National Association of Teachers of Singing, Inc.; Analysis To Aid Public Comment, 52008-52010 [2014-20747]
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52008
Federal Register / Vol. 79, No. 169 / Tuesday, September 2, 2014 / Notices
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The Complaint alleges that NARPM
has violated Section 5 of the Federal
Trade Commission Act by adopting and
maintaining provisions in its Code of
Ethics that restrain its members from (1)
soliciting the customers of competing
property managers, and (2) making
statements that are not false or
deceptive about competing property
managers. The Complaint alleges that
the purpose, effects, tendency, or
capacity of the combination, agreement,
acts and practices of NARPM has been
and is to restrain competition
unreasonably and to injure consumers
by discouraging and restricting
competition among property managers,
and by depriving consumers and others
of the benefits of free and open
competition among property managers.
II. The Proposed Order
The Proposed Order has the following
substantive provisions. Paragraph II
requires NARPM to cease and desist
from restraining its members from
soliciting property management work,
or from making statements about
competitors’ products, services, or
business or commercial practices that
are not false or deceptive. The Proposed
Order does not prohibit NARPM from
adopting and enforcing reasonable
restraints with respect to
representations that NARPM reasonably
believes would be false or deceptive
within the meaning of Section 5 of the
Federal Trade Commission Act.
Paragraph III of the Proposed Order
requires NARPM to remove from its
Web site and organization documents
any statement that does not comply
with the Proposed Order, and to publish
on the Web site any revision to the
organization documents. NARPM must
publish an announcement that it has
changed its Code of Ethics, and a
statement describing the Consent
Agreement (‘‘the Settlement
Statement’’). NARPM must publish the
aforementioned documents in NARPM’s
news magazine. NARPM must distribute
the Settlement Statement to NARPM’s
board of directors, officers, employees,
and members. NARPM must publish in
all ethics courses designed or offered by
NARPM that discuss the provisions at
issue a statement that restrictions on
solicitation or advertising no longer
apply. Paragraph III also requires
NARPM to provide all new members
and all members who receive a
membership renewal notice with a copy
of the Settlement Statement.
Paragraph IV of the Proposed Order
requires NARPM to design, maintain,
and operate an antitrust compliance
program. NARPM will have to appoint
an Antitrust Compliance Officer for the
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duration of the Proposed Order. For a
period of five years, NARPM will have
to provide in-person annual training to
its board of directors, officers, and
employees, and conduct a presentation
at its annual convention, regional
conferences, and each code of ethics
training session, that summarizes
NARPM’s obligations under the
Proposed Order and provides contextappropriate guidance on compliance
with the antitrust laws. NARPM must
also implement policies and procedures
to enable persons to ask questions
about, and report violations of, the
Proposed Order and the antitrust laws
confidentially and without fear of
retaliation, and to discipline its board of
directors, officers, employees, members,
and agents for failure to comply with
the Proposed Order.
Paragraphs V–VII of the Proposed
Order impose certain standard reporting
and compliance requirements on
NARPM.
The Proposed Order will expire in 20
years.
By direction of the Commission.
Janice Podoll Frankle,
Acting Secretary.
[FR Doc. 2014–20776 Filed 8–29–14; 8:45 am]
BILLING CODE 6750–01–P
FEDERAL TRADE COMMISSION
[File No. 131 0127]
National Association of Teachers of
Singing, Inc.; Analysis To Aid Public
Comment
Federal Trade Commission.
Proposed Consent Agreement.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair methods
of competition. The attached Analysis to
Aid Public Comment describes both the
allegations in the draft complaint and
the terms of the consent order—
embodied in the consent agreement—
that would settle these allegations.
