The FTC’s Bureau of Economics (“BE”) values an open exchange of ideas between the staff and experts outside the agency. This enables the staff to learn about new ideas and perspectives, hone their professional skills, and receive feedback on their work. Such a dialogue requires transparency with respect to relationships with interested parties so that there is no question whether undisclosed relationships may have exerted influence on the opinions expressed.
The goal of this document is to clarify BE’s policies regarding these disclosures. The policy is a modified version of the and is in the spirit of similar policies at other professional organizations and journals.
Who should disclose?
Every participant in a BE-sponsored event such as a conference, workshop, or seminar is required to disclose any of the circumstances listed below. Participants include paper presenters, co-authors of presented papers, discussants, panelists, and scientific committee members. Audience members are not considered participants for purposes of this policy (even if they ask questions of participants or make other comments at the event).
What types of circumstances should be disclosed?
- All sources of financial support for the material included in the presentation. Disclosure is required regardless of the monetary value of the support and when it was received.
- Support summing to $10,000 received within the last three years or where there is a reasonable expectation of receiving in the future from an “interested” party. An “interested” party is any individual, group, or organization that has a financial, ideological, or political stake in topic(s) related to participation in the event. This should include any support received both directly and indirectly, including funding for centers and institutes that are material benefit to the author(s).
- Significant personal involvement or any financial support in relation to a specific matter to be addressed by the participant at the event. Employees or former employees of government agencies or consulting firms may not be able to disclose whether they worked on a specific matter but should disclose whether they worked at the agency or firm while the matter was under consideration without any indication of their own involvement in the matter.
- Any paid or unpaid positions as officer, director, or board member of any organization whose policy positions, goals, or financial interests relate to the topics associated with their participation in the event.
- If the participant is subject to a nondisclosure agreement with respect to the support in question, the participant should state that they received funding along with as much information about the interested party as allowed.
- Any third-party that had the right to review the research and/or presentation prior to its circulation.
Whose interests must be disclosed?
- The participant,
- The participant’s spouse,
- Participant’s coauthors on any presented research, and
- Spouses of any relevant coauthors.
What is considered financial support?
Support may be in the form of in-kind data support, research grants, consulting fees, retainers, and the like.
How should the information be disclosed?
For an oral presentation: Provide an oral disclosure and write the disclosure on a slide that is visible to the audience.
For written materials (e.g., papers distributed in advance of an event): Write the disclosure on either the title page or first page of the written materials.
For conferences: Submit a written disclosure to FTC staff, who will make it available on the event website (if applicable).
What if there is nothing to disclose?
That should be explicitly stated as the disclosure.
What if someone cannot make these disclosures?
In cases where the participant cannot make these disclosures, they are expected to recuse themselves from participating in the event.