83 FR 18061 - Uber Technologies, Inc.; Analysis To Aid Public Comment

FEDERAL TRADE COMMISSION

Federal Register Volume 83, Issue 80 (April 25, 2018)

Page Range		18061-18064
FR Document		2018-08600

The consent agreement in this matter settles alleged violations of federal law prohibiting unfair or deceptive acts or practices. The attached Analysis To Aid Public Comment describes both the allegations in the complaint and the terms of the consent order-- embodied in the consent agreement--that would settle these allegations.

Federal Register, Volume 83 Issue 80 (Wednesday, April 25, 2018)

[Federal Register Volume 83, Number 80 (Wednesday, April 25, 2018)]
[Notices]
[Pages 18061-18064]
From the Federal Register Online [www.thefederalregister.org]
[FR Doc No: 2018-08600]

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FEDERAL TRADE COMMISSION

[File No. 152 3054]

Uber Technologies, Inc.; Analysis To Aid Public Comment

AGENCY: Federal Trade Commission.

ACTION: Proposed consent agreement.

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SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair or deceptive acts or
practices. The attached Analysis To Aid Public Comment describes both
the allegations in the 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 May 14, 2018.

ADDRESSES: Interested parties may file a comment online or on paper, by
following the instructions in the Request for Comment part of the
SUPPLEMENTARY INFORMATION section below. Write: ``Uber Technologies,
Inc.'' on your comment, and file your comment online at https://ftcpublic.commentworks.com/ftc/reviseduberconsent by following the
instructions on the web-based form. If you prefer to file your comment
on paper, write ``Uber Technologies, Inc.'' 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:
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: Ben Rossen (202-326-3679) and James
Trilling (202-326-3497), Bureau of Consumer Protection, 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 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 April 12, 2018), on the World Wide Web, at
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 May 14, 2018.
Write ``Uber Technologies, Inc.'' 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 website, at https://www.ftc.gov/policy/public-comments.
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/reviseduberconsent by following the instructions on the web-based
form. If this Notice appears at http://www.regulations.gov/#!home, you
also may file a comment through that website.
If you prefer to file your comment on paper, write ``Uber
Technologies, Inc.'' on your comment and on the envelope, and mail your
comment to the following

[[Page 18062]]

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 FTC
website at https://www.ftc.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 that 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 the public FTC website--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from the FTC 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 http://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 May 14, 2018. 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 Proposed Consent Order To Aid Public Comment

