANCIAL 

STATEMENTS 

The principal financial statements are prepared to 

report the financial position, financial condition, and 

results of operations, pursuant to the requirements of 

31 U.S.C. § 3515(b). The statements are prepared f

records of Federal entities in accordance with Federal 

Federal Trade Commission

Agency Mission

Protecting the public from deceptive or unfair business practices and from unfair 

methods of competition through law enforcement, advocacy, research, and education

Website

https://www.ftc.go

Congressional Justification of Budget (CJ)

https://www.ftc.gov/

generally accepted accounting principles (GAAP) and 

the formats prescribed by OMB. Reports used to

monitor and control budgetary resources are prepared 

from the same records. Users of the statements are

advised that the statements are for a component of 

the U.S. Governme
FEDERAL TRADE COMMISSION
FISCAL YEAR 2023

FINANCIAL

SECTION
FEDERAL TRADE COMMISSION
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 51

FINANCIAL SECTION

I am pleased to present the Agency Financial Report (AFR) for Fiscal Year 2023. The AFR provides a

comprehensive view of the FTC’s financial activities and demonstrates the FTC’s stewardship and management 

of public funds. The financial statements and corresponding financial analysis, together with the Agency’s

Performance Highlights, demonstrate how the FTC optimizes its financial resources to protect American 

consumers and maintain competition in the marketplace.

In FY 2023, the FTC has achieved, for the twenty-seventh consecutive year, an unmodified audit opinion from 

independent auditors. We are very proud of this accomplishment. This sustained achievement is due to the effort

of the Financial Management Office (FMO) staff, as supported by senior leadership, fund managers, and FTC 

personnel throughout the agency.

The accomplishments outlined in this report are the result of 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

Randy Salzer, Deputy Chief Financial Officer 

November 15, 2023
52 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

November 15, 2023

MEMORANDUM

FROM: Andrew Katsaros

Inspector General

TO: Lina M. Khan, Chair

SUBJECT: Report on Audit of the FTC’s Fiscal Year 2023 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’s) fiscal 

year 2023 financial statements. We commend the FTC for attaining an unmodified (clean) opinion for 

the 27th consecutive year.

We contracted with the independent public accounting firm of Allmond & Company, LLC, to audit the 

financial statements of the FTC as of and for the fiscal year ended September 30, 2023,

1 and to provide a 

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

audit was performed in accordance with U.S. generally accepted auditing standards, the Government 

Accountability Office’s Government Auditing Standards, and Office of Management and Budget guidance.

In its audit of the agency, Allmond & Company reported

• that the financial statements 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;

2 and

• no reportable noncompliance with provisions of laws tested or other matters.

Allmond & Company is responsible for the attached auditor’s report dated November 15, 2023, and the 

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

internal control over financial reporting, or conclusions on compliance and other matters.

We appreciate the cooperation given by management to Allmond & 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.

1 The financial statements of the FTC as of and for the fiscal year ended September 30, 2022, were audited by another 

auditor, who expressed an unmodified opinion on those statements on November 14, 2022.

2 A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that 

there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or 

detected and corrected, on a timely basis.

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

 Office of Inspector General
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 53

FINANCIAL SECTION

 FEDERAL TRADE COMMISSION

AUDIT REPORT

SEPTEMBER 30, 2023

 ALLMOND & COMPANY, LLC

 Certified Public Accountants

 7501 Forbes Boulevard, Suite 200

 Lanham, Maryland 20706

 (301) 918-8200
54 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

1 

 

Independent Auditor’s Report

Chair, Federal Trade Commission

Inspector General, Federal Trade Commission

 

Report on the Financial Statements

Opinion 

Pursuant to the Accountability of Tax Dollars Act of 2002, we have audited the accompanying financial 

statements of the Federal Trade Commission (FTC), which comprise the balance sheet as of September 30, 

2023; the related statements of net cost, changes in net position, budgetary resources, and custodial activity 

for the fiscal year then ended; and the related notes to the financial statements (hereinafter referred to as the 

financial statements). 

In our opinion, the financial statements present fairly, in all material respects, the financial position of the 

Federal Trade Commission as of September 30, 2023 and its net costs, changes in net position, budgetary 

resources, and custodial activity for the fiscal year then ended in accordance with accounting principles 

generally accepted in the United States of America.

Basis for Opinion

We conducted our audit in accordance with U.S. generally accepted auditing standards (GAAS); the 

standards applicable to financial audits contained in Government Auditing Standards issued by the 

Comptroller General of the United States; and Office of Management and Budget (OMB) Bulletin No. 24-

01, Audit Requirements for Federal Financial Statements. Our responsibilities under those standards and 

OMB Bulletin No. 24-01 are further described in the Auditor’s Responsibilities for the Audit of the 

Financial Statements section of our report. We are required to be independent of the FTC and to meet our 

other ethical responsibilities, in accordance with the relevant ethical requirements relating to our audits. We 

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

audit opinion. 

Other Matter

The financial statements of FTC as of and for the fiscal year ended September 30, 2022 were audited by 

another auditor, who expressed an unmodified opinion on those statements on November 14, 2022. These 

statements were not audited, reviewed, or compiled by us; accordingly, we do not express an opinion or 

provide any other form of assurance on them.

Responsibilities of Management for the Financial Statements

Management is responsible for (1) the preparation and fair presentation of these financial statements in
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 55

FINANCIAL SECTION

Independent Auditor’s Report 

2 

accordance with U.S. generally accepted accounting principles; (2) the preparation, measurement, and 

presentation of Required Supplementary Information (RSI) in accordance with U.S. generally accepted 

accounting principles; (3) the preparation and presentation of other information included in FTC’s Agency 

Financial Report and ensuring the consistency of that information with the audited financial statements and 

the RSI; and (4) the design, implementation, and maintenance of effective 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 Responsibilities for the Audit of the Financial Statements

Our objectives are to (1) obtain reasonable assurance about whether the financial statements as a whole are 

free from material misstatement, whether due to fraud or error, and (2) issue an auditor’s report that includes 

our opinion. Reasonable assurance is a high level of assurance but is not absolute assurance and therefore 

is not a guarantee that an audit of the financial statements conducted in accordance with GAAS, generally 

accepted government auditing standards (GAGAS), and OMB Bulletin No. 24-01 will always detect a 

material misstatement or material weakness when it exists.

The risk of not detecting a material misstatement resulting from fraud is higher than for one resulting from 

error, as fraud may involve collusion, forgery, intentional omissions, misrepresentations, or the override of 

internal control. Misstatements, including omissions, are considered to be material if there is a substantial 

likelihood that, individually or in the aggregate, they would influence the judgment made by a reasonable 

user based on the financial statements.

In performing an audit in accordance with GAAS, GAGAS, and OMB Bulletin No. 24-01, we exercise 

professional judgment and maintain professional skepticism throughout the audit; identify and assess risks 

of material misstatement of the financial statements, whether due to fraud or error; and design and perform 

audit procedures that are responsive to those risks. Such procedures include examining, on a test basis, 

evidence regarding the amounts and disclosures in the financial statements. In addition, in making those 

risk assessments, we obtain an understanding of internal control relevant to an audit 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 FTC’s internal control over financial reporting. 

Accordingly, we express no such opinion.

An audit also includes 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, and performing other procedures we consider necessary in the circumstances. We 

are required to communicate with those charged with governance regarding, among other matters, the 

planned scope and timing of the audit, significant audit findings, and certain internal control-related matters 

that we identified during the financial statement audit.

Required Supplementary Information (RSI)

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

(FASAB) require that the information in the RSI be presented to supplement the financial statements. Such 

information is the responsibility of management and, although not a part of the financial statements, is 

required by FASAB, which considers it to be an essential part of financial reporting for placing the financial 

statements in appropriate operational, economic, or historical context.
56 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

Independent Auditor’s Report 

3 

We have applied certain limited procedures to the RSI in accordance with U.S. generally accepted 

government auditing standards. These procedures consisted of (1) inquiring of management about the 

methods used to prepare the RSI and (2) comparing the RSI for consistency with management’s responses 

to our inquiries, the financial statements, and other knowledge we obtained during the audit of FTC’s 

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.

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. Management is responsible for the other information included 

in FTC’s Agency Financial Report. The other information comprises the Message from the Chair, 

Performance Highlights, and Other Information sections, as listed in the Table of Contents of FTC’s 

Agency Financial Report, but does not include the financial statements and our auditor’s report thereon. 

Our opinion on the financial statements does not cover the other information, and we do not express an 

opinion or any form of assurance thereon.

In connection with our audit of the financial statements, our responsibility is to read the other information 

and consider whether a material inconsistency exists between the other information and the financial 

statements, or the other information otherwise appears to be materially misstated. If, based on the work 

performed, we conclude that an uncorrected material misstatement of the other information exists, we are 

required to describe it in our report.

Report on Internal Control over Financial Reporting 

In connection with our audit of FTC’s financial statements, we considered FTC’s internal control over 

financial reporting, consistent with our auditor’s responsibilities discussed below.

