Full speed ahead on FTC, CFPB, DOT, FCC rulemakings, and prepare to defend them in court.
Use agency rulemaking and enforcement to make “all‑in pricing” the default and treat hidden fees as an unfair or deceptive practice. This strategy focuses on building strong administrative records (comments, evidence, coalitions), tracking decision windows across agencies, and preparing rapid legal defense when industry challenges rules in court. The goal is rules that are not only finalized, but enforced with visible outcomes.
Why this works
- Agencies can often move faster than Congress.
- The FTC’s broad trade regulation rule on fees could set a baseline across the economy – essentially outlawing deceptive fee practices as an “unfair or deceptive act.” Supporting and expediting that process (through public comments, expert evidence) is key.
- Similarly, ensure the CFPB finalizes its credit card fee cap and perhaps starts rulemaking on other bank fees.
- DOT should finalize its airline pricing transparency and family seating rules, FCC should mandate “what you see is what you pay” on cable/Internet bills (the Biden administration asked them to).
- This multipronged approach addresses different industries in parallel.
- Then, be ready with legal defenses: a coalition of consumer advocacy orgs and supportive state attorneys general can intervene to uphold these rules if industry sues.
- Many states (especially Democratic AGs) would defend the FTC rule, for instance, given how popular it is with constituents (some Republican AGs might join too since red states hate Ticketmaster fees as much as blue states).
National Committee to Preserve Social Security and Medicare
AdvocacyProtecting and enhancing retirement and health security for seniors
Mechanism
About LobbyingHow National Committee to Preserve Social Security and Medicare uses funding
- Define the objective per agency: what “all‑in pricing” requires and what practices count as deceptive.
- Build the case with consumer evidence, coalition alignment, and clear proof points for regulators.
- Submit comments and support agency processes through hearings, rulemaking steps, and implementation guidance.
- Track industry challenges and prepare coordinated legal defense (amicus, expert support, and rapid analysis).
- Support enforcement readiness by surfacing patterns of violations and reporting pathways.
- Publish plain-language updates on what changed and what consumers should expect.
Milestones
Checkpoints and the expected timing for each step
- 1
Coalition record built
0–30 daysComments, evidence, and supportive sign-ons are ready for key rulemaking steps.
- 2
Rules finalized + implementation guidance prepared
This cycleAgencies issue requirements that define total pricing and prohibit hidden fees.
- 3
Legal defense posture activated
As challenges ariseAmicus, expert support, and rapid analysis are delivered to defend the rules.
- 4
Enforcement outcomes visible
After rules take effectSettlements or enforcement actions deter repeat violators and clarify expectations.