The Federal Trade Commission has withdrawn its acceptance of the
agreement containing consent order from Uber Technologies, Inc.
(``Uber'') that the Commission released for public comment in this
proceeding on August 15, 2017 (``August 2017 proposed consent
agreement''), and has accepted, subject to final approval, a new
agreement containing consent order from Uber (``April 2018 proposed
consent agreement'').
The April 2018 proposed consent agreement has been placed on the
public record for thirty (30) days for receipt of comments by
interested persons. All comments received during this period will
become part of the public record. Interested persons who submitted
comments during the public comment period for the August 2017 proposed
consent agreement should resubmit their original comments, or submit
new comments, during the new comment period if they would like the
Commission to consider their comments when the Commission decides
whether to make final the April 2018 proposed consent agreement. After
thirty (30) days, the Commission again will review the April 2018
proposed consent agreement, and the comments received, and will decide
whether it should withdraw from the agreement or make final the
agreement's proposed order.
Since 2010, Uber has operated a mobile application (the ``App'')
that connects consumers who are transportation providers (``Drivers'')
with consumers seeking those services (``Riders''). Riders book
transportation or delivery services through a publicly-available
version of the App that can be downloaded to a smartphone. When a Rider
requests transportation through the App, the request is conveyed to a
nearby Uber Driver signed into the App.
Drivers use the App to determine which ride requests they will
accept. Uber collects a variety of personal information from Drivers,
including names, email addresses, phone numbers, postal addresses,
Social Security numbers, driver's license numbers, bank account
information, vehicle registration information, and insurance
information. With respect to Riders, Uber collects names, email
addresses, postal addresses, and detailed trip records with precise
geolocation information, among other things.
In November 2014, Uber was the subject of various news reports
describing improper access and use of consumer personal information,
including geolocation information, by Uber employees. One article
reported that an Uber executive had suggested that Uber should hire
``opposition researchers'' to look into the ``personal lives'' of
journalists who criticized Uber's practices. Another article described
an aerial tracking tool known as ``God View'' that displayed the
personal information of Riders using Uber's services. These reports led
to considerable consumer uproar. In an effort to respond to consumer
concerns, Uber issued a statement describing its policies concerning
access to Rider and Driver data. As part of that statement, Uber
promised that all ``access to rider and driver accounts is being
closely monitored and audited by data security specialists on an
ongoing basis, and any violations of the policy will result in
disciplinary action, including the possibility of termination and legal
action.''
As alleged in the proposed complaint, Uber has not monitored or
audited its employees' access to Rider and Driver personal information
on an ongoing basis since November 2014. In fact, between approximately
August 2015 and May 2016, Uber did not timely follow up on automated
alerts concerning the potential misuse of consumer personal
information, and for approximately the first six months of this period
only monitored access to account information belonging to a set of
internal high-profile users, such as Uber executives. During this time,
Uber did not otherwise monitor internal access to personal information
unless an employee specifically reported that a co-worker had engaged
in improper access. Count one of the proposed complaint alleges that
Uber's representation that it closely monitored and audited internal
access to consumers' personal information was false or misleading in
violation of Section 5 of the FTC Act in light of Uber's subsequent
failure to

[[Page 18063]]