DATES: Comments must be received on
or before September 22, 2014.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
natsconsent online or on paper, by
following the instructions in the
Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘National Association of
Teachers of Singing, Inc.—Consent
Agreement; File No. 131 0127’’ on your
comment and file your comment online
at https://ftcpublic.commentworks.com/
ftc/natsconsent by following the
SUMMARY:
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instructions on the web-based form. If
you prefer to file your comment on
paper, mail your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
600 Pennsylvania Avenue NW., Suite
CC–5610 (Annex D), Washington, DC
20580, or deliver your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
Constitution Center, 400 7th Street SW.,
5th Floor, Suite 5610 (Annex D),
Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT:
Karen Mills, Bureau of Competition,
(202–326–2052), 600 Pennsylvania
Avenue NW., Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis to Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for August 22, 2014), on the
World Wide Web, at https://www.ftc.gov/
os/actions.shtm.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before September 22, 2014. Write
‘‘National Association of Teachers of
Singing, Inc.—Consent Agreement; File
No. 131 0127’’ on your comment. Your
comment—including your name and
your state—will be placed on the public
record of this proceeding, including, to
the extent practicable, on the public
Commission Web site, at https://
www.ftc.gov/os/publiccomments.shtm.
As a matter of discretion, the
Commission tries to remove individuals’
home contact information from
comments before placing them on the
Commission Web site.
Because your comment will be made
public, you are solely responsible for
making sure that your comment does
not include any sensitive personal
information, like anyone’s Social
Security number, date of birth, driver’s
license number or other state
identification number or foreign country
equivalent, passport number, financial
account number, or credit or debit card
number. You are also solely responsible
for making sure that your comment does
not include any sensitive health
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Federal Register / Vol. 79, No. 169 / Tuesday, September 2, 2014 / Notices
information, like medical records or
other individually identifiable health
information. In addition, do not include
any ‘‘[t]rade secret or any commercial or
financial information which . . . is
privileged or confidential,’’ as discussed
in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR
4.10(a)(2). In particular, do not include
competitively sensitive information
such as costs, sales statistics,
inventories, formulas, patterns, devices,
manufacturing processes, or customer
names.
If you want the Commission to give
your comment confidential treatment,
you must file it in paper form, with a
request for confidential treatment, and
you have to follow the procedure
explained in FTC Rule 4.9(c), 16 CFR
4.9(c).1 Your comment will be kept
confidential only if the FTC General
Counsel, in his or her sole discretion,
grants your request in accordance with
the law and the public interest.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
natsconsent by following the
instructions on the web-based form. If
this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you file your comment on paper,
write ‘‘National Association of Teachers
of Singing, Inc.—Consent Agreement;
File No. 131 0127’’ on your comment
and on the envelope, and mail your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW., Suite CC–5610 (Annex D),
Washington, DC 20580, or deliver your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610
(Annex D), Washington, DC 20024. If
possible, submit your paper comment to
the Commission by courier or overnight
service.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
1 In particular, the written request for confidential
treatment that accompanies the comment must
include the factual and legal basis for the request,
and must identify the specific portions of the
comment to be withheld from the public record. See
FTC Rule 4.9(c), 16 CFR 4.9(c).
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Jkt 232001
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before September 22, 2014. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/ftc/privacy.htm.
Analysis of Agreement Containing
Consent Order To Aid Public Comment
The Federal Trade Commission
(‘‘Commission’’) has accepted, subject to
final approval, an Agreement
Containing Consent Order (‘‘Consent
Agreement’’) from the National
Association of Teachers of Singing, Inc.
(hereinafter ‘‘NATS’’). The
Commission’s complaint (‘‘Complaint’’)
alleges that NATS, acting as a
combination of its members and in
agreement with at least some of its
members, restrained competition among
its members and others in violation of
Section 5 of the Federal Trade
Commission Act, as amended, 15 U.S.C.
45, by adopting and maintaining a
provision in its Code of Ethics that
restrains solicitation of teaching work.
Under the terms of the proposed
Consent Agreement, NATS is required
to cease and desist from restricting
solicitation among its members, and is
required to disaffiliate any Chapter that
adopts or maintains provisions in its
code of ethics or similar documents that
restrain solicitation, advertising, or
price-related competition.
The Commission anticipates that the
competitive issues described in the
Complaint will be resolved by accepting
the proposed order, subject to final
approval, contained in the Consent
Agreement. The proposed Consent
Agreement has been placed on the
public record for 30 days for receipt of
comments from interested members of
the public. Comments received during
this period will become part of the
public record. After 30 days, the
Commission will review the Consent
Agreement again and the comments
received, and will decide whether it
should withdraw from the Consent
Agreement or make final the
accompanying Decision and Order (‘‘the
Proposed Order’’).
The purpose of this Analysis to Aid
Public Comment is to invite and
facilitate public comment. It is not
intended to constitute an official
interpretation of the proposed Consent
Agreement and the accompanying
Proposed Order or in any way to modify
their terms.
The Consent Agreement is for
settlement purposes only and does not
constitute an admission by NATS that
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52009
the law has been violated as alleged in
the Complaint or that the facts alleged
in the Complaint, other than
jurisdictional facts, are true.
I. The Complaint
The Complaint makes the following
allegations.
A. The Respondent
NATS is a non-profit professional
association of more than 7,300 singing
teachers. Many of NATS’s members
provide music-teaching services for a
fee. Some also are employed at schools,
universities and music studios as music
teachers. NATS membership provides
pecuniary benefits to its members.
NATS has affiliated state and local
chapters, which are grouped into 14
regions. Members of Chapters also are
members of NATS.
NATS maintains a Code of Ethics
applicable to the commercial activities
of its members, and requires its
members to read and pledge adherence
to all the provisions of the Code of
Ethics. The NATS Bylaws require that
Chapters shall abide by Association
Bylaws, policies and guidelines, and
will establish their own Bylaws and
operating procedures consistent with
the NATS Bylaws and with review and
consent of the NATS Board of Directors.
The NATS Code of Ethics has three
sections. One of those sections is titled
‘‘Ethical Standards Relating to
Colleagues.’’ That Section of the Code of
Ethics includes a provision that states,
‘‘Members will not, either by
inducements, innuendos, or other accts,
proselytize students of other teachers.’’
Some NATS Chapters have the same
Code of Ethics that NATS has. Some
Chapters have codes of ethics that
contain other restrictions on
solicitation, restrictions on price
competition, restrictions on advertising
free tuition, or restrictions on accepting
pupils who have not fulfilled a financial
obligation to another member until
those obligations are satisfied.
B. The Anticompetitive Conduct
The Complaint alleges that NATS
violated Section 5 of the Federal Trade
Commission Act by restraining
competition among singing teachers
through adoption and enforcement of
the non-solicitation provision of its
Code of Ethics. This is in effect an
agreement among competitors not to
compete. NATS requires members to
agree to abide by the non-solicitation
provision. NATS adopted a complaint
and enforcement procedure for the Code
of Ethics that can result in termination
of membership. When NATS members
have complained that other members
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Federal Register / Vol. 79, No. 169 / Tuesday, September 2, 2014 / Notices
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violated the non-solicitation provision
of the Code of Ethics, NATS has
investigated complaints, and even
where no formal action is taken, the
NATS Ethics Committee, Executive
Director, President, and Regions
sometimes contact a teacher to secure
compliance with the non-solicitation
provision of the Code of Ethics, or
mediate between parties in order to
resolve complaints.
The Complaint alleges that the
purpose, effect, tendency, or capacity of
the combination, agreement, acts and
practices of NATS has been and is to
restrain competition unreasonably and
to injure consumers by discouraging and
restricting competition among music
teachers.
II. The Proposed Order
The Proposed Order has the following
substantive provisions.
Paragraph I contains definitions for
terms used in the Order.
Paragraph II requires NATS to cease
and desist from restraining or declaring
unethical the solicitation of teaching
work. It also requires NATS to cease and
desist from maintaining a relationship
with any NATS Chapter that NATS
learns or learns that, or obtains
information that would lead a
reasonable person to conclude that,
engages in conduct that restrains
solicitation, advertising, or price-related
competition by its members.
The Proposed Order does not prohibit
NATS from adopting and enforcing
reasonable principles (i) to prevent false
or deceptive representations, or (ii) to
govern the conduct of judges during
singing competitions sponsored or held
by NATS or its Chapters, or maintaining
a relationship with a Chapter that
adopts and enforces such principles.
The Proposed Order does not prohibit
restrictions on judges’ solicitation
during competitions because NATS
could have a plausible efficiency
rationale: Ensuring fair competitions.
The Proposed Order’s exemption is
limited to restrictions on judges’
behavior during competitions;
prohibitions on judges’ pre- or postcompetition solicitation would violate
the Proposed Order.
Paragraph III requires NATS to
remove from its organization documents
and Web site any statement inconsistent
with the Proposed Order, including the
Code of Ethics restriction on
solicitation. NATS also must publicize
to its members, new members, Chapters,
new Chapters, leaders, employees, and
the public the changes NATS must
make to the Code of Ethics, and a
statement describing the Consent
Agreement.
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Paragraph III also requires NATS to
notify each of its Chapters that, as a
condition of remaining a NATS Chapter,
each Chapter must execute and return a
Certification to NATS that the Chapter
does not have restrictions on
solicitation, advertising, or price-related
competition. NATS must terminate any
Chapter that does not provide an
executed Certification within one
hundred and twenty days of when
NATS gave notice to the Chapter.
Thereafter, if NATS learns that a
Chapter has engaged in restraining or
declaring unethical the solicitation,
advertising, or price-related
competition, the Proposed Order
requires NATS to terminate the Chapter
for one year unless the Chapter informs
NATS that the Chapter has eliminated
and will not reengage in such practices.
Paragraph IV requires NATS to
design, maintain, and operate an
antitrust compliance program. NATS
must appoint an Antitrust Compliance
Officer for the duration of the Proposed
Order. For a period of five years, NATS
must provide guidance to its staff,
employees, members, leaders, and
Chapters concerning the antitrust laws
and NATS’ obligations under the
Proposed Order. NATS also must
implement policies and procedures to
enable persons to ask questions about,
and report violations of, the Proposed
Order and the antitrust laws
confidentially and without fear of
retaliation, and to discipline its leaders,
employees and agents for failure to
comply with the Proposed Order.
Paragraphs V–VII of the Proposed
Order requires certain standard
compliance reporting, cooperation, and
access.
The Proposed Order will expire in 20
years.
By direction of the Commission.
Janice Podoll Frankle,
Acting Secretary.
[FR Doc. 2014–20747 Filed 8–29–14; 8:45 am]
BILLING CODE 6750–01–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Office of the Secretary
[Document Identifier OS–0990–0330–60D]
Agency Information Collection
Activities; Proposed Collection; Public
Comment Request
Office of the Secretary, HHS.
Notice.
AGENCY:
ACTION:
In compliance with section
3506(c)(2)(A) of the Paperwork
SUMMARY:
PO 00000
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Reduction Act of 1995, the Office of the
Secretary (OS), Department of Health
and Human Services, announces plans
to submit an Information Collection
Request (ICR), described below, to the
Office of Management and Budget
(OMB). The ICR is for extending the use
of the approved information collection
assigned OMB control number 0990–
0330, which expires on 12/31/14. Prior
to submitting that ICR to OMB, OS seeks
comments from the public regarding the
burden estimate, below, or any other
aspect of the ICR.
DATES: Comments on the ICR must be
received on or before November 3, 2014.
ADDRESSES: Submit your comments to
Information.CollectionClearance@
hhs.gov or by calling (202) 690–6162.
FOR FURTHER INFORMATION CONTACT:
Information Collection Clearance staff,
Information.CollectionClearance@
hhs.gov or (202) 690–6162.
SUPPLEMENTARY INFORMATION:
Information Collection Request Title:
Annual Appellant Climate Survey—
Office of Medicare Hearings and
Appeals (OMHA).
OMB No.: 0990—0330.
Abstract: The annual OMHA
Appellant Climate Survey is a survey of
Medicare beneficiaries, providers,
suppliers, or their representatives who
participated in a hearing before an
Administrative Law Judge (ALJ) from
the Office of Medicare Hearings and
Appeals (OMHA). Appellants
dissatisfied with the outcome of their
Level 2 Medicare appeal may request a
hearing before an OMHA ALJ. The
Appellant Climate Survey will be used
to measure appellant satisfaction with
their OMHA appeals experience, as
opposed to their satisfaction with a
specific ruling.
OMHA was established by the
Medicare Prescription Drug,
Improvement, and Modernization Act
(MMA) of 2003 (Pub. L. 108–173) and
became operational on July 1, 2005. The
MMA legislation and implementing
regulations issued on March 8, 2007
instituted a number of changes in the
appeals process. The MMA legislation
also directed the U.S. Department of
Health and Human Services to consider
the feasibility of conducting hearings
using telephone or video-teleconference
(VTC) technologies. In carrying out this
mandate, OMHA makes use of VTC to
provide appellants with a vast
nationwide network of access points for
hearings close to their homes. The first
three-year administration cycle of the
OMHA survey began in FY08 and a
second three-year cycle began in FY12.
The survey will continue to be
E:\FR\FM\02SEN1.SGM
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Agencies
[Federal Register Volume 79, Number 169 (Tuesday, September 2, 2014)]
[Notices]
[Pages 52008-52010]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-20747]
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 131 0127]
National Association of Teachers of Singing, Inc.; Analysis To
Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed Consent Agreement.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair methods of competition.
The attached Analysis to Aid Public Comment describes both the
allegations in the draft complaint and the terms of the consent order--
embodied in the consent agreement--that would settle these allegations.
DATES: Comments must be received on or before September 22, 2014.
ADDRESSES: Interested parties may file a comment at https://ftcpublic.commentworks.com/ftc/natsconsent online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Write ``National Association
of Teachers of Singing, Inc.--Consent Agreement; File No. 131 0127'' on
your comment and file your comment online at https://ftcpublic.commentworks.com/ftc/natsconsent by following the
instructions on the web-based form. If you prefer to file your comment
on paper, mail your comment to the following address: Federal Trade
Commission, Office of the Secretary, 600 Pennsylvania Avenue NW., Suite
CC-5610 (Annex D), Washington, DC 20580, or deliver your comment to the
following address: Federal Trade Commission, Office of the Secretary,
Constitution Center, 400 7th Street SW., 5th Floor, Suite 5610 (Annex
D), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT: Karen Mills, Bureau of Competition,
(202-326-2052), 600 Pennsylvania Avenue NW., Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of thirty (30) days. The
following Analysis to Aid Public Comment describes the terms of the
consent agreement, and the allegations in the complaint. An electronic
copy of the full text of the consent agreement package can be obtained
from the FTC Home Page (for August 22, 2014), on the World Wide Web, at
https://www.ftc.gov/os/actions.shtm.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before September 22,
2014. Write ``National Association of Teachers of Singing, Inc.--
Consent Agreement; File No. 131 0127'' on your comment. Your comment--
including your name and your state--will be placed on the public record
of this proceeding, including, to the extent practicable, on the public
Commission Web site, at https://www.ftc.gov/os/publiccomments.shtm. As a
matter of discretion, the Commission tries to remove individuals' home
contact information from comments before placing them on the Commission
Web site.
Because your comment will be made public, you are solely
responsible for making sure that your comment does not include any
sensitive personal information, like anyone's Social Security number,
date of birth, driver's license number or other state identification
number or foreign country equivalent, passport number, financial
account number, or credit or debit card number. You are also solely
responsible for making sure that your comment does not include any
sensitive health
[[Page 52009]]
information, like medical records or other individually identifiable
health information. In addition, do not include any ``[t]rade secret or
any commercial or financial information which . . . is privileged or
confidential,'' as discussed in Section 6(f) of the FTC Act, 15 U.S.C.
46(f), and FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2). In particular, do
not include competitively sensitive information such as costs, sales
statistics, inventories, formulas, patterns, devices, manufacturing
processes, or customer names.
If you want the Commission to give your comment confidential
treatment, you must file it in paper form, with a request for
confidential treatment, and you have to follow the procedure explained
in FTC Rule 4.9(c), 16 CFR 4.9(c).\1\ Your comment will be kept
confidential only if the FTC General Counsel, in his or her sole
discretion, grants your request in accordance with the law and the
public interest.
---------------------------------------------------------------------------
\1\ In particular, the written request for confidential
treatment that accompanies the comment must include the factual and
legal basis for the request, and must identify the specific portions
of the comment to be withheld from the public record. See FTC Rule
4.9(c), 16 CFR 4.9(c).
---------------------------------------------------------------------------
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/natsconsent by following the instructions on the web-based form. If
this Notice appears at https://www.regulations.gov/#!home, you also may
file a comment through that Web site.
If you file your comment on paper, write ``National Association of
Teachers of Singing, Inc.--Consent Agreement; File No. 131 0127'' on
your comment and on the envelope, and mail your comment to the
following address: Federal Trade Commission, Office of the Secretary,
600 Pennsylvania Avenue NW., Suite CC-5610 (Annex D), Washington, DC
20580, or deliver your comment to the following address: Federal Trade
Commission, Office of the Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610 (Annex D), Washington, DC 20024. If
possible, submit your paper comment to the Commission by courier or
overnight service.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before September 22, 2014. You can find more
information, including routine uses permitted by the Privacy Act, in
the Commission's privacy policy, at https://www.ftc.gov/ftc/privacy.htm.
Analysis of Agreement Containing Consent Order To Aid Public Comment
The Federal Trade Commission (``Commission'') has accepted, subject
to final approval, an Agreement Containing Consent Order (``Consent
Agreement'') from the National Association of Teachers of Singing, Inc.
(hereinafter ``NATS''). The Commission's complaint (``Complaint'')
alleges that NATS, acting as a combination of its members and in
agreement with at least some of its members, restrained competition
among its members and others in violation of Section 5 of the Federal
Trade Commission Act, as amended, 15 U.S.C. 45, by adopting and
maintaining a provision in its Code of Ethics that restrains
solicitation of teaching work.
Under the terms of the proposed Consent Agreement, NATS is required
to cease and desist from restricting solicitation among its members,
and is required to disaffiliate any Chapter that adopts or maintains
provisions in its code of ethics or similar documents that restrain
solicitation, advertising, or price-related competition.
The Commission anticipates that the competitive issues described in
the Complaint will be resolved by accepting the proposed order, subject
to final approval, contained in the Consent Agreement. The proposed
Consent Agreement has been placed on the public record for 30 days for
receipt of comments from interested members of the public. Comments
received during this period will become part of the public record.
After 30 days, the Commission will review the Consent Agreement again
and the comments received, and will decide whether it should withdraw
from the Consent Agreement or make final the accompanying Decision and
Order (``the Proposed Order'').
The purpose of this Analysis to Aid Public Comment is to invite and
facilitate public comment. It is not intended to constitute an official
interpretation of the proposed Consent Agreement and the accompanying
Proposed Order or in any way to modify their terms.
The Consent Agreement is for settlement purposes only and does not
constitute an admission by NATS that the law has been violated as
alleged in the Complaint or that the facts alleged in the Complaint,
other than jurisdictional facts, are true.
I. The Complaint
The Complaint makes the following allegations.
A. The Respondent
NATS is a non-profit professional association of more than 7,300
singing teachers. Many of NATS's members provide music-teaching
services for a fee. Some also are employed at schools, universities and
music studios as music teachers. NATS membership provides pecuniary
benefits to its members.
NATS has affiliated state and local chapters, which are grouped
into 14 regions. Members of Chapters also are members of NATS.
NATS maintains a Code of Ethics applicable to the commercial
activities of its members, and requires its members to read and pledge
adherence to all the provisions of the Code of Ethics. The NATS Bylaws
require that Chapters shall abide by Association Bylaws, policies and
guidelines, and will establish their own Bylaws and operating
procedures consistent with the NATS Bylaws and with review and consent
of the NATS Board of Directors.
The NATS Code of Ethics has three sections. One of those sections
is titled ``Ethical Standards Relating to Colleagues.'' That Section of
the Code of Ethics includes a provision that states, ``Members will
not, either by inducements, innuendos, or other accts, proselytize
students of other teachers.''
Some NATS Chapters have the same Code of Ethics that NATS has. Some
Chapters have codes of ethics that contain other restrictions on
solicitation, restrictions on price competition, restrictions on
advertising free tuition, or restrictions on accepting pupils who have
not fulfilled a financial obligation to another member until those
obligations are satisfied.
