Louisiana Real Estate Appraisers Board; Analysis of Agreement Containing Consent Order To Aid Public Comment, 32678-32680 [2021-13139]
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Federal Register / Vol. 86, No. 117 / Tuesday, June 22, 2021 / Notices
The Commission will request this
information from CMS providers on a
voluntary basis, including geographic
area served and devices that are
programmed, at point of sale, to
transmit WEAs. We note that many
participating CMS providers already
provide information of this nature in
their docketed filings. As discussed
below, this database will remove a
major roadblock to emergency
managers’ ability to conduct tests of the
alerting system and enable individuals
and emergency managers to identify the
alert coverage area.
Since ensuring consumer notice and
collecting information on the extent of
CMS providers’ participation is
statutorily mandated, the Commission
requests to extend approval of this
collection by OMB so that the
Commission may continue to meet its
statutory obligation under the WARN
Act.
Federal Communications Commission.
Marlene Dortch,
Secretary, Office of the Secretary.
[FR Doc. 2021–13088 Filed 6–21–21; 8:45 am]
BILLING CODE 6712–01–P
FEDERAL TRADE COMMISSION
[File No. 161 0068, Docket No. 9374]
Louisiana Real Estate Appraisers
Board; Analysis of Agreement
Containing Consent Order To Aid
Public Comment
Federal Trade Commission.
Proposed consent agreement;
request for comment.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
federal law prohibiting unfair methods
of competition. The attached Analysis of
Proposed Consent Orders to Aid Public
Comment describes both the allegations
in the complaint and the terms of the
consent orders—embodied in the
consent agreement—that would settle
these allegations.
DATES: Comments must be received on
or before July 22, 2021.
ADDRESSES: Interested parties may file
comments online or on paper, by
following the instructions in the
Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Please write: ‘‘Louisiana Real
Estate Appraisers Board; File No. 161
0068, Docket No. 9374’’ on your
comment, and file your comment online
at www.regulations.gov by following the
instructions on the web-based form. If
you prefer to file your comment on
lotter on DSK11XQN23PROD with NOTICES1
SUMMARY:
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paper, please 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:
Patricia M. McDermott (202–326–2569),
Bureau of Competition, Federal Trade
Commission, 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 a 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 of Agreement Containing
Consent Orders 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
website at this web address: https://
www.ftc.gov/news-events/commissionactions.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before July 22, 2021. Write ‘‘Louisiana
Real Estate Appraisers Board; File No.
161 0068, Docket No. 9374’’ 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 www.regulations.gov
website.
Due to protective actions in response
to the COVID–19 pandemic and the
agency’s heightened security screening,
postal mail addressed to the
Commission will be subject to delay. We
strongly encourage you to submit your
comments online through the
www.regulations.gov website.
If you prefer to file your comment on
paper, write ‘‘Louisiana Real Estate
Appraisers Board; File No. 161 0068,
Docket No. 9374’’ 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:
PO 00000
Frm 00007
Fmt 4703
Sfmt 4703
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.
Because your comment will be placed
on the publicly accessible website at
www.regulations.gov, you are solely
responsible for making sure that your
comment does not include any sensitive
or confidential information. In
particular, your comment should not
include any sensitive personal
information, such as your or anyone
else’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 your
comment does not include any sensitive
health information, such as medical
records or other individually
identifiable health information. In
addition, your comment should not
include any ‘‘trade secret or any
commercial or financial information
which . . . is privileged or
confidential’’—as provided by 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)—
including in particular competitively
sensitive information such as costs,
sales statistics, inventories, formulas,
patterns, devices, manufacturing
processes, or customer names.
Comments containing material for
which confidential treatment is
requested must be filed in paper form,
must be clearly labeled ‘‘Confidential,’’
and must comply with FTC Rule 4.9(c).
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). Your
comment will be kept confidential only
if the General Counsel grants your
request in accordance with the law and
the public interest. Once your comment
has been posted on
www.regulations.gov—as legally
required by FTC Rule 4.9(b)—we cannot
redact or remove your comment from
that website, unless you submit a
confidentiality request that meets the
requirements for such treatment under
FTC Rule 4.9(c), and the General
Counsel grants that request.