monitor and audit such access between August 2015 and May 2016.\1\
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\1\ Count one of the proposed complaint and the underlying
factual allegations are unchanged from the proposed complaint
against Uber that the Commission issued previously as part of the
August 2017 proposed consent agreement.
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The proposed complaint also alleges that Uber failed to provide
reasonable security for consumer information stored in a third-party
cloud storage service provided by Amazon Web Services (``AWS'') called
the Amazon Simple Storage Service (the ``Amazon S3 Datastore''). Uber
stores in the Amazon S3 Datastore a variety of files that contain
sensitive personal information, including full and partial back-ups of
Uber databases. These back-ups contain a broad range of Rider and
Driver personal information, including, among other things, names,
email addresses, phone numbers, driver's license numbers, and trip
records with precise geolocation information.
From July 13, 2013 to July 15, 2015, Uber's privacy policy
described the security measures Uber used to protect the personal
information it collected from consumers, stating that such information
``is securely stored within our databases, and we use standard,
industry-wide commercially reasonable security practices such as
encryption, firewalls and SSL (Secure Socket Layers) for protecting
your information--such as any portions of your credit card number which
we retain . . . and geo-location information.'' Additionally, Uber's
customer service representatives offered assurances about the strength
of Uber's security practices to consumers who were reluctant to submit
personal information to Uber.
As described below, count two of the proposed complaint alleges
that the above statements violated Section 5 of the FTC Act because
Uber engaged in a number of practices that, taken together, failed to
provide reasonable security to prevent unauthorized access to Rider and
Driver personal information in the Amazon S3 Datastore.\2\
Specifically, Uber allegedly:
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\2\ Count two of the proposed complaint addresses the same
allegedly false or misleading statements as did count two of the
proposed complaint against Uber that the Commission issued as part
of the August 2017 proposed consent agreement. The proposed
complaint includes allegations that the now withdrawn complaint
included to support count two and also includes additional
allegations to support count two based on new information the
Commission obtained after August 2017.
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Failed to implement reasonable access controls to
safeguard data stored in the Amazon S3 Datastore. For example, Uber (1)
until approximately September 2014, permitted engineers to access the
Amazon S3 Datastore with a single, shared AWS access key that provided
full administrative privileges over all data stored there; (2) until
approximately September 2014, failed to restrict access to systems
based on employees' job functions; and (3) until approximately
September 2015, failed to require multi-factor authentication for
individual account access, and until at least November 2016, failed to
require multi-factor authentication for programmatic service account
access, to the Amazon S3 Datastore;
Until at least September 2014, failed to implement
reasonable security training and guidance;
Until approximately September 2014, failed to have a
written information security program; and
Until at least November 2016, stored sensitive personal
information in the Amazon S3 Datastore in clear, readable text, rather
than encrypting the information.
As a result of these failures, intruders accessed Uber's Amazon S3
Datastore multiple times using access keys that Uber engineers had
posted to GitHub, a code-sharing site used by software developers.
First, on or about May 12, 2014, an intruder accessed Uber's Amazon
S3 Datastore using an access key that was publicly posted and granted
full administrative privileges to all data and documents stored within
Uber's Amazon S3 Datastore (the ``2014 data breach''). The intruder
accessed one file that contained sensitive personal information
belonging to Uber Drivers, including over 100,000 unencrypted names and
driver's license numbers, 215 unencrypted names and bank account and
domestic routing numbers, and 84 unencrypted names and Social Security
numbers. Uber did not discover the breach until September 2014. Uber
sent breach notification letters to affected Uber Drivers in February
2015. Uber later learned of more affected Uber Drivers in May and July
2016 and sent breach notification letters to those Drivers in June and
August 2016.
Second, between October 13, 2016 and November 15, 2016, intruders
accessed Uber's Amazon S3 Datastore using an AWS access key that was
posted to a private GitHub repository (``the 2016 data breach''). Uber
granted its engineers access to Uber's GitHub repositories through
engineers' individual GitHub accounts, which engineers generally
accessed through personal email addresses. Uber did not have a policy
prohibiting engineers from reusing credentials, and did not require
engineers to enable multi-factor authentication when accessing Uber's
GitHub repositories. The intruders who committed the 2016 breach said
that they accessed Uber's GitHub page using passwords that were
previously exposed in other large data breaches, whereupon they
discovered the AWS access key they used to access and download files
from Uber's Amazon S3 Datastore. The intruders downloaded sixteen files
that contained unencrypted consumer personal information relating to
U.S. Riders and Drivers, including approximately 25.6 million names and
email addresses, 22.1 million names and mobile phone numbers, and
607,000 names and driver's license numbers. Nearly all of the exposed
personal information was collected before July 2015 and stored in
unencrypted database backup files.
Uber discovered the 2016 data breach on or about November 14, 2016,
when one of the attackers contacted Uber claiming to have compromised
Uber's ``databases'' and demanding a six-figure payout. Uber paid the
attackers $100,000 through the third party that administers Uber's
``bug bounty'' program. Respondent created the bug bounty program to
pay financial rewards in exchange for the responsible disclosure of
serious security vulnerabilities. However, the attackers who committed
the 2016 data breach were fundamentally different from legitimate bug
bounty recipients. Instead of responsibly disclosing a vulnerability,
the attackers maliciously exploited the vulnerability and acquired
millions of consumers' personal information.
Uber failed to disclose the 2016 data breach to affected consumers
until November 21, 2017, more than a year after discovering it. Uber
also failed to disclose the 2016 data breach to the Commission until
November 2017 despite the fact that the breach occurred in the midst of
a nonpublic Commission investigation relating to Uber's data security
practices, including, specifically, the security of Uber's Amazon S3
Datastore.
The proposed consent order contains provisions designed to prevent
Uber from engaging in acts and practices in the future similar to those
alleged in the proposed complaint.
Part I of the proposed order prohibits Uber from making any
misrepresentations about the extent to which Uber monitors or audits
internal access to consumers' personal information or the extent to
which Uber protects the privacy, confidentiality, security, or
integrity of consumers' personal information. This Part is identical to
Part I of the August 2017 proposed consent agreement.

