In this testimony, we first discuss why we support eliminating what is functionally discrimination in the law against the FTC in its rule-making authority, compared to other agencies. Section I. We also support the Congressional guidance to the FTC to use the APA rule-making in the area of consumer credit and debt, which we recognize to be central to the health of the economy as a whole. We first put that priority into context, with a general picture of the financial health of the majority of America's households. Section II. Turning to the specific areas identified in the bill, Section III discusses the two areas that the bill would set as priorities for the FTC: III-A explains some of the critical and widespread problems which have infected the auto sales and finance market. Section III-B details some of the problems in the debt settlement industry which led the sponsors of the CCDPA to prioritize that industry. In Section III-C, we suggest, too, that the Commission review its existing credit-related rules, including the Credit Practices Rule, now a quarter of a century old, to evaluate whether they need to be updated to address the evolution of the consumer credit market place. Finally, in Section IV, we support giving concurrent enforcement authority to state attorneys general.