B. The Anticompetitive Conduct
The Complaint alleges that NATS violated Section 5 of the Federal
Trade Commission Act by restraining competition among singing teachers
through adoption and enforcement of the non-solicitation provision of
its Code of Ethics. This is in effect an agreement among competitors
not to compete. NATS requires members to agree to abide by the non-
solicitation provision. NATS adopted a complaint and enforcement
procedure for the Code of Ethics that can result in termination of
membership. When NATS members have complained that other members
[[Page 52010]]
violated the non-solicitation provision of the Code of Ethics, NATS has
investigated complaints, and even where no formal action is taken, the
NATS Ethics Committee, Executive Director, President, and Regions
sometimes contact a teacher to secure compliance with the non-
solicitation provision of the Code of Ethics, or mediate between
parties in order to resolve complaints.
The Complaint alleges that the purpose, effect, tendency, or
capacity of the combination, agreement, acts and practices of NATS has
been and is to restrain competition unreasonably and to injure
consumers by discouraging and restricting competition among music
teachers.
II. The Proposed Order
The Proposed Order has the following substantive provisions.
Paragraph I contains definitions for terms used in the Order.
Paragraph II requires NATS to cease and desist from restraining or
declaring unethical the solicitation of teaching work. It also requires
NATS to cease and desist from maintaining a relationship with any NATS
Chapter that NATS learns or learns that, or obtains information that
would lead a reasonable person to conclude that, engages in conduct
that restrains solicitation, advertising, or price-related competition
by its members.
The Proposed Order does not prohibit NATS from adopting and
enforcing reasonable principles (i) to prevent false or deceptive
representations, or (ii) to govern the conduct of judges during singing
competitions sponsored or held by NATS or its Chapters, or maintaining
a relationship with a Chapter that adopts and enforces such principles.
The Proposed Order does not prohibit restrictions on judges'
solicitation during competitions because NATS could have a plausible
efficiency rationale: Ensuring fair competitions. The Proposed Order's
exemption is limited to restrictions on judges' behavior during
competitions; prohibitions on judges' pre- or post-competition
solicitation would violate the Proposed Order.
Paragraph III requires NATS to remove from its organization
documents and Web site any statement inconsistent with the Proposed
Order, including the Code of Ethics restriction on solicitation. NATS
also must publicize to its members, new members, Chapters, new
Chapters, leaders, employees, and the public the changes NATS must make
to the Code of Ethics, and a statement describing the Consent
Agreement.
Paragraph III also requires NATS to notify each of its Chapters
that, as a condition of remaining a NATS Chapter, each Chapter must
execute and return a Certification to NATS that the Chapter does not
have restrictions on solicitation, advertising, or price-related
competition. NATS must terminate any Chapter that does not provide an
executed Certification within one hundred and twenty days of when NATS
gave notice to the Chapter. Thereafter, if NATS learns that a Chapter
has engaged in restraining or declaring unethical the solicitation,
advertising, or price-related competition, the Proposed Order requires
NATS to terminate the Chapter for one year unless the Chapter informs
NATS that the Chapter has eliminated and will not reengage in such
practices.
Paragraph IV requires NATS to design, maintain, and operate an
antitrust compliance program. NATS must appoint an Antitrust Compliance
Officer for the duration of the Proposed Order. For a period of five
years, NATS must provide guidance to its staff, employees, members,
leaders, and Chapters concerning the antitrust laws and NATS'
obligations under the Proposed Order. NATS also must implement policies
and procedures to enable persons to ask questions about, and report
violations of, the Proposed Order and the antitrust laws confidentially
and without fear of retaliation, and to discipline its leaders,
employees and agents for failure to comply with the Proposed Order.
Paragraphs V-VII of the Proposed Order requires certain standard
compliance reporting, cooperation, and access.
The Proposed Order will expire in 20 years.
By direction of the Commission.
Janice Podoll Frankle,
Acting Secretary.
[FR Doc. 2014-20747 Filed 8-29-14; 8:45 am]
BILLING CODE 6750-01-P