Visit the FTC website at https://
www.ftc.gov to read this Notice and the
news release describing this matter. The
FTC Act and other laws that the
Commission administers permit the
E:\FR\FM\22JNN1.SGM
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Federal Register / Vol. 86, No. 117 / Tuesday, June 22, 2021 / Notices
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 July 22, 2021. For information on
the Commission’s privacy policy,
including routine uses permitted by the
Privacy Act, see https://www.ftc.gov/
site-information/privacy-policy.
Analysis of Agreement Containing
Consent Orders To Aid Public Comment
I. Introduction
The Federal Trade Commission
(‘‘Commission’’) has accepted, subject to
final approval by the Commission, an
Agreement Containing Consent Order
(‘‘Consent Agreement’’) with the
Louisiana Real Estate Appraisers Board
(‘‘the Board’’). The Consent Agreement
resolves allegations against the Board in
the administrative complaint issued by
the Commission on May 31, 2017.
The Commission has placed the
Consent Agreement on the public record
for 30 days to solicit comments from
interested persons. Comments received
during this period will become part of
the public record. After 30 days, the
Commission will again review the
Consent Agreement and the comments
received, and will decide whether it
should withdraw from the Consent
Agreement, modify it, or issue the
proposed Order. The proposed Order is
for settlement purposes only and does
not constitute an admission by the
Board that it violated the law, or that the
facts alleged in the complaint, other
than jurisdictional facts, are true.
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II. Challenged Conduct
This matter involves allegations that
the Board unreasonably restrained price
competition for appraisal services in
Louisiana. The Board is a state
regulatory agency controlled by
Louisiana-licensed appraisers. The
Commission’s complaint challenges the
Board’s promulgation and enforcement
of subparts A, B, and C of Rule 31101
of Title 46 Part LXVII of the Professional
and Occupational Standards of the
Louisiana Administrative Code (‘‘Rule
31101’’).
The complaint alleges that the Board’s
promulgation and enforcement of Rule
31101 displaced competition and
introduced a regime of rate regulation.
The Board’s actions had the effect of
requiring appraisal management
companies (‘‘AMCs’’) to pay rates for
appraisal services consistent with
median fees identified in fee surveys
commissioned and published by the
Board. Specifically, the Board
investigated and issued complaints
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against AMCs that paid fees below the
rates specified in the surveys, and
entered into settlement agreements with
AMCs that required those companies to
pay fees at or above the median fee
survey levels.
The complaint alleges that the Board’s
actions exceeded the scope of its
obligations under the appraisal
independence provisions in the 2010
Dodd-Frank Wall Street Reform and
Consumer Protection Act (‘‘Dodd-Frank
Act’’). The complaint further alleges that
the Board’s conduct resulted in
anticompetitive harm in the form of
higher appraisal fees paid by AMCs in
Louisiana, and that this harm is not
outweighed by any procompetitive
benefits.
III. Legal Analysis
The factual allegations in the
complaint support a finding that the
Board violated Section 5 of the FTC Act,
15 U.S.C. 45, by promulgating and
enforcing Rule 31101. Section 5 of the
FTC Act prohibits unfair methods of
competition, including unlawful
agreements in restraint of trade
prohibited by Section 1 of the Sherman
Act, 15 U.S.C. 1.1 Under Section 1, a
plaintiff must show (1) concerted action
that (2) unreasonably restrains
competition.2
A state regulatory board that consists
of market participants with distinct and
potentially competing economic
interests engages in concerted action
when it adopts or enforces rules that
govern the conduct of its members’
separate businesses.3 Rule 31101,
adopted and enforced by the Board,
regulates the fees paid by AMCs to
appraisers in Louisiana, including those
appraisers that serve as members of the
Board.
Price regulation practiced by market
participants is a form of price fixing and
is per se unlawful.4 In the alternative, a
restraint on price competition may be
judged inherently suspect: that is, the
1 15 U.S.C. 45; see, e.g., FTC v. Cement Inst., 333
U.S. 683, 693–94 (1948).
2 15 U.S.C. 1; see, e.g., Arizona v. Maricopa Cnty.