Results of Our Consideration of Internal Control over Financial Reporting

Our consideration of internal control was for the limited purpose described below, and was not designed to 

identify all deficiencies in internal control that might be material weaknesses or significant deficiencies 1 or 

to express an opinion on the effectiveness of FTC’s internal control over financial reporting. Given these 

limitations, during our 2023 audit, we did not identify any deficiencies in internal control over financial 

reporting that we consider to be material weaknesses. However, material weaknesses or significant 

deficiencies may exist that have not been identified.

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

employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, 

misstatements on a timely basis. A material weakness is a deficiency, or combination of deficiencies, in internal 

control over financial reporting, such that there is a reasonable possibility that a material misstatement of the entity’s 

financial statements will not be prevented, or detected and corrected, on a timely basis. A significant deficiency is a 

deficiency, or a combination of deficiencies, in internal control over financial reporting that is less severe than a 

material weakness, yet important enough to merit the attention by those charged with governance.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 57

FINANCIAL SECTION

Independent Auditor’s Report 

4 

During our audit, we identified deficiencies in FTC’s internal control over financial reporting that we do 

not consider to be material weaknesses or significant deficiencies that, nonetheless, warrant management’s 

attention. We have communicated these matters to FTC management and, where appropriate, will report 

on them separately.

Basis for Results of Our Consideration of Internal Control over Financial Reporting

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

U.S. generally accepted government auditing standards and OMB audit guidance.

Responsibilities of Management for Internal Control over Financial Reporting

FTC management is responsible for designing, implementing, and maintaining effective internal control 

over financial reporting relevant to the preparation and fair presentation of financial statements that are free 

from material misstatement, whether due to fraud or error.

Auditor’s Responsibilities for Internal Control over Financial Reporting

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

September 30, 2023, in accordance with U.S. generally accepted government auditing standards, we 

considered FTC’s internal control relevant to the financial statement audit 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 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 as those 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 internal control over financial reporting 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.

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 

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.
58 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

Independent Auditor’s Report 

5 

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

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

of applicable laws, regulations, contracts, and grant agreements consistent with our auditor’s 

responsibilities discussed below.

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 2023 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.

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

We performed our tests of compliance in accordance with U.S. generally accepted government auditing 

standards.

Responsibilities of Management for Compliance with Laws, Regulations, Contracts, and Grant 

Agreements

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

applicable to FTC.

Auditor’s Responsibilities for Tests of Compliance with Laws, Regulations, Contracts, and Grant 

Agreements

Our responsibility is to test compliance with selected provisions of 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 to perform certain other limited procedures. Accordingly, 

we did not test compliance with all provisions of laws, regulations, contracts, and grant agreements 

applicable to FTC. We caution that noncompliance may occur and not be detected by these tests.

Intended Purpose for 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 provision 

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.

 

 

Allmond & Company, LLC 

Lanham, Maryland

November 15, 2023

58 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

58 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 59

FINANCIAL SECTION

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 a 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
60 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

BALANCE SHEET

AS OF SEPTEMBER 30, 2023 AND 2022

(DOLLARS IN THOUSANDS)

2023 2022

Assets (Note 2):

Intragovernmental:

Fund balance with Treasury (Note 3) $ 810,370 $ 516,745 

Accounts receivable, Net (Note 4) 84 6

Advances and prepayments 845 7 

Total intragovernmental assets 811,299 516,758 

Other than intragovernmental:

Accounts receivable, Net (Note 4) 39,914 45,175 

General property, plant, and equipment, Net (Note 5) 16,348 19,643 

Total other than intragovernmental assets 56,262 64,818

Total Assets $ 867,561 $ 581,576 

Liabilities (Notes 6 and 7):

Intragovernmental:

Accounts payable $ 873 $ 1,251 

Other liabilities (Note 7) 1,724 1,504 

Total intragovernmental liabilities 2,597 2,755

Other than intragovernmental:

Accounts payable 12,846 12,085 

Other liabilities:

Accrued redress due to claimants 39,427 44,976 

Undisbursed redress collections (Note 12) 649,018 204,704

Other (Note 7) 22,445 21,030 

Total other than Intragovernmental liabilities 723,736 282,795

Total Liabilities 726,333 285,550 

Net position (Note 1(o)):

Total unexpended appropriations 3,372 20,821

Total cumulative results of operations 137,856 275,205 

Total Net Position 141,228 296,026 

Total Liabilities and Net Position $ 867,561 $ 581,576

The accompanying notes are an integral part of these statements.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 61

FINANCIAL SECTION

STATEMENT OF NET COST

FOR THE YEARS ENDED SEPTEMBER 30, 2023 AND 2022 

(DOLLARS IN THOUSANDS)

2023 2022

Strategic Goal 1: Protect Consumers:

Intragovernmental costs $ 56,302 $ 51,731 

Public costs 162,129 141,644 

Gross costs, protect consumers 218,431 193,375 

Intragovernmental earned revenue - (88)

Public earned revenue (14,952) (14,310)

Earned revenue, protect consumers (14,952) (14,398)

Net Cost, Protect Consumers 203,479 178,977 

Strategic Goal 2: Maintain Competition:

Intragovernmental costs 51,556 44,603 

Public costs 148,463 122,125 

Gross costs, maintain competition 200,019 166,728 

Intragovernmental earned revenue (1,183) (796)

Public earned revenue (171,824) (191,427)

Earned revenue, maintain competition (173,007) (192,223)

Net Cost, Maintain Competition 27,012 (25,495) 

Net Cost of Operation $ 230,491 $ 153,482 

The accompanying notes are an integral part of these statements.
62 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

STATEMENT OF CHANGES IN NET POSITION

FOR THE YEARS ENDED SEPTEMBER 30, 2023 AND 2022 

(DOLLARS IN THOUSANDS)

2023 2022

Unexpended Appropriations:

Beginning balance $ 20,821 $ 27,000 

Appropriations received 70,724 224,228 

Appropriations transferred in - 1,615

Other adjustments (11,072) -

Appropriations used (77,101) (232,022)

Net change in unexpended appropriations (17,449) (6,179)

Total Unexpended Appropriations 3,372 20,821

Cumulative Results of Operations:

Beginning balance $ 275,205 $ 186,044 

Appropriations used 77,101 232,022 

Transfers in - 1

Imputed financing 16,063 10,634 

Other (21) (14) 

Net cost of operations (230,491) (153,482)

Net change in cumulative results of operations (137,348) 89,161

Cumulative Results of Operations 137,857 275,205 

Net Position (Note 1(o)) $ 141,229 $ 296,026

The accompanying notes are an integral part of these statements.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 63

FINANCIAL SECTION

STATEMENT OF BUDGETARY RESOURCES

FOR THE YEARS ENDED SEPTEMBER 30, 2023 AND 2022

(DOLLARS IN THOUSANDS)

2023 2022

Budgetary Resources: 

Unobligated balance, brought forward, October 1 $ 63,455 $ 45,375

 Recoveries of unpaid prior year obligations 10,609 7,710

Other changes in unobligated balance 341 2,009

Unobligated balance from prior year budget authority, net 74,405 55,094

Appropriations 59,652 224,228

Spending authority from offsetting collections 360,260 154,479

Total Budgetary Resources $ 494,317 $ 433,801 

Status of Budgetary Resources:

New obligations and upward adjustments (total) (Note 10) $ 427,449 $ 370,346

Unobligated balance, end of year: 

 Apportioned, unexpired accounts 60,921 60,666

 Unapportioned, unexpired accounts 5,947 2,789 

 Unexpired unobligated balance, end of year 66,868 63,455

Unobligated balance, end of year (total) 66,868 63,455

Total Budgetary Resources $ 494,317 $ 433,801

Outlays, Net: 

 Outlays, gross $ 398,543 $ 353,507

 Actual offsetting collections (188,202) (206,742)

 Outlays, net 210,341 146,765

 Distributed offsetting receipts (4,442) (14,376)

 Agency outlays, net $ 205,899 $ 132,389

The accompanying notes are an integral part of these statements.
64 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

STATEMENT OF CUSTODIAL ACTIVITY

FOR THE YEARS ENDED SEPTEMBER 30, 2023 AND 2022 

(DOLLARS IN THOUSANDS)

2023 2022

Revenue Activity (Note 11):

Civil penalties and fines 317,525 158,019 

Consumer redress 4,406 14,348 

Other miscellaneous receipts 15 13 

Total cash collections 321,946 172,380 

Accrual adjustments 280 158

Total Custodial Revenue $ 322,226 $ 172,538

Disposition of Custodial Collections (Note 11):

Transferred to treasury general fund $ 321,946 $ 172,380

Non-cash accural adjustment 280 158

Total Disposition of Collections $ 322,226 $ 172,538

Net Custodial Activity - -

The accompanying notes are an integral part of these statements.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 65

FINANCIAL SECTION

NOTES TO THE FINANCIAL 

STATEMENTS 

NOTE 1—SIGNIFICANT ACCOUNTING 

POLICIES 

(a) Reporting Entity 

The reporting entity is a component of the U.

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. T

financial statements should be read with the 

realization that they are for a component of the U.

