SIIA appreciates the chance to comment on the petition for rulemaking regarding Commissioner disqualification (Docket No. R307004). We emphasize the need for greater procedural transparency in the Federal Trade Commission (FTC) and clearer standards for Commissioner recusals, supporting the U.S. Chamber of Commerce’s call for enhanced procedures. SIIA underscores the importance of public confidence in the FTC’s decision-making process due to its far-reaching jurisdiction. We recommend specific recusal criteria, written guidance from agency ethics officials, and written disclosure of recusal reasons.
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