Agency Information Collection Activities; Proposed Collection; Comment Request; Extension
In accordance with the Paperwork Reduction Act of 1995 (PRA), the Federal Trade Commission (FTC or Commission) is seeking public comment on its proposal to extend for an additional three years the Office of Management and Budget (OMB) clearances for information collection requirements in Regulations B, E, M, and Z, which are enforced by the Commission. These clearances expire on November 30, 2024.
What this rule actually says
The FTC is extending its own internal paperwork requirements for three years. This is about *how the FTC collects information from companies*—not new rules about what AI founders can or cannot do. Specifically, the FTC wants to keep existing data collection procedures for consumer protection regulations (B, E, M, Z) active through 2027. Think of it as the FTC renewing its own permission slip to send surveys and information requests to businesses.
Who it applies to
- If you're a U.S.-based AI company: This potentially affects you, since the FTC has broad jurisdiction over "unfair or deceptive practices" in commerce.
- If you collect consumer data (medical histories, hiring records, customer support conversations, etc.): You're in the FTC's wheelhouse and may receive information requests from them.
- If you're outside the U.S.: You're mostly out of scope *unless* you have U.S. customers or handle U.S. consumer data.
- AI use cases that matter: Medical scribes handling patient data, hiring tools processing job applications, chatbots collecting user information, and support assistants retaining customer data all fall under potential FTC scrutiny.
- Data scope: The FTC cares about personal information (names, health records, employment history, behavioral data). Purely anonymized, non-identifiable data is lower risk.
What founders need to do
- Do nothing immediately (0 days). This is a procedural renewal, not a new regulation. Keep building.
- Understand your data practices (2-3 days). Document what consumer data you collect, how you store it, and how you use it. This matters for FTC compliance *generally*, not just this extension.
- Monitor FTC guidance on AI (ongoing, 1-2 hours/month). The FTC is actively issuing AI-specific guidance (like rules against deceptive AI claims). Subscribe to FTC.gov announcements so you don't miss actual new rules.
- Prepare for possible FTC inquiries (1 day, later). If the FTC sends you a data request or complaint, respond truthfully and consider consulting a lawyer. These extension renewals increase the likelihood they'll actually use these information-gathering tools.
- Audit your terms and disclosures (3-5 days). Make sure your privacy policy, consent mechanisms, and data handling actually match what you claim. This is evergreen best practice.
Bottom line
Monitor, don't panic—this rule doesn't change what you can build, but it signals the FTC is staying active on consumer data, so keep your data practices honest and documented.