Government, a sovereign entity. The accompanying

financial statements and notes of the FTC include 

financial activity recorded in all funds under the FTC’s 

control. The FTC maintains these funds including

appropriations received for salaries and necessary 

expenses, as well as non-entity funds that are primarily 

collections derived from court ordered judgments 

and settlements held for subsequent distribution to 

approved claimants

The FTC records and tracks financial activities using 

Treasury Account Symbols (TAS). Each TAS included

in the agency’s fund accounting structure is described 

below: 

General Funds 

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

this account receives budget authority from an 

appropriation and offsetting collections, 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. In the FY2023 the FTC

received authority to return all prior year collections in 

excess of previously established congressional limits 

that were unavailable by law and had been included in 

the FTC’s unavailable – excess offsetting collections

(See Note 3, Fund Balance with Treasury.)

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

FTC received an appropriation under the American 

Rescue Plan Act (ARPA). ARPA provides funding to

cover cost increases as a result of the COVID-19 

pandemic of 2020-2022. Funding for the FTC under

ARPA includes payroll costs, consumer education, and 

monitoring of consumer complaints received into the 

Consumer Sentinel Network. In May 2023, the Fiscal

Responsibility Act of 2023 rescinded all unobligated 

funds at the time, leaving only funds to cover current 

obligations

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 y

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 12, 

Consumer Redress Activities.) For reporting purposes,

funds held by redress third party administrators 

outside of the U.S. Treasury on behalf of harme

consumers are not part of the FTC reporting entity

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.

Government at the end of each fiscal year

General Fund Proprietary Receipts (TAS 29 3220): 

Miscellaneous receipts that by law are not available for 

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

is fees collected under the Freedom of Information 
66 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

Act (FOIA). Furthermore, collections for the consumer

redress program for which redress to consumers is not 

practicable are also recorded in this account. These

funds are ultimately disgorged to the U.S. Treasu

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 o

each fiscal year

Clearing/Suspense Account 

Budget Clearing and Suspense (TAS 29F3875): Prior 

to a systems process change in the first quarter of 

FY 2021, fees collected for premerger notification 

filings under the HSR Act were deposited, initially, 

into the Budget Clearing and Suspense account, 

then distributed equally to the FTC (as an offsetting 

collection in the general fund) and the Department 

of Justice (DOJ). Premerger receipts are now split

evenly upon collection between the FTC and the DOJ, 

eliminating the custodial activity transactions. The

Budget Clearing and Suspense account is still used to 

process refund payments to vendors. (See Note 1(p),

Revenues and Other Financing Sources.)

Horseracing Integrity and Safety Authority (HISA) 

The FTC reporting entity does not include the 

Horseracing Integrity and Safety Authority (HISA), a 

private self-regulatory organization that has been 

setup to develop rules related to horseracing, 

including anti-doping, medication control and 

racetrack safety. The FTC is given broad oversight over

the Authority. The FTC, after providing an opportunity

for public comment, must approve or disapprove 

any rule, standard or procedure proposed by HISA

Civil sanctions imposed by the Authority for violations 

of its rules or standards may be appealed to the 

Commission.

(b) Basis of Presentation and Accounting 

The accompanying financial statements present the 

financial position, net cost of operations, changes 

in net position, budgetary resources, and custodial 

activities of the FTC, and have been prepared from 

the accounting records of the FTC. These financial

statements may differ from other financial reports 

submitted pursuant to the Office of Management and 

Budget (OMB) directives for the purpose of monitoring 

and controlling the use of the FTC’s budgetary 

resources.

The FTC’s financial statements are prepared in 

conformity with U.S. Generally Accepted Accountin

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 May 2023)

Transactions are recorded on both an accrual and a 

budgetary basis. Accordingly, revenues are recognized

when earned and expenses are recognized when 

incurred, without regard to the receipt or payment 

of cash. Accrual methods of accounting may differ

from budgetary accounting principles, primarily in 

the capitalization and depreciation of property and 

equipment, as well as the recognition of other longterm assets and liabilities. The purpose of federal

budgetary accounting is to control, monitor, and 

report on funds made available to federal agencies 

by law and help ensure compliance with the law

Budget terms commonly used are defined in OMB 

Circular A-11, Section 20.3. Further information abou

budget terms and concepts is available in the “Budget 

Concepts” chapter of the Analytical Perspectives

volume of the President’s Budget

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

maintains a primary fund to account for salaries and 

operating expenses. There are limited intra-entity

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

that require eliminating entries to present consolidated 

statements. Furthermore, the FTC does not currently

have any funds classified as dedicated collections 

which require separate reporting under FASAB 

Statement of Federal Financial Accounting Standards 

(SFFAS) 43, Funds from Dedicated Collections

Accordingly, the proprietary financial statements 

are not labeled consolidated nor is the Statement of 

Budgetary Resources (SBR) presented as combined

FTC reconciles its intragovernmental activity and 

works with agency trading partners to reduce 

significant or material differences in conformance with 

U.S. Treasury intragovernmental reporting guideline

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
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 67

FINANCIAL SECTION

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 goal: 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 

accruals for travel and interagency agreements. The

FTC uses statistical techniques to evaluate vendor 

accounts payable balances for previous fiscal years, 

averages the balances to obtain an accrual estimate, 

and then adjusts the estimate using a factor that 

represents the proportional change in obligations 

between the current and the previous fiscal year. Every

year, the agency statistically validates that the yearend 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 

2023 Congressional Budget Justification, pages 14-15, 

“Appropriations Language Provisions”). In addition, the

FTC places internal restrictions on fund expenditures 

to ensure the efficient and proper use of all funds

The FTC’s budget authority is derived from direct 

appropriations and offsetting collections. The FTC

accounts for budget authority in its General Fund 

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

Statement of Budgetary Resources

(e) Classified Activities 

Accounting standards require all reporting entities 

to disclose that accounting standards allow certain 

presentations and disclosures to be modified, if 

needed, to prevent the disclosure of classified 

information.

(f) Entity and Non-Entity Assets 

The FTC reports on both entity and non-entity assets 

in the financial statements. Assets that the agency is

authorized to use in its operations are entity assets

Assets that the agency holds on behalf of another 

federal agency or a third party and are not available for 

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

include collections and accounts receivable that 

arise from court-order judgments for monetary relief 

and civil monetary penalties. These non-entity assets

are included in the financial statements along with 

offsetting non-entity liabilities of equal amount. (See

Note 2, Entity and Non-Entity Assets.)

(g) Fund Balance with Treasury 

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

reporting entity and a liability of the General Fund 

of the U.S. Government. Amounts reported for FB

represent commitments by the federal government 

to provide resources to particular programs; however, 

they do not represent net assets to the government as 

a whole. When a reporting entity seeks to use FBwT to

liquidate budgetary obligations, Treasury will finance 

the disbursements with current receipts or borrow 

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

statements, FBwT represents the aggregate amount of 

undisbursed funds in the FTC’s general funds, deposit 

fund, and clearing/suspense fund. The general fund
68 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

cash balance includes a portion that is available to 

the FTC to make expenditures and pay liabilities and a 

portion that is unavailable. Deposit fund and clearing

suspense fund balances are non-entity funds that 

are temporarily held by the FTC until transferred to 

another federal agency or distributed to a third party

Fund balances are carried forward into subsequent 

fiscal years until disbursements are made. (See Note 3,

Fund Balance with Treasury.)

(h) Accounts Receivable, Net 

Accounts receivable, net of allowances, reflect the 

FASAB standard for the recognition of losses using 

the collection criterion of “more likely than not” as 

prescribed in SFFAS 1, Accounting for Selected Assets 

and Liabilities. This criterion results in receivable

balances that are more conservatively stated than 

those valued by the private sector under GAAP. FASAB

states that it is appropriate to recognize the nature of 

federal receivables, which, unlike trade accounts of 

private firms or loans made by banks, are not created 

through credit screening procedures. Rather, these

receivables arise because of the assessment of fines 

from regulatory violations. In these circumstances,

historical experience and economic realities indicate 

that these types of claims are frequently not fully 

collectible. Accounts receivable includes estimates

of the net cash value from court appointed receivers 

for which the FTC anticipates the proceeds will be 

deposited in the Consumer Redress Escrow account 

(29X6013)

The method used to estimate the allowance for 

uncollectible accounts consists of individual case 

analysis by a case manager who assesses the 

debtor’s ability and willingness to pay, the defendant’s 

payment history, and the probable recovery amount 

including the value of assets. Based on the litigation

and collection status, cases may be referred to the 

Treasury for collection action. (See Note 4, Accounts

Receivable, Net.)

(i) General Property, Plant, and 

Equipment 

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

consists of general equipment used by the agency 

and capital improvements made to buildings leased 

from the General Services Administration (GSA) by 

the FTC for office space, as well as software leased 

and purchased from vendors. The FTC’s capitalization

policy, Accounting for Property, Plant, and Equipment, 

was updated with an effective date on or after October 

1, 2014. PP&E placed in service prior to October 1,

2014, will continue to be accounted for based on the 

capitalization policy in effect at the time acquired, until 

fully depreciated or removed from service

Asset Type Capitalization 

Threshold

Furniture $ 50,000

General Equipment $ 50,000

IT Equipment $ 150,000

Leasehold Improvements $ 150,000

Internal Use Software $ 200,000

The FTC reports property and equipment at historical 

cost and capitalizes acquisitions based on the above 

thresholds for items with a useful life of two or more 

years. Property and equipment that meet these criteria

are depreciated or amortized using the straight-line 

method over the estimated useful life of the asset

An exception applies to leasehold improvements, 

which are amortized over the lesser of the useful 

life of the asset or the remaining lease term. Assets

under development, such as internal use software and 

leasehold improvements with an estimated aggregate 

cost meeting the threshold criteria, are capitalized 

and then amortized once completed and placed 

into service. Normal repairs and maintenance, and

PP&E that do not meet the capitalization criteria, are 

recognized as an expense in the current period. (See

Note 5, General Property, Plant, and Equipment, Net.)

(j) Accrued Liabilities and Accounts 

Payable 

Accrued liabilities and accounts payable represent a 

probable future outflow or other sacrifice of resources 

from past transactions or events. Liabilities are

recognized when they are incurred, regardless of 

whether they are covered by budgetary resources. The

FTC has both entity and non-entity liabilities. Entity

liabilities cannot be liquidated without legislation 

that provides the resources to do so. In addition, the

government, acting in its sovereign capacity, can 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 69

FINANCIAL SECTION

abrogate the FTC’s liabilities (other than contracts)

Non-entity liabilities represent claims against nonentity 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. Governme

(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 percen

for both FERS-RAE and FERS-FRAE. In addition, the

FTC contributes the employer’s matching share to 

the Social Security Administration under the Federal 

Insurance Contributions Act (FICA), which fully covers 

FERS participating employees. FTC contributions are

recognized as current operating expenses

The Thrift Savings Plan (TSP) is a defined contribution 

retirement savings and investment plan for employees 

covered by either CSRS or FERS. Participating

employees may contribute any dollar amount or 

percentage of basic salary to the TSP, not to exceed 

an annual dollar limit set by law. In calendar year 2023,

the annual contribution limit is $22,500 and employees 

aged 50 and over may contribute an additional $7,500 

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 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 13, 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 
70 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

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 13, 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) Net Position 

The portion of the FTC’s budget authority funded 

by its no-year direct appropriation is fully expended 

during the year. Therefore, the remaining unexpended

appropriation balance in net position at the end of the 

fiscal year reflects the unspent ARPA funds

Cumulative results of operations represent the net 

results of operations since the agency’s inception, 

the cumulative amount of prior period adjustments, 

the remaining net book value of capitalized assets, 

and future funding requirements. (See Statement of

Changes in Net Position.)

(p) Revenues and Other Financing 

Sources 

As a component of the Government-wide reporting 

entity, the FTC is subject to the federal budget 

process, which involves annual appropriations

The financial transactions that are supported by 

budgetary resources, which include appropriations, 

are generally the same transactions reflected in 

agency and Government-wide financial reports

In addition to an annual appropriation provided 

by the Congress, the FTC’s activities are financed 

through exchange revenues it receives from others

Intragovernmental exchange revenues arise from 

reimbursable transactions with other federal entities

The FTC provides consulting and technical assistance 

aimed at developing sound competition policies under 

interagency agreements. Reimbursable revenue is

recognized as expenses are incurred

The majority of the FTC’s exchange revenues are 

from the public, consisting of fees collected for 

premerger notification filings under the HSR Act and 

fees collected for the National Do Not Call (DNC) 

Registry. The HSR Act establishes a waiting period

before mergers, acquisitions, or transfers of assets that 

meet or exceed certain thresholds may be completed

Entities must file premerger notifications with the 

FTC and the Antitrust Division of the DOJ. HSR fees

are split equally between the FTC and the DOJ with 

fees determined by the values and sizes of involved 

parties. As mandated by an amendment to the Clayton

Act, the FTC revises the jurisdictional threshold 

requirements annually based on the change in gross 

national product. The DNC Registry Fee Extension

Act of 2007 established a permanent fee structure for 

the DNC registry and provides that fees be reviewed 

annually and adjusted for inflation, as appropriate

Telemarketers must pay an annual subscription 

fee and download a list of telephone numbers of 

consumers who do not wish to receive calls. Fees

are based on the number of area codes downloaded

Revenues for both HSR and DNC fees are recognized 

upon collection.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 71

FINANCIAL SECTION

The reporting entity’s budgetary resources reflect past 

congressional action and enable the entity to incur 

budgetary obligations, but they do not reflect assets 

to the federal government as a whole. Budgetary

obligations are legal obligations for goods, services, 

or amounts to be paid based on statutory provisions

After budgetary obligations are incurred, Treasury 

will make disbursements to liquidate the budgetary 

obligations and finance those disbursements in the 

same way it finances all disbursements, which, is to 

borrow from the public if there is a budget deficit

(q) Methodology for Assigning Costs and 

Exchange Revenues 

The FTC allocates costs and exchange revenues on 

the Statement of Net Cost to its two major strategic 

goals: Protect Consumers and Maintain Competition

Costs and exchange revenues that are identified 

specifically with each of these two strategic goals 

are charged or credited directly. Costs not directly

attributable to these two goals, including costs related 

to the FTC’s third goal, Advance Performance, are 

allocated based on the percentage of dollars directly 

traceable to each of these two goals
72 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

Entity and non-entity assets consisted of the following as of September 30, 2023: 

(Dollars in thousands) 2023

Entity

2023

Non-Entity

2023

Total

Intragovernmental:

Fund balance with Treasury:

General funds $ 161,352 $ - $ 161,352

Deposit funds - consumer redress - 649,018 649,018

Accounts receivable, net 84 - 84

Advances and Prepayments 845 - 845

Total intragovernmental assets 162,281 649,018 811,299

Accounts receivable, net 49 39,865 39,914

Property, plant and equipment, net 16,348 - 16,348

Total Assets $ 178,678 $ 688,883 $ 867,561

Entity and non-entity assets consisted of the following as of September 30, 2022: 

(Dollars in thousands) 2022

Entity

2022

Non-Entity

2022

Total

Intragovernmental:

Fund balance with Treasury:

General funds $ 312,041 $ - $ 312,041

Deposit funds - consumer redress - 204,704 204,704

Accounts receivable, net 6 - 6

Advances and Prepayments 7 - 7

Total intragovernmental assets 312,054 204,704 516,758

Accounts receivable, net 41 45,134 45,175

Property, plant and equipment, net 19,643 - 19,643

Total Assets $ 331,738 $ 249,838 $ 581,576

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 as well as amounts paid to the Department 

of Defense for employee background investigations

The FTC’s non-entity assets include fund balance with 

Treasury and accounts receivable. The fund balance

with Treasury consists of amounts held temporarily 

in a deposit fund pending disbursement to harmed 

consumers for redress. Accounts receivable, net, is the

estimated amount collectible on consumer redress 

judgments and civil penalties
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 73

FINANCIAL SECTION

NOTE 3—FUND BALANCE WITH TREASURY 

There are no material differences between amounts 

reported by the FTC and those reported to U.

Treasury as of September 30, 2023, and 2022. 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 large decrease or zeroing out of Unavailable 

– Excess Offsetting Collections is the result of the 

FY2023 appropriation instructing the FTC to offset the 

general fund appropriation with all HSR Premerger 

fees collected prior to FY 2023 in excess of the 

congressional authorized amount.

The decrease or zeroing out of unavailable - 

temporary reduction of $6,450 thousand is the result 

of the FY 2023 appropriation instructing the FTC to 

offset the general fund appropriation which consisted 

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

thousand National Do Not Call Registry offsetting 

collections sequestered from FY 2013

The higher Non-Budgetary Fund Balance with Treasury 

is due to the large increase in Undisbursed Redress 

Collections of $444 million. Two cases that make up

most of the increase are collections from Epic Games, 

Inc., the Fortnite video game maker, for $245 million

for tricking users into unwanted purchases and $100 

million from Vonage Holdings Corp, the internet phone 

provider who imposed illegal charges and thwarted 

consumers and small businesses efforts from 

canceling their service

Fund balance with Treasury consisted of the following as of September 30, 2023 and 2022:

(Dollars in thousands) 2023 2022

Status of Fund Balance with Treasury:

Unobligated balance:

 Available - apportioned $ 60,921 $ 60,666 

 Unavailable - unapportioned 5,947 2,789

 Unavailable - excess offsetting collections - 166,072 

 Unavailable - temporary reduction - 6,450

Total unobligated balance: 66,868 235,977 

Obligated balance not yet disbursed 94,484 76,064 

Non-budgetary fund balance with Treasury 649,018 204,704 

Total Status of Fund Balance with Treasury $ 810,370 $ 516,745
74 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

NOTE 4—ACCOUNTS RECEIVABLE, NET 

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

or litigation of administrative and federal court cases in 

connection with the consumer redress program, and 

from civil monetary penalties imposed for violation 

of an FTC order and/or antitrust acts. Because of

the nature of these receivables, they are frequently 

not fully collectible and are offset with a significant 

allowance. The allowance for uncollectible accounts

is based on an analysis by a case manager who 

assesses the debtor’s ability and willingness to pay, 

the defendant’s payment history, and the probable 

recovery amount including the value of assets. These

non-entity accounts receivable are included in the 

financial statements along with offsetting non-entity 

liabilities

Non-entity redress gross accounts receivable is the 

court ordered judgment amount, usually a calculated 

amount of ill-gotten gains by the defendant(s)

Accounts receivable, net consisted of the following as of September 30, 2023:

(Dollars in thousands) Gross

Receivables 

Allowance for

Uncollectible

Accounts 

 2023 Net

 Entity Accounts Receivable: 

 Intragovernmental $ 84 $ - $ 84 

 With the public 49 - 49

 Total entity accounts receivable 133 - 133 

 Non-Entity Accounts Receivable: 

 Consumer redress 846,322 (806,895) 39,427 

 Civil penalties 938 (500) 438 

 Total non-entity accounts receivable 847,260 (807,395) 39,865

Total Accounts Receivable $ 847,393 $ (807,395) $ 39,998

Accounts receivable, net consisted of the following as of September 30, 2022:

(Dollars in thousands) Gross

Receivables 

Allowance for

Uncollectible

Accounts 

 2022 Net

 Entity Accounts Receivable: 

 Intragovernmental $ 6 $ - $ 6 

 With the public 41 - 41 

 Total entity accounts receivable 47 - 47 

 Non-Entity Accounts Receivable: 

 Consumer redress 1,347,604 (1,302,628) 44,976 

 Civil penalties 158 - 158 

 Total non-entity accounts receivable 1,347,762 (1,302,628) 45,134

Total Accounts Receivable $ 1,347,809 $ (1,302,628) $ 45,181 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 75

FINANCIAL SECTION

NOTE 5—GENERAL PROPERTY, PLANT, 

AND EQUIPMENT, NET 

The following represents the FTC’s capital assets and 

accumulated depreciation as of September 30, 2023, 

and 2022. No asset impairments were recognized in

either year. The net book value of capitalized assets

has declined from the previous fiscal year as a result 

of continual depreciation and amortization expenses

Current year depreciation and amortization expense 

is $3,406 thousand. Asset retirements equaled $3,830

thousand but had no impact to the Net Book Value as 

the assets were fully depreciated

Property, plant, and equipment, net consisted of the following as of September 30, 2023:

Asset Class

(Dollars in thousands)

Service 

Life

Acquisition 

Value

Accumulated 

Depreciation/

Amortization

Net 

Book Value

Equipment 5-20 Years $ 18,962 $ (18,218) $ 744 

Leasehold improvements 15 Years 47,085 (31,849) 15,236 

Software 5 Years 16,235 (15,867) 368

Total Property, Plant, and Equipment $ 82,282 $ (65,934) $ 16,348 

Property, plant, and equipment, net consisted of the following as of September 30, 2022:

Asset Class

(Dollars in thousands)

Service 

Life

Acquisition 

Value

Accumulated 

Depreciation/

Amortization

Net 

Book Value

Equipment 5-20 Years $ 20,620 $ (19,658) $ 962 

Leasehold improvements 15 Years 47,317 (29,191) 18,126 

Software 5 Years 18,064 (17,509) 555 

Total Property, Plant, and Equipment $ 86,001 $ (66,358) $ 19,643 

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 fees owed to other federal agencies

In FY 2022, the FTC received funding for information 

technology enhancements through GSA’s Technology 

Modernization Fund (TMF) with a requirement to repay 

a portion of the monies back to GSA in fiscal years 

2023 and 2024
76 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

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. Governme

Liabilities Not Covered by Budgetary Resources consisted of the following as of September 30, 2023:

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2023 Total

Intragovernmental Liabilities:

FECA liability $ - $ - $ -

Employment-Related Liability 10 - 10

Fees owed under interagency agreements 135 - 135

Accrued civil penalties and receipts due to 

treasury - 438 438

Total Intragovernmental Liabilities 145 438 583 

Non-Federal Liabilities:

Accrued leave 17,749 - 17,749 

Actuarial FECA 791 - 791 

Undisbursed redress collections - 649,018 649,018 

Accrued redress due to claimants - 39,427 39,427 

Total Non-Federal Liabilities 18,540 688,445 706,985 

Total Unfunded Liabilities 18,685 688,883 707,568 

Liabilities Covered by Budgetary Resources 18,765 

Total Liabilities $ 726,333

Liabilities Not Covered by Budgetary Resources consisted of the following as of September 30, 2022:

(Dollars in thousands) Not Covered by Budgetary 

Resources

Not Requiring Budgetary 

Resources FY 2022 Total

Intragovernmental Liabilities:

FECA liability $ 49 $ - $ 49

Employment-Related Liability

Fees owed under interagency agreements 285 - 285

Accrued civil penalties and receipts due to 

treasury - 158 158

Total Intragovernmental Liabilities 334 158 492 

Non-Federal Liabilities:

Accrued leave 16,774 - 16,774 

Actuarial FECA 810 - 810 

Undisbursed redress collections - 204,704 204,704 

Accrued redress due to claimants - 44,976 44,976 

Total Non-Federal Liabilities 17,584 249,680 267,264 

Total Unfunded Liabilities 17,918 249,838 267,756 

Liabilities Covered by Budgetary Resources 17,794 

Total Liabilities $ 285,550

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
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 77

FINANCIAL SECTION

NOTE 7—OTHER LIABILITIES 

As of September 30, 2023, and 2022, components 

of amounts reported on the Balance Sheet as Other 

Intragovernmental Liabilities and Other Liabilities 

(Other Than Intragovernmental) are presented below

FECA liabilities are long-term in nature and are not 

funded with budgetary resources while accrued 

employee benefits and accrued funded payroll 

and leave are covered by budgetary resources. For

Government-wide reporting, the liabilities for Accrued 

Redress Due to Claimants and Undisbursed Redress 

Collections are reported as Other Liabilities in the 

Financial Report of the U.S. Government. Becau

these liabilities are material to the FTC, they are 

displayed as separate line-items on the agency’s 

Balance Sheet. (See Note 6, Liabilities Not Covered by

Budgetary Resources.

Other Liabilities consisted of the following as of September 30, 2023 and 2022:

(Dollars in thousands) 2023 2022

Intragovernmental liabilities:

Accrued employee benefits $ 1,151 $ 1,012

FECA liability - 49 

Fees owed under interagency agreements 135 285

Accrued civil penalties and receipts due to treasury 438 158

Total intragovernmental liabilities 1,724 1,504

Other than intragovernmental liabilities:

Accrued funded payroll and leave 3,905 3,446

Unfunded accrued annual leave 17,749 16,774

Actuarial FECA 791 810 

Total other than intragovernmental liabilities 22,445 21,030 

Total Other Liabilities $ 24,169 $ 22,534
78 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

NOTE 8—LEASES 

Leases of government-owned and commercialowned 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 undersigned lease agreements. The

FTC currently leases spaces from four governmentowned properties and seven commercial properties 

totaling approximately 590 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 2033. Future minimum lease payments

owed to GSA on contracts for space 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, 2023:

Fiscal Year 2023 (Dollars in thousands)

2024 $ 8,096

2025 8,108

2026 8,121

2027 8,093

2028 7,902

Thereafter 7,318 

Total Future Minimum Lease Payments $ 47,638 

Future minimum lease payments due under leases of commercial-owned 

property for the fiscal year ended September 30, 2023:

Fiscal Year 2023 (Dollars in thousands)

2024 $ 7,401 

2025 2,166 

2026 1,824 

2027 1,748 

2028 1,035 

Thereafter 3,267

Total Future Minimum Lease Payments $ 17,441

In addition, the FTC is committed under short-term 

lease agreements with commercial vendors for 

parking and telecommunications equipment. Total

short-term lease obligations are $2,084 thousand as 

of September 30, 2023, and these contracts expire in 

fiscal years 2023 through 2027 with options to renew

NOTE 9–INTER-ENTITY COSTS 

Goods and services may be received from other 

federal entities at no cost or at a cost less than the 

full cost to the providing federal entity. In accordance

with accounting standards, certain costs of the 

providing federal entity that are not fully reimbursed 

are recognized as imputed costs in the Statement 

of Net Cost and are offset by imputed financing 

sources in the Statement of Changes in Net Position

Such imputed costs and financing sources relate 

to employee benefits paid by the OPM. No other

unreimbursed costs of goods and services are 

included in the FTC’s financial statements as imputed 

costs and imputed financing sources
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 79

FINANCIAL SECTION

NOTE 10—STATEMENT OF BUDGETARY RESOURCES 

In addition to future lease commitments discussed in Note 8, the FTC is committed under obligations for goods 

and services that have been ordered but not yet received. Aggregate undelivered orders are presented in the

table below

Undelivered obligations consisted of the following as of September 30, 2023 and 2022:

(Dollars in thousands) 2023 2022

Non-Federal Undelivered Orders Unpaid $ 68,138 $ 53,326

Non-Federal Undelivered Orders Paid - -

Total Non-Federal Undelivered Orders 68,138 53,326

Federal Undelivered Orders Unpaid 9,929 7,413 

Federal Undelivered Orders Paid 845 7 

Total Federal Undelivered Orders 10,774 7,420 

Total Undelivered Orders $ 78,912 $ 60,746 

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 2024 President’s Budget, which contains FY 2022 

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 2022 Statement of

Budgetary Resources and the FY 2022 actual amounts as reported in the FY 2024 President’s Budget; however, 

the Statement of Budgetary Resources includes Distributed Offsetting Receipts, which are excluded from the 

President’s Budget. The FY 2025 Budget of the United States Government is not available to compare FY 2023

actual amounts to the FY 2023 Statement of Budgetary Resources. The expected availability for this report is

February 2024 on the OMB’s website.