Med. Soc., 457 U.S. 332, 342–343 (1982).
3 See N.C. Bd. of Dental Exam’rs v. FTC., 574 U.S.
494, 510–12 (2015); In re N.C. Bd. of Dental
Exam’rs, 2011 FTC LEXIS 290 at *38–39, 2011–2
Trade Cas. (CCH) ¶ 77,705 (Comm’n Op. and Order,
Dec. 7, 2011); see also Mass. Bd. of Registration in
Optometry, 110 FTC 549, 1988 WL 1025476 at *47–
48 (Comm’n Op. and Order, June 13, 1988).
4 FTC v. Ticor Title Ins. Co., 504 U.S. 621, 639
(1992) (equating price regulation by market
participants with per se unlawful price fixing); Cal.
Retail Liquor Dealers Ass’n v. Midcal Aluminum,
Inc., 445 U.S. 97, 103–106 (1980) (same); Goldfarb
v. Va. State Bar, 421 U.S. 773, 781–82 (1975)
(same); Schwegmann Bros. v. Calvert Distillers
Corp., 341 U.S. 384, 386–390 (1951) (same); Ky.
Household Goods Carriers Ass’n., Inc. v. FTC, 199
F. App’x 410, 411 (6th Cir. 2006) (same).
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agreement is presumed to be
anticompetitive because the
anticompetitive nature of the challenged
conduct is obvious.5
The state action defense is not
applicable here. On a motion for partial
summary decision, the Commission
concluded: (1) The Board is controlled
by active market participants; (2)
therefore, in order to constitute state
action, the Board’s conduct must be
actively supervised by the State; and (3)
the Board’s promulgation and
enforcement of Rule 31101 were not
actively supervised by the State of
Louisiana.6
The Dodd-Frank Act also does not
give rise to a defense to antitrust
liability. Exemptions from the antitrust
laws are to be narrowly construed,7 and
the general rule is, except where federal
statutes impose conflicting obligations,
courts will give effect to both statutes.8
The ‘‘good faith regulatory compliance
defense’’ to antitrust liability is a
narrow, rarely invoked defense. The
defense applies only when there is an
inconsistency between the antitrust
laws and the imperatives imposed on
the respondent by federal regulation,
such that the respondent is not able to
comply with both laws.9 ‘‘The defense
does not insulate anticompetitive
conduct that a respondent freely
chooses to undertake; the conduct must
be necessitated by regulatory and factual
imperatives.’’ 10
5 N. Tex. Specialty Physicians v. FTC, 528 F.3d
346, 359–63 (5th Cir. 2008); Polygram Holding, Inc.
v. FTC, 416 F.3d 29, 35–36 (D.C. Cir. 2005).
6 In the Matter of La. Real Est. Appraisers Bd., No.
9374, Op. and Order of the Comm’n, at 19–20 (Apr.
10, 2018).
7 Union Labor Life Ins. Co., v. Pireno, 458 U.S.
119, 126 (1982).
8 See Pom Wonderful LLC v. Coca-Cola Co., 573
U.S. 102, 107 (2014) (‘‘When two statutes
complement each other, it would show disregard
for the congressional design to hold that Congress
nonetheless intended one federal statute to
preclude the operation of the other.’’); Morton v.
Mancari, 417 U.S. 535, 551 (1974) (‘‘The courts are
not at liberty to pick and choose among
congressional enactments, and when two statutes
are capable of co-existence, it is the duty of the
courts, absent a clearly expressed congressional
intention to the contrary, to regard each as
effective.’’); United States v. Borden Co., 308 U.S.
188, 198 (1939) (‘‘When there are two acts upon the
same subject, the rule is to give effect to both if
possible.’’)
9 In the Matter of La. Real Est. Appraisers Bd., No.
9374, Op. and Order of the Comm’n, at 5–7 (May
6, 2019) (‘‘May 6 Comm’n Order’’); see also
PhoneTele, Inc. v. Am. Tel. & Tel. Co., 664 F.2d
716, 737–38 (9th Cir. 1981) (defendant must
establish that ‘‘at the time the various
anticompetitive acts alleged here were taken, it had
a reasonable basis to conclude that its actions were
necessitated by concrete factual imperatives
recognized as legitimate by the regulatory
authority’’).
10 May 6 Comm’n Order at 7 (citing PhoneTele,
664 F.2d at 737–38).
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Federal Register / Vol. 86, No. 117 / Tuesday, June 22, 2021 / Notices
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With regard to the Board’s conduct at
issue here, there is no conflict or
inconsistency between the Board’s
obligations under the Dodd-Frank Act
and its obligations under the antitrust
laws; the Board may readily comply
with both laws. The Dodd-Frank Act
invites States (and not private actors
such as the Board) to cooperate with
federal authorities in regulating the real
estate appraisal industry. The antitrust
laws constrain the actions of private
actors (such as the Board), but do not
apply to states acting in their sovereign
capacity.11 It follows that, if the State of
Louisiana wishes to use a regulatory
board as its instrument for
implementing Dodd-Frank
responsibilities, it can avoid antitrust
complications by complying with the
requirements of the state action
doctrine. This assures the resulting
regulatory regime furthers the
governmental interests of the State, and
not the private interests of market
participants.12
IV. The Proposed Order
The proposed Order remedies the
Board’s anticompetitive conduct by
requiring rescission of Rule 31101 and
prohibiting the Board from regulating or
fixing appraisal fees in Louisiana.
Sections II and III of the proposed
Order address the core of the Board’s
anticompetitive conduct. Paragraph II.A
prohibits the Board from enforcing Rule
31101, or adopting or enforcing any
other rule that sets, determines, or fixes
compensation levels for appraisal
services. Paragraph II.B prohibits the
Board from raising, fixing, maintaining,
or stabilizing compensation levels for
appraisal services; requiring or
encouraging an AMC to pay any specific
fee or range of fees for appraisal
services; or requiring or encouraging
appraisers to request any specific fee or
range of fees for appraisal services.
Prohibited conduct includes adopting a
fee schedule for appraisal services or
requiring AMCs to pay fees consistent
with a fee survey or schedule of
appraisal fees. Paragraph II.C prohibits
the Board from discriminating against
any AMC based on the fees that the
company pays for appraisal services
except in the limited circumstance
described below. Prohibited
discrimination includes requesting
information, conducting audits or
investigations, or holding enforcement
hearings based on the AMC’s fees. The
non-discrimination provision includes a
proviso that permits the Board to take
actions necessary to comply with
11 Parker
12 See
v. Brown, 317 U.S. 341, 350–51 (1943).
N.C. Dental, 574 U.S. at 505–12.
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specific written instructions it receives
in conjunction with a compliance
review by the Appraisal Subcommittee
of the Federal Financial Institutions
Examination Council, which monitors
States’ implementation of minimum
requirements for registration and
supervision of AMCs under the DoddFrank Act. A copy of these instructions
must be provided to Commission staff
no later than 15 days after receipt,
together with a description of how the
Board will comply with them. The
proviso does not apply to or limit the
broad prohibitions on interfering with
price competition set forth in
Paragraphs II.A and II.B of the proposed
Order. Paragraph III.A requires the
Board to rescind Rule 31101, and any
enforcement order based on an alleged
violation of Rule 31101, within 30 days
of the issuance of the Order. Paragraph
III.B requires the Board to notify the
Commission within 60 days any time
the Board adopts a new rule or amends
an existing rule relating to
compensation levels for appraisal
services.
Section IV requires the Board to
provide notice of the Order to the
Board’s members and employees, as
well as each AMC licensed by the
Board. Section V requires the Board to
file with the Commission verified
written compliance reports. Section VI
requires the Board to notify the
Commission in advance of changes in
the Board’s structure that would affect
its compliance obligations. Section VII
requires that the Board provide the
Commission with access to certain
information for the purpose of
determining or securing compliance
with the Order. Section VIII provides
that the Order will terminate 20 years
from the date it is issued.
The purpose of this Analysis to Aid
Public Comment is to invite and
facilitate public comment concerning
the proposed Order. It does not
constitute an official interpretation of
the proposed Order or in any way
modify its terms.
By direction of the Commission.
April J. Tabor,
Secretary.
[FR Doc. 2021–13139 Filed 6–21–21; 8:45 am]
BILLING CODE 6750–01–P
UNITED STATES AGENCY FOR
GLOBAL MEDIA
Public Input for USAGM 2022–2026
Strategic Plan
United States Agency for
Global Media.
AGENCY:
PO 00000
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ACTION:
Request for comment.
The United States Agency for
Global Media (USAGM) requests public
input to inform development of
USAGM’s Strategic Plan for fiscal years
2022–2026.
SUMMARY:
DATES:
Submit comments by July 9,
2021.
You may send comments by
any of the following methods:
• Agency website: www.usagm.gov.
Follow the instructions for submitting
comments at www.usagm.gov/requestfor-public-input-on-usagm-strategicplan-2022–2026.
• Email: publicaffairs@usagm.gov.
Please include the phrase ‘strategic
plan’ in the subject line of the message.
ADDRESSES:
FOR FURTHER INFORMATION CONTACT:
Laurie Moy, Acting Director of Public
Affairs, at publicaffairs@usagm.gov or
(202) 920–2380.
The U.S.
Agency for Global Media (USAGM) is an
independent establishment that
supervises U.S. international
broadcasting under the U.S. Information
and Educational Exchange Act of 1948,
the U.S. International Broadcasting Act
of 1994 (as amended), and other
authorities. In accordance with the
Government Performance and Results
Modernization Act of 2010, USAGM is
required to submit its Strategic Plan to
Congress the year following the start of
a presidential term.
USAGM is in the process of
developing its Strategic Plan for fiscal
years 2022–2026 and is consulting a
wide range of stakeholders. USAGM
welcomes public input into this process
on the following questions:
• What are the biggest challenges
facing USAGM and other publiclyfunded international media over the
next five years?
• What are the biggest opportunities
for USAGM and other publicly-funded
international media over the next five
years?
• Do you have any advice for agency
leaders on how to position USAGM to
best fulfill its mission ‘‘to inform,
engage, and connect audiences around
the world in support of freedom and
democracy’’?
SUPPLEMENTARY INFORMATION:
Dated: June 16, 2021.
Daniel Rosenhotlz,
Attorney-Advisor, Policy Officer U.S. Agency
for Global Media.
[FR Doc. 2021–13082 Filed 6–21–21; 8:45 am]
BILLING CODE 8610–01–P
E:\FR\FM\22JNN1.SGM
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Agencies
[Federal Register Volume 86, Number 117 (Tuesday, June 22, 2021)]
[Notices]
[Pages 32678-32680]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-13139]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 161 0068, Docket No. 9374]
Louisiana Real Estate Appraisers Board; Analysis of Agreement
Containing Consent Order To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement; request for comment.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair methods of competition.
The attached Analysis of Proposed Consent Orders to Aid Public Comment
describes both the allegations in the complaint and the terms of the
consent orders--embodied in the consent agreement--that would settle
these allegations.
DATES: Comments must be received on or before July 22, 2021.
ADDRESSES: Interested parties may file comments online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Please write: ``Louisiana Real
Estate Appraisers Board; File No. 161 0068, Docket No. 9374'' on your
comment, and file your comment online at www.regulations.gov by
following the instructions on the web-based form. If you prefer to file
your comment on paper, please 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: Patricia M. McDermott (202-326-2569),
Bureau of Competition, Federal Trade Commission, 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 a 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 of Agreement Containing Consent Orders 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 website at
this web address: https://www.ftc.gov/news-events/commission-actions.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before July 22, 2021.
Write ``Louisiana Real Estate Appraisers Board; File No. 161 0068,
Docket No. 9374'' 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 www.regulations.gov
website.
Due to protective actions in response to the COVID-19 pandemic and
the agency's heightened security screening, postal mail addressed to
the Commission will be subject to delay. We strongly encourage you to
submit your comments online through the www.regulations.gov website.
If you prefer to file your comment on paper, write ``Louisiana Real
Estate Appraisers Board; File No. 161 0068, Docket No. 9374'' 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.
Because your comment will be placed on the publicly accessible
website at www.regulations.gov, you are solely responsible for making
sure that your comment does not include any sensitive or confidential
information. In particular, your comment should not include any
sensitive personal information, such as your or anyone else'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 your comment does not include any
sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
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)--including in particular competitively sensitive
information such as costs, sales statistics, inventories, formulas,
patterns, devices, manufacturing processes, or customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule 4.9(c). 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). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted on www.regulations.gov--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from that website,
unless you submit a confidentiality request that meets the requirements
for such treatment under FTC Rule 4.9(c), and the General Counsel
grants that request.
Visit the FTC website at https://www.ftc.gov to read this Notice and
the news release describing this matter. The FTC Act and other laws
that the Commission administers permit the
[[Page 32679]]
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 July 22, 2021. For
information on the Commission's privacy policy, including routine uses
permitted by the Privacy Act, see https://www.ftc.gov/site-information/privacy-policy.
Analysis of Agreement Containing Consent Orders To Aid Public Comment
I. Introduction
The Federal Trade Commission (``Commission'') has accepted, subject
to final approval by the Commission, an Agreement Containing Consent
Order (``Consent Agreement'') with the Louisiana Real Estate Appraisers
Board (``the Board''). The Consent Agreement resolves allegations
against the Board in the administrative complaint issued by the
Commission on May 31, 2017.
The Commission has placed the Consent Agreement on the public
record for 30 days to solicit comments from interested persons.
Comments received during this period will become part of the public
record. After 30 days, the Commission will again review the Consent
Agreement and the comments received, and will decide whether it should
withdraw from the Consent Agreement, modify it, or issue the proposed
Order. The proposed Order is for settlement purposes only and does not
constitute an admission by the Board that it violated the law, or that
the facts alleged in the complaint, other than jurisdictional facts,
are true.
II. Challenged Conduct
This matter involves allegations that the Board unreasonably
restrained price competition for appraisal services in Louisiana. The
Board is a state regulatory agency controlled by Louisiana-licensed
appraisers. The Commission's complaint challenges the Board's
promulgation and enforcement of subparts A, B, and C of Rule 31101 of
Title 46 Part LXVII of the Professional and Occupational Standards of
the Louisiana Administrative Code (``Rule 31101'').
The complaint alleges that the Board's promulgation and enforcement
of Rule 31101 displaced competition and introduced a regime of rate
regulation. The Board's actions had the effect of requiring appraisal
management companies (``AMCs'') to pay rates for appraisal services
consistent with median fees identified in fee surveys commissioned and
published by the Board. Specifically, the Board investigated and issued
complaints against AMCs that paid fees below the rates specified in the
surveys, and entered into settlement agreements with AMCs that required
those companies to pay fees at or above the median fee survey levels.
The complaint alleges that the Board's actions exceeded the scope
of its obligations under the appraisal independence provisions in the
2010 Dodd-Frank Wall Street Reform and Consumer Protection Act (``Dodd-
Frank Act''). The complaint further alleges that the Board's conduct
resulted in anticompetitive harm in the form of higher appraisal fees
paid by AMCs in Louisiana, and that this harm is not outweighed by any
procompetitive benefits.
III. Legal Analysis
The factual allegations in the complaint support a finding that the
Board violated Section 5 of the FTC Act, 15 U.S.C. 45, by promulgating
and enforcing Rule 31101. Section 5 of the FTC Act prohibits unfair
methods of competition, including unlawful agreements in restraint of
trade prohibited by Section 1 of the Sherman Act, 15 U.S.C. 1.\1\ Under
Section 1, a plaintiff must show (1) concerted action that (2)
unreasonably restrains competition.\2\
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\1\ 15 U.S.C. 45; see, e.g., FTC v. Cement Inst., 333 U.S. 683,
693-94 (1948).
\2\ 15 U.S.C. 1; see, e.g., Arizona v. Maricopa Cnty. Med. Soc.,
457 U.S. 332, 342-343 (1982).
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A state regulatory board that consists of market participants with
distinct and potentially competing economic interests engages in
concerted action when it adopts or enforces rules that govern the
conduct of its members' separate businesses.\3\ Rule 31101, adopted and
enforced by the Board, regulates the fees paid by AMCs to appraisers in
Louisiana, including those appraisers that serve as members of the
Board.
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\3\ See N.C. Bd. of Dental Exam'rs v. FTC., 574 U.S. 494, 510-12
(2015); In re N.C. Bd. of Dental Exam'rs, 2011 FTC LEXIS 290 at *38-
39, 2011-2 Trade Cas. (CCH) ] 77,705 (Comm'n Op. and Order, Dec. 7,
2011); see also Mass. Bd. of Registration in Optometry, 110 FTC 549,
1988 WL 1025476 at *47-48 (Comm'n Op. and Order, June 13, 1988).
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Price regulation practiced by market participants is a form of
price fixing and is per se unlawful.\4\ In the alternative, a restraint
on price competition may be judged inherently suspect: that is, the
agreement is presumed to be anticompetitive because the anticompetitive
nature of the challenged conduct is obvious.\5\
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\4\ FTC v. Ticor Title Ins. Co., 504 U.S. 621, 639 (1992)
(equating price regulation by market participants with per se
unlawful price fixing); Cal. Retail Liquor Dealers Ass'n v. Midcal
Aluminum, Inc., 445 U.S. 97, 103-106 (1980) (same); Goldfarb v. Va.
State Bar, 421 U.S. 773, 781-82 (1975) (same); Schwegmann Bros. v.
Calvert Distillers Corp., 341 U.S. 384, 386-390 (1951) (same); Ky.
Household Goods Carriers Ass'n., Inc. v. FTC, 199 F. App'x 410, 411
(6th Cir. 2006) (same).
\5\ N. Tex. Specialty Physicians v. FTC, 528 F.3d 346, 359-63
(5th Cir. 2008); Polygram Holding, Inc. v. FTC, 416 F.3d 29, 35-36
(D.C. Cir. 2005).
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The state action defense is not applicable here. On a motion for
partial summary decision, the Commission concluded: (1) The Board is
controlled by active market participants; (2) therefore, in order to
constitute state action, the Board's conduct must be actively
supervised by the State; and (3) the Board's promulgation and
enforcement of Rule 31101 were not actively supervised by the State of
Louisiana.\6\
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\6\ In the Matter of La. Real Est. Appraisers Bd., No. 9374, Op.
and Order of the Comm'n, at 19-20 (Apr. 10, 2018).
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The Dodd-Frank Act also does not give rise to a defense to
antitrust liability. Exemptions from the antitrust laws are to be
narrowly construed,\7\ and the general rule is, except where federal
statutes impose conflicting obligations, courts will give effect to
both statutes.\8\ The ``good faith regulatory compliance defense'' to
antitrust liability is a narrow, rarely invoked defense. The defense
applies only when there is an inconsistency between the antitrust laws
and the imperatives imposed on the respondent by federal regulation,
such that the respondent is not able to comply with both laws.\9\ ``The
defense does not insulate anticompetitive conduct that a respondent
freely chooses to undertake; the conduct must be necessitated by
regulatory and factual imperatives.'' \10\
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\7\ Union Labor Life Ins. Co., v. Pireno, 458 U.S. 119, 126
(1982).
\8\ See Pom Wonderful LLC v. Coca-Cola Co., 573 U.S. 102, 107
(2014) (``When two statutes complement each other, it would show
disregard for the congressional design to hold that Congress
nonetheless intended one federal statute to preclude the operation
of the other.''); Morton v. Mancari, 417 U.S. 535, 551 (1974) (``The
courts are not at liberty to pick and choose among congressional
enactments, and when two statutes are capable of co-existence, it is
the duty of the courts, absent a clearly expressed congressional
intention to the contrary, to regard each as effective.''); United
States v. Borden Co., 308 U.S. 188, 198 (1939) (``When there are two
acts upon the same subject, the rule is to give effect to both if
possible.'')
\9\ In the Matter of La. Real Est. Appraisers Bd., No. 9374, Op.
and Order of the Comm'n, at 5-7 (May 6, 2019) (``May 6 Comm'n
Order''); see also PhoneTele, Inc. v. Am. Tel. & Tel. Co., 664 F.2d
716, 737-38 (9th Cir. 1981) (defendant must establish that ``at the
time the various anticompetitive acts alleged here were taken, it
had a reasonable basis to conclude that its actions were
necessitated by concrete factual imperatives recognized as
legitimate by the regulatory authority'').
\10\ May 6 Comm'n Order at 7 (citing PhoneTele, 664 F.2d at 737-
38).
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[[Page 32680]]
With regard to the Board's conduct at issue here, there is no
conflict or inconsistency between the Board's obligations under the
Dodd-Frank Act and its obligations under the antitrust laws; the Board
may readily comply with both laws. The Dodd-Frank Act invites States
(and not private actors such as the Board) to cooperate with federal
authorities in regulating the real estate appraisal industry. The
antitrust laws constrain the actions of private actors (such as the
Board), but do not apply to states acting in their sovereign
capacity.\11\ It follows that, if the State of Louisiana wishes to use
a regulatory board as its instrument for implementing Dodd-Frank
responsibilities, it can avoid antitrust complications by complying
with the requirements of the state action doctrine. This assures the
resulting regulatory regime furthers the governmental interests of the
State, and not the private interests of market participants.\12\
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\11\ Parker v. Brown, 317 U.S. 341, 350-51 (1943).
\12\ See N.C. Dental, 574 U.S. at 505-12.
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IV. The Proposed Order
The proposed Order remedies the Board's anticompetitive conduct by
requiring rescission of Rule 31101 and prohibiting the Board from
regulating or fixing appraisal fees in Louisiana.
Sections II and III of the proposed Order address the core of the
Board's anticompetitive conduct. Paragraph II.A prohibits the Board
from enforcing Rule 31101, or adopting or enforcing any other rule that
sets, determines, or fixes compensation levels for appraisal services.
Paragraph II.B prohibits the Board from raising, fixing, maintaining,
or stabilizing compensation levels for appraisal services; requiring or
encouraging an AMC to pay any specific fee or range of fees for
appraisal services; or requiring or encouraging appraisers to request
any specific fee or range of fees for appraisal services. Prohibited
conduct includes adopting a fee schedule for appraisal services or
requiring AMCs to pay fees consistent with a fee survey or schedule of
appraisal fees. Paragraph II.C prohibits the Board from discriminating
against any AMC based on the fees that the company pays for appraisal
services except in the limited circumstance described below. Prohibited
discrimination includes requesting information, conducting audits or
investigations, or holding enforcement hearings based on the AMC's
fees. The non-discrimination provision includes a proviso that permits
the Board to take actions necessary to comply with specific written
instructions it receives in conjunction with a compliance review by the
Appraisal Subcommittee of the Federal Financial Institutions
Examination Council, which monitors States' implementation of minimum
requirements for registration and supervision of AMCs under the Dodd-
Frank Act. A copy of these instructions must be provided to Commission
staff no later than 15 days after receipt, together with a description
of how the Board will comply with them. The proviso does not apply to
or limit the broad prohibitions on interfering with price competition
set forth in Paragraphs II.A and II.B of the proposed Order. Paragraph
III.A requires the Board to rescind Rule 31101, and any enforcement
order based on an alleged violation of Rule 31101, within 30 days of
the issuance of the Order. Paragraph III.B requires the Board to notify
the Commission within 60 days any time the Board adopts a new rule or
amends an existing rule relating to compensation levels for appraisal
services.
Section IV requires the Board to provide notice of the Order to the
Board's members and employees, as well as each AMC licensed by the
Board. Section V requires the Board to file with the Commission
verified written compliance reports. Section VI requires the Board to
notify the Commission in advance of changes in the Board's structure
that would affect its compliance obligations. Section VII requires that
the Board provide the Commission with access to certain information for
the purpose of determining or securing compliance with the Order.
Section VIII provides that the Order will terminate 20 years from the
date it is issued.
The purpose of this Analysis to Aid Public Comment is to invite and
facilitate public comment concerning the proposed Order. It does not
constitute an official interpretation of the proposed Order or in any
way modify its terms.
By direction of the Commission.
April J. Tabor,
Secretary.
[FR Doc. 2021-13139 Filed 6-21-21; 8:45 am]
BILLING CODE 6750-01-P