[[Page 18064]]

Part II of the proposed order requires Uber to implement a mandated
comprehensive privacy program that is reasonably designed to (1)
address privacy risks related to the development and management of new
and existing products and services for consumers, and (2) protect the
privacy and confidentiality of consumers' personal information. Part
II.B includes new language that requires Uber's mandated privacy risk
assessments to include consideration of risks and safeguards related to
(a) secure software design, development, and testing, including access
key and secret key management and secure cloud storage; (b) review,
assessment, and response to third-party security vulnerability reports,
including through a ``bug bounty'' or similar program; and (c)
prevention, detection, and response to attacks, intrusions, or systems
failures.
Part III of the proposed order requires Uber to undergo biennial
assessments of its mandated privacy program by a third party. Part III
has been revised from the August 2017 proposed consent agreement to
require Uber to submit to the Commission each of its assessments rather
than only its initial assessment.
Part IV of the proposed order requires Uber to submit a report to
the Commission if Uber discovers any ``covered incident'' involving
unauthorized access or acquisition of consumer information. This Part
is new.
Parts V through IX of the proposed order are reporting and
compliance provisions. Part V requires dissemination of the order now
and in the future to all current and future principals, officers,
directors, and managers, and to persons who participate in conduct
related to the subject matter of the order, including all employees,
agents, and representatives who regularly access personal information.
Part VI mandates that Uber submit a compliance report to the FTC one
year after issuance of the order and submit additional notices as
specified. Parts VII and VIII require Uber to retain documents relating
to its compliance with the order, and to provide such additional
information or documents as are necessary for the Commission to monitor
compliance. Part IX states that the order will remain in effect for 20
years.
These provisions include modifications from the August 2017
proposed consent agreement. Part V expands the acknowledgement of order
provision to require Uber to obtain signed acknowledgements from all
employees, agents, and representatives who regularly access personal
information that Uber collects or receives from or about consumers,
rather than limiting the requirement to employees with managerial
responsibility related to the order. And Part VII contains modified
recordkeeping provisions and new recordkeeping provisions relating to
Uber's bug bounty program and its subpoenas and communications with law
enforcement.
The purpose of this analysis is to aid public comment on the
proposed order. It is not intended to constitute an official
interpretation of the complaint or proposed order, or to modify in any
way the proposed order's terms.

By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2018-08600 Filed 4-24-18; 8:45 am]
BILLING CODE 6750-01-P

18064 Federal Register / Vol. 83, No. 80 / Wednesday, April 25, 2018 / Notices

Part II of the proposed order requires receives from or about consumers, limitations imposed by the review and
Uber to implement a mandated rather than limiting the requirement to funding cycle.
comprehensive privacy program that is employees with managerial Name of Committee: National Institute of
reasonably designed to (1) address responsibility related to the order. And Diabetes and Digestive and Kidney Diseases
privacy risks related to the development Part VII contains modified Special Emphasis Panel; NIDDK KUH
Fellowship Review.
and management of new and existing recordkeeping provisions and new Date: June 6, 2018.
products and services for consumers, recordkeeping provisions relating to Time: 8:00 a.m. to 2:00 p.m.
and (2) protect the privacy and Uber’s bug bounty program and its Agenda: To review and evaluate grant
confidentiality of consumers’ personal subpoenas and communications with applications.
information. Part II.B includes new law enforcement. Place: Bethesda North Marriott Hotel and
language that requires Uber’s mandated The purpose of this analysis is to aid Conference Center, Montgomery County
privacy risk assessments to include public comment on the proposed order. Conference Center Facility, 5701 Marinelli
consideration of risks and safeguards It is not intended to constitute an Road, Bethesda, MD 20852.
related to (a) secure software design, Contact Person: Xiaodu Guo, MD, Ph.D.,
official interpretation of the complaint
development, and testing, including Scientific Review Officