Comment by db48x

6 days ago

Suppose I am selling magazine subscriptions. I basically already follow all of the FTC’s new rules, because I’m not trying to cheat. But the new rules are pages and pages of amendments to pages and pages of existing rules. Those rules are complicated and detailed. How can I be _sure_ that _all_ of my marketing materials are compliant with these new rules, which detail exactly what information I must disclose to my customers and potential customers. I have to first understand the new rules, then review all my existing marketing materials, possibly with the aid of legal advice. Maybe I have to reword some things so that I’m using exactly the language specified by the FTC. Changing a website is cheap, but what about my printed materials? I’ve got 6 editions in various stages of completion for each of my dozen different brands.

Those costs are definitely going to be passed along to the consumer in some form or another. Fewer sales, fewer discounts, higher subscription prices, higher advertising prices, thinner magazines, it doesn’t matter. It all flows down to the consumers in the end. I don’t see how you can argue that these costs _can’t_ be passed down to the consumers.

And it’s definitely going to cost more than $1,000. The FTC estimates that there are over a hundred thousands entities offering subscriptions of some kind to customers in the US. 100,000 × $1,000 = $100,000,000. That’s the threshold beyond which rules changes need additional review.

> I don’t see how you can argue that these costs _can’t_ be passed down to the consumers.

Because you've ignored the profits factor and have supposed away the other factor I mentioned as part of your hypothetical

  • > The ease with which you can continue to charge consumers without providing value to them directly affects the total amount of those charges (also, profits is a variable)

    I can’t even parse this sentence. You appear to be assuming a dishonest magazine company, rather than an honest one. The hundred million rule is there to protect the honest companies from overly–complex rules brought about in an attempt to eliminate dishonest ones, so starting with a dishonest one is irrelevant. We know that they are not going to comply with the rules to start with, so the cost to them is irrelevant.

    And profits are always variable, but that doesn’t matter. No matter how much or little your profit margin happens to be, increased costs can always be passed on to the consumer.