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Although primarily an enforcement agency, the Federal Trade Commission (FTC) has issued a historic number of proposed rules over the past two years. From prohibiting non-compete provisions potentially impacting 30 million employment contracts or privacy and data security rules implicating personal information online, these proposed rules will affect most sectors of the U.S. economy. This panel of experts will explore how a federal agency undertakes the cost-benefit analysis for proposed rules, comparing independent agencies to those subject to OIRA review, and provide practical tips for lawyers and economists working on agency rulemaking comments.


  • Dr. Andrew Stivers, Associate Director, NERA Economic Consulting
  • Paul Ray, Director, Thomas A. Roe Institute for Economic Policy Studies, The Heritage Foundation
  • Jonathan Wolfson, Chief Legal Officer and Policy Director, Cicero Institute
  • Paul Metrey, Senior Vice President, Regulatory Affairs, National Automotive Dealers Association 
  • [Moderator] Svetlana Gans, Partner, Gibson, Dunn & Crutcher, LLP

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As always, the Federalist Society takes no position on particular legal or public policy issues; all expressions of opinion are those of the speaker.