NOTE 11—CUSTODIAL ACTIVITIES 

The primary custodial activities of the FTC are: 

Premerger Filing Fees 

Fees collected for premerger notification filings 

under the HSR Act are divided evenly between the 

FTC and the DOJ. In FY 2021, the FTC implemented a

new collection process for the Premerger filing fees.

Collections are now split evenly between the FTC and 

the DOJ upon receipt. Under the previous method,

the FTC collected the full amount and remitted half 

to the DOJ, which resulted in a custodial liability 

and custodial transfers. As of September 30, 2023

and 2022, the FTC collected $171,814 and $191,420 

thousand in HSR premerger filing fees.

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.

Government at the end of the fiscal year. In FY2023,

the FTC collected $266.75 million from Epic Games,

Inc., creator of the popular video game Fortnite for

violating the Children’s Online Privacy Protection 
80 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

Act (COPPA) – the largest penalty ever obtained for 

violating an FTC rule. Additionally, in a first-of-its-kind

provision, Epic will be required to adopt strong privacy 

default settings for children and teens, ensuring that 

voice and text communications are turned off by 

default. In FY 2022, the FTC collected $146 million

from Twitter for deceptively using account security 

data to sell targeted ads to its users.

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

$4,406 thousand as of September 30, 2023 and 

$14,348 thousand as of September 30, 2022

Other line items on the Statement of Custodial Activity 

include: 

Accrual Adjustment

Accrual adjustments represent the change in accounts 

receivable, net of allowances for uncollectible 

accounts, for civil penalties assessed in court actions.
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 81

FINANCIAL SECTION

NOTE 12—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 

$41,841and $325,056 thousand as of September 30, 

2023, and 2022

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, 2023 and 2022:

(Dollars in thousands) 2023 2022

Consumer Redress:

Fund Balance with Treasury

Beginning balance $ 204,704 $ 384,821 

Collections 490,561 159,287 

Disbursements to claimants and third party administrators 

for redress, net (41,841) (325,056)

Disgorgements to Treasury, net (4,406) (14,348)

Total Fund Balance with Treasury, Ending $ 649,018 $ 204,704 

Accounts Receivable, Net

Beginning balance $ 44,976 $ 51,116

Net activity (5,549) (6,140) 

Total Accounts Receivable, Ending $ 39,427 $ 44,976 
82 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

FINANCIAL SECTION

NOTE 13—RECONCILIATION OF NET 

OPERATING COST AND NET BUDGETARY 

OUTLAYS

In accordance with the requirements of SFFAS 7, 

Accounting for Revenue and Other Financing Sources, 

as amended by SFFAS 53, Budget and Accrual 

Reconciliation, the schedules presented below bridge 

the gap between the net operating costs presented 

on the Statement of Net Cost and the net outlays 

presented on the Statement of Budgetary Resources 

for the fiscal years ended September 30, 2023, and 

2022. Net cost is calculated on an accrual basis while

net outlays consist of the receipt and use of cash 

from a budgetary basis. This reconciliation assures

the integrity of relationships between proprietary and 

budgetary accounting

Reconciliation of Net Operating Cost and Net Budgetary Outlays for the Year Ended September 30, 2023:

(Dollars in thousands)

FY 2023

Intragovernmental With the Public Total

Net Operating Cost (SNC) $ 106,675 $ 123,816 $ 230,491

Components of Net Operating Cost Not Part of the Budgetary Outlays

Depreciation and Amortization - (3,405) (3,405)

Losses on Asset Dispositions - - - 

Increase/(Decrease) in Assets 916 8 924

(Increase)/Decrease in Liabilities 288 (2,176) (1,888)

Imputed Costs (16,063) - (16,063)

Total Components of Net Operating Cost Not Part of the Budgetary Outlays (14,859) (5,573) (20,432)

Components of Budgetary Outlays Not Part of Net Operating Cost

Purchases of Assets - 261 261 

Transfers Out (in) Without Reimbursement - - - 

Total Components of Budgetary Outlays Not Part of Net Operating Cost - 261 261

Other Reconciling Items

Miscellaneous Receipts - (4,421) (4,421)

Total Other Reconciling Items - (4,421) (4,421) 

Net Outlays (Calculated) $ 91,816 $ 114,083 $ 205,899

Budgetary Agency Outlays, Net - Statement of Budgetary Resources $ 205,899 

Reconciliation of Net Operating Cost and Net Budgetary Outlays for the Year Ended September 30, 2022:

(Dollars in thousands)

FY 2022

Intragovernmental With the Public Total

Net Operating Cost (SNC) $ 95,450 $ 58,032 $ 153,482 

Components of Net Operating Cost Not Part of the Budgetary Outlays

Depreciation and Amortization - (3,742) (3,742)

Losses on Asset Dispositions - (66) (66)

Increase/(Decrease) in Assets (25) (9) (34)

(Increase)/Decrease in Liabilities 1,710 4,846 6,556

Imputed Costs (10,634) - (10,634)

Total Components of Net Operating Cost Not Part of the Budgetary Outlays (8,949) 1,029 (7,920)

Components of Budgetary Outlays Not Part of Net Operating Cost

Purchases of Assets - 1,189 1,189 

Transfers Out (in) Without Reimbursement (1) - (1)

Total Components of Budgetary Outlays Not Part of Net Operating Cost (1) 1,189 1,188

Other Reconciling Items

Miscellaneous Receipts - (14,361) (14,361)

Total Other Reconciling Items - (14,361) (14,361) 

Net Outlays (Calculated) $ 86,500 $ 45,889 $ 132,389

Budgetary Agency Outlays, Net - Statement of Budgetary Resources $ 132,389 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 83

FINANCIAL SECTION

NOTE 14—COVID-19 ACTIVITY 

In FY 2021, the FTC received an appropriation of 

$30,400 thousand through the American Rescue 

Plan Act (ARPA), signed into law by President Biden 

on March 11, 2021. ARPA funds were made available

through the end of FY 2026. This appropriation

authorized funding for the FTC to cover higher costs 

associated with the COVID-19 pandemic of 2020-

2022. Funding for the FTC under ARPA includes

payroll costs, consumer education, and monitoring 

of consumer complaints received into the Consumer 

Sentinel Network.

In May 2023, the Fiscal Responsibility Act of 2023 

rescinded $11,072 thousand of the ARPA funds, the 

amount of unobligated funds at the time, leaving only 

funds to cover current obligations. As of September

30, 2023, $2,544 thousand remains.

Summarized financial information is provided below

Summarized COVID-19 financial activity for the fiscal years ended September 30, 2023 and 2022:

(Dollars in thousands) 2023 2022

Total Assets $ 2,544 $ 19,206

Total Liabilities (320) -

Net Operating Results (5,911) (7,794)

Appropriations Used 5,911 7,794

Unexpended Appropriations 2,224 19,206 

Budgetary Resources $ 6,288 $ 26,010

Obligations Incurred 6,288 8,650

Unobligated Balance - 17,360

Net Outlays $ 5,591 $ 7,794 
FEDERAL TRADE COMMISSION
OTHER

INFORMATION

FISCAL YEAR 2023
FEDERAL TRADE COMMISSION
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 87

OTHER INFORMATION

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
88 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

OTHER INFORMATION

Summary of the Top Management and 

Performance Challenges Identified by the 

Office of Inspector General

As required by the Reports Consolidation Act of 2000, the 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 

As with any other federal government agency, the FTC must remain vigilant in securing its networks and systems 

against ever-changing IT security threats. As we noted in last year’s Top Management and Performance Challenges 

(TMC) report, our most recent Federal Information Security Modernization Act of 2014 (FISMA) audit has 

concluded that the FTC’s information security program and practices were effective. Nonetheless, there will be 

significant tasks that lie ahead for (a) elevating the agency’s supply chain risk management (SCRM) maturity level 

and (b) aligning the agency’s security posture with the federal government’s evolving requirements for establishing 

zero trust architecture (ZTA). 

FTC Progress in Addressing the Challenge. FTC management reports having taken steps to finish implementing 

controls that comprise its SCRM. The FTC also reports having made steady progress on its ZTA implementation. 

The FTC communicated to the OIG that its ongoing ZTA implementation continues to be a priority for the 

Commission; however, given potential resource constraints, the agency anticipates that this work may extend 

beyond FY 2024. 

2. Addressing Challenges to FTC Litigation 

The FTC continues to grapple with how to obtain relief effectively for consumers following last year’s Supreme 

Court decision in AMG Capital Management, LLC v. FTC, 593 U.S. __, 141 S. Ct. 1341 (2021) (“AMG”) and 

Axon Enterprise, Inc. v. FTC, 598 U.S. __, 143 S. Ct. 890 (Apr. 14, 2023) (Axon). In 2021, AMG stripped 

federal courts of the authority—which they had been exercising for more than 4 decades—to award equitable 

monetary relief to consumers when the FTC obtains a permanent injunction in federal court pursuant to FTC Act 

Section 13(b), 15 U.S.C. § 53(b). Since the decision, the FTC’s primary means of obtaining monetary relief is 

through FTC Act Section 19. For cases post-AMG that involve deceptive or unfair conduct that does not violate 

an existing FTC rule, the process is time-consuming and resource-intensive, because it requires agency staff to 

litigate the case twice––once through the administrative process, and then in federal court. And, after AMG and 

Axon, the FTC’s use of Section 19 to obtain monetary relief for consumers is vulnerable to further limitations 

and easier delays through constitutional challenges in federal court. 

FTC Progress in Addressing the Challenge. The FTC reports having taken several steps to maximize its ability 

to bring successful cases and obtain monetary relief for consumers in this new legal landscape. First, the FTC 

asserts that its Bureau of Consumer Protection (BCP) continues to focus its enforcement efforts on cases that 

involve rule violations for which they can obtain monetary relief directly in federal court under Section 19(a)(1). 

In addition, BCP reports that it has turned to using alternative remedial authorities, such as the Penalty Offense 

Authority—which allows it to seek civil penalties if an entity engages in conduct that the FTC has previously 

found unfair or deceptive in an administrative order other than a consent. The FTC also asserts that it has 

initiated several rulemakings to increase the number of cases it could bring directly in federal court pursuant to 

Section 19(a)(1). Finally, the FTC reports its continued support and technical assistance to Congress on proposed 

legislation that would restore its authority to obtain monetary relief in federal court under 13(b). 

3. Successfully Managing the Volume of Merger Transactions 

How the FTC can most efficiently and effectively manage its workload related to the Hart-Scott-Rodino 

Antitrust Improvements Act of 1976 (HSR Act)—and the difficulties encountered by Bureau of Competition 

(BC) attorneys charged with reviewing reported HSR transactions—has persisted as one of the agency’s top 

management and performance challenges. The shift that the FTC may be experiencing in oversight relationship 
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 89

OTHER INFORMATION

with merger-proposing entities, along with approaches that entities more often deploy in disputes with the agency, 

present an evolving merger landscape. On June 29, 2023, the FTC issued a proposed rulemaking with the stated 

intent of expanding the information available to the agency, thereby improving the efficiency and effectiveness 

of premerger reviews—including thorough changes to its Premerger Notification and Report Form to expand the 

information available to the agency, to improve the efficiency and effectiveness of premerger reviews. 

FTC Progress in Addressing the Challenge. Regarding its June 29, 2023, proposed rulemaking, the FTC reports 

that receiving additional information up-front will allow the agency to more effectively use the initial 30-day 

waiting period before issuing a second request. On the heels of the FTC’s proposed amendments to the premerger 

notification rules, in a separate July 19, 2023, draft proposal for public comment, the FTC and the DOJ issued 

joint merger guidelines with a similar update rationale to “reflect the collected experience of the Agencies over 

many years of merger review in a changing economy.” 

4. Combating Increasingly Sophisticated Imposter Scams and Enhancing the Public’s Awareness 

of Them

Given the FTC’s role as the nation’s primary consumer protection agency, the OIG considers the FTC’s ability to 

stay on top of increasingly sophisticated scam tactics against consumers and educating them about these tactics to 

be a top management and performance challenge. Imposter scams have become a significant fraud type reported 

to the FTC, resulting in reported losses of $2.6 billion. Further, the perpetrators of these scams can conduct their 

schemes from overseas locations, while masking their identities and locations, making it difficult for the agency 

to locate and pursue fraud perpetrators. The fight against consumer scams remains an uphill battle. Scammers 

continue to evolve, using increasingly sophisticated methods in their illegal operations. As scammers increase the 

sophistication of their methods and regularly adapt tactics to exploit vulnerabilities and evade detection, the FTC 

must also continue to innovate to keep pace. 

FTC Progress in Addressing the Challenge. Consistent with its consumer protection mission, the FTC has taken a 

multi-pronged approach in its attempts to combat increasingly sophisticated scams and enhance public awareness: 

through public awareness and education (via its website and blogs); the proposed Rule on Impersonation 

of Government and Business from December 2021; disruption through court cases and Point of No Entry 

technology; and collaboration with other agencies via its Consumer Sentinel Network cyber tool for federal, state, 

and local law enforcement agencies investigating scams. 

Through these measures, the FTC has demonstrated that combating and preventing fraud, including imposter 

scams, remains a priority. Nonetheless, increasingly sophisticated measures to combat scam tactics must be 

developed to protect consumers. 

Watch List Item

The OIG also maintains a “watch list,” currently with one issue that does not meet the threshold of a serious management or performance challenge—but nevertheless warrants the vigilant attention of agency officials. 

The FTC’s Oversight of the Horseracing Integrity and Safety Authority

The Horseracing Integrity and Safety Act of 2020 (the Act) requires the FTC to oversee the newly established 

Horseracing Integrity and Safety Authority (HISA)—whose purpose is to develop and implement a horseracing anti-doping and medication control program, as well as a racetrack safety program. The agency does not currently have 

the expertise in the horseracing industry—or in such narrower fields as racetrack safety and anti-doping and medication control—that is necessary to provide effective oversight. 

Agency Comments. The FTC reports having taken several measures to exercise its statutory obligation to enforce this 

Act. Most significantly, the agency asserts that it has focused on transparency in HISA’s operations, rules, and budget. 

The FTC reports exploring other possible ways in which the agency, consistent with the Act, can ensure HISA’s 

adoption of best practices for effective governance. In addition, the FTC reports that it has designated a matrixed 

cross-agency group of staff to work on HISA-related issues—and engaged in benchmarking discussions with multiple federal agencies that oversee independent self-regulatory organizations. 

1

The entire FY 2023 report is available at https://www.ftc.gov/system/files/ftc_gov/pdf/OIG-FY-2023-Top-Management-ChallengesReport-09-29-2023.pdf
90 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

OTHER INFORMATION

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 2021 risk assessment 

for all major payment programs including payroll, 

procurement, redress payments to consumers, travel, 

purchase card, premerger filing fee refunds, training, 

and two miscellaneous payment processes. The FTC

evaluated each payment program over $1 million using 

the following qualitative risk factors identified in OMB 

Circular A-123 Appendix C: 

• The relative complexity of the program or activity 

operation 

• The extent and significance of recent changes in the 

program that may be reason for improper payment in 

funding, authorities, practices and procedure 

• The extent and significance of recent changes in 

program payment amounts or volume of payments 

• The level, experience, and quality of training 

for personnel responsible for program eligibility 

determination or certifying that payments are 

accurate 

• The inherent risks of improper payments due to the 

nature of programs or operation 

• Known control deficiencies (i.e., reported by OIG, 

or GAO) that might hinder accurate payment 

certification 

The FTC also performed a quantitative risk assessment 

which assessed risks related to the amounts of 

payments processed relative to the OMB specified 

threshold amounts that define payment programs 

susceptible to improper payments. As a result of the

FY 2021 risk assessment, the FTC determined that the 

agency’s programs and activities presented low risk 

of improper payments and that none of the agency’s 

programs or activities were determined to be 

susceptible to significant improper payments

The FTC also reviews potential matches on an ongoing basis and incorporates a pre-award check 

on potential contractors against the Do Not Pay 

databases to prevent improper payments. In 2015, the

FTC performed and documented testing of statistical 

samples from larger payment processes to verify that 

the FTC payment programs are not susceptible to 

significant improper payments which served as the 

baseline for the FY 2021 risk assessment. Per OMB

guidance and the result of the FY 2021 IPERIA risk 

assessment, no assessment was conducted during 

FY 2023 and the next assessment is scheduled for 

FY 2024. In addition, the FTC regularly conducts

assessments over the internal controls over payment 

processes. In 2023, the FTC performed an assessment

of the Human Resources payroll and benefit process 

including the Student Loan Repayment Program to 

assess the effectiveness of controls over the proper 

authorization, approval, and processing of payments

For programs with more than $1 million of 

expenditures, the FTC determined and documented 

that performing recapture audits were not cost 

effective. The FTC’s analysis had two parts; first the

error rates determined during the FY 2015 quantitative 

risk assessment, and second the documented 

management assessments of the effective operation 

of controls within the payment processes. The 2015

test work used statistical methods to project error 

rates to the population of payments for the larger 

payment processes. These larger payment amounts

could have produced errors classifying the process 

as ‘Significant’. This test work did not detect errors

within the population of payments and, therefore, did 

not identify payments subject to recapture. Recent

management assessments of each payment process 

determined sufficient controls to detect and prevent 

improper payments were in place and operating 

effectively. As a result, the Office of the Chief Financial

Officer determined and documented that projected 

amounts subject to recapture audits are “de minimis” 

and recapture audits are not cost-effective
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 91

OTHER INFORMATION

CIVIL MONETARY PENALTY ADJUSTMENT FOR INFLATION 

The Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by the Federal Civil Penalties Inflation 

Adjustment Act Improvements Act of 2015, requires agencies to make regular and consistent inflationary 

adjustments of civil monetary penalties to improve the effectiveness of civil monetary penalties and to maintain 

their deterrent effect. The 2015 Act requires agencies to: (1) adjust the level of civil monetary penalties with an

initial “catch-up” adjustment; and (2) make subsequent annual adjustments for inflation. Accordingly, the Federal

Trade Commission increased its maximum civil penalty amounts to address inflation since the initial catch-up 

adjustment

The following table lists the civil monetary penalties that the FTC may impose, the authority for imposing the 

penalty, penalty description, year enacted, latest year of adjustment, current penalty level, the Bureau that 

administers the penalty, and location for penalty update details. Additional information about these penalties and

the latest adjustment is available in the Federal Register.

Statutory 

Authority 

Penalty 

(Name or 

Description)

Year 

Enacted

Latest year of 

adjustment 

(via statute or 

regulation)

Current 

Penalty Level 

($ Amount or 

Range)

SubAgency/ 

Bureau/

Unit

Location 

for Penalty 

Update Details

Section 7A(g)(1) of the Clayton Act,

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

Premerger filing 

notification 

violations under 

the HartScott-Rodino 

Improvements 

Act

1976 January 10, 2023 $ 50,120 BC Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 11(l) of the Clayton Act, 15

U.S.C. 21(l)

Violations of 

cease and desist 

orders issued 

under Clayton 

Act

section 11(b)

1959 January 10, 2023 $ 26,628 BC Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 5(l) of the FTC Act, 15

U.S.C. 45(l)

Unfair or 

deceptive acts or 

practices

1973 January 10, 2023 $ 50,120 BC and 

BCP

Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 5(m)(1)(A) of the FTC Act,

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

Unfair or 

deceptive acts or 

practices

1975 January 10, 2023 $ 50,120 BC and 

BCP

Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 5(m)(1)(B) of the FTC Act,

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

Unfair or 

deceptive acts or 

practices

1975 January 10, 2023 $ 50,120 BC and 

BCP

Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 10 of the FTC Act, 15 U.S.C.

50

Failure to file 

required reports

1914 January 10, 2023 $ 659 BC and 

BCP

Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 5 of the Webb-Pomerene

(Export Trade) Act, 15 U.S.C. 65

Failure by 

associations 

engaged solely 

in export trade 

to file required 

statements

1918 January 10, 2023 $ 659 BC Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500
92 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

OTHER INFORMATION

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

Section 6(b) of the Wool Products

Labeling Act, 15 U.S.C. 68d(b)

Failure by wool 

manufacturers 

to maintain 

required records 

1940 January 10, 2023 $ 659 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 3(e) of the Fur Products

Labeling Act, 15 U.S.C. 69a(e)

Failure to 

maintain 

required records 

regarding fur 

products 

1951 January 10, 2023 $ 659 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 8(d)(2) of the Fur Products

Labeling Act, 15 U.S.C. 69f(d)(2)

Failure to 

maintain 

required records 

regarding fur 

products 

1951 January 10, 2023 $ 659 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 333(a) of the Energy Policy

and Conservation Act, 42 U.S.C. 

6303(a)

Knowing 

violations of 

EPCA § 332,

including 

labeling 

violations

1975 January 10, 2023 $ 542 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 525(a) of the Energy Policy

and Conservation Act, 42 U.S.C. 

6395(a)

Recycled 

oil labeling 

violations

1975 January 10, 2023 $ 26,628 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 525(b) of the Energy Policy

and Conservation Act, 42 U.S.C. 

6395(b)

Willful violations 

of recycled 

oil labeling 

requirements

1975 January 10, 2023 $ 50,120 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 621(a)(2) of the Fair Credit

Reporting Act, 15 U.S.C. 1681s(a)(2)

Knowing 

violations of the 

Fair Credit

Reporting Act

1996 January 10, 2023 $ 4,705 BCP Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 1115(a) of the Medicare

Prescription Drug Improvement and

Modernization Act of 2003, Public 

Law

108–173, as amended by Public 

Law

115–263, 21 U.S.C. 355

Failure to

comply with filing 

requirements

2003 January 10, 2023 $ 17,719 BC Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500

Section 814(a) of the Energy

Independence and Security Act of 

2007,

42 U.S.C. 17304

Violations of

prohibitions 

on market 

manipulation

and provision of 

false information 

to

federal agencies

2007 January 10, 2023 $ 1,426,319 BC Federal Register 

Vol. 88, January 

11, 2023, pages 

1499-1500
APPENDICES

FISCAL YEAR 2023
FEDERAL TRADE COMMISSION
APPENDICES

FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 95

APPENDIX A: ACRONYMS

Because many of the acronyms in this document are not commonly used, or have multiple meanings, this 

Appendix is provided as a reference. This is not all-inclusive, and only meant to show how these acronyms are

used in the context of this AFR

Acronym Definition

AFR Agency Financial Report 

AI/AN American Indian and Alaska Native

APP Annual Performance Plan 

APR Annual Performance Report 

ARC Administrative Resource Center

ARPA American Rescue Plan Act of 2021 

ATO Authorized to Operate

BC Bureau of Competition 

BCP Bureau of Consumer Protection 

BE Bureau of Economics

CGE Concur Government Edition 

COPPA Children’s Online Privacy Protection Act

CSN Consumer Sentinel Network

CSRS Civil Service Retirement System 

DATA Act Digital Accountability and Transparency Act of 2014 

DNC Do Not Call 

DOJ Department of Justice 

DOL Department of Labor 

DQA Data Quality Appendix

ERM Enterprise Risk Management 

FASAB Federal Accounting Standards Advisory Board 

FBwT Fund Balance with Treasury 

FECA Federal Employees’ Compensation Act 

FEGLIP Federal Employees’ Group Life Insurance Program 

FEHBP Federal Employees’ Health Benefit Program 

FERS Federal Employees’ Retirement System 

FERS-FRAE Federal Employees’ Retirement System – Further Revised Annuity Employees

FERS-RAE Federal Employees’ Retirement System – Revised Annuity Employees

FEVS Federal Employee Viewpoint Survey

FISMA Federal Information Security Management Act 

FMFIA Federal Managers’ Financial Integrity Act 

FMO Financial Management Office 

APPENDICES
96 FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023

APPENDICES

Acronym Definition

FTC Federal Trade Commission 

FTE Full-Time Equivalent 

FY Fiscal Year 

GAAP Generally Accepted Accounting Principles 

GAO Government Accountability Office 

GSA General Services Administration 

HSR Hart-Scott-Rodino Act 

IBC Department of the Interior Business Center 

ICE Intercontinental Exchange

ICOR Internal Control Over Reporting

IG Inspector General 

IPERIA Improper Payments Elimination and Recovery Improvement Act 

IPP Invoice Processing Platform

IT Information Technology 

LOS Loan Origination Systems

NIST National Institute of Standards and Technology 

OFF Oracle Federal Financials 

OIG Office of Inspector General 

OMB Office of Management and Budget 

OPM Office of Personnel Management 

PIO Performance Improvement Officer

PMRO Performance Measure Reporting Official 

PPE Product Pricing and Eligibility Engines

PP&E Property, Plant, and Equipment 

PRISM Procurement Information System for Management

SAT Senior Assessment Team 

SBR Statement of Budgetary Resources 

SFFAS Statement of Federal Financial Accounting Standards

SMC Senior Management Council

TAS Treasury Account Symbol 

TMF Technology Modernization Fund

TSP Thrift Savings Plan

VoIP Voice Over Internet Protocol
FEDERAL TRADE COMMISSION Agency Financial Report FISCAL YEAR 2023 97

APPENDICES

APPENDIX B: CONTACT INFORMATION AND ACKNOWLEDGEMENTS

FEDERAL TRADE COMMISSION 600 Pennsylvania Avenue, NW

Washington, D.C. 205

General Information Number 202-326-2222

Internet Home Page www.ftc.g

FTC Spanish Home Page www.ftc.gov/espan

Strategic Plan Internet Site https://www.ftc.gov/about-ftc/budget-strategy

strategic-plan

FTC Press Releases https://www.ftc.gov/news-events/news/press-releas

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 https://www.ftc.gov/about-ftc/budget-strategy/budgetperformance-financial-reporti

AFR Contact Randall Salzer

AFR Telephone 202-326-2028

AFR Email Address gpra@ftc.go

AFR Mailing Address Federal Trade Commission

Attn: AFR, M/D H-701 

600 Pennsylvania Avenue, NW

Washington, D.C. 205

CONSUMER RESPONSE CENTER

FTC Complaint Assistant https://reportfraud.ftc.gov

Identity Theft Education, Complaints, and Recovery Plan www.identitytheft.go

National Do Not Call Registry www.donotcall.go

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 

ACKNOWLEDGEMENTS

The FTC offers our sincerest thanks and acknowledges the following individuals who made significant contributions 

in producing this report: Thomas Dahdouh, Michelle Grajales, Kevin Moriarty, Mark Suter, and Elizabeth Wilkins of the 

Office of the Chair; Gretchen Abraham, George Adam, Sharon Ball, Chris Bryan, David Burgman, Danette Diaz-Juarez, 

James Hale, Stephen Laurance, David Rebich, David Robbins, Randall Salzer, Anthony Timpanaro, and Lori Walsh-Van 

Wey of the Office of the Executive Director; Nathan Hawthorne of the Bureau of Competition; Jenny Kellogg of the 

Bureau of Consumer Protection; Catherine Wayne of the Office of Congressional Relations; Mary Harmison and Andrew 

Katsaros of the Office of the Inspector General; Mitchell Katz and Zehra Khan of the Office of Public Affairs. Finally, we 

offer thanks to Red Creek Solutions and Graphic Visions for their contributions in the design and production of 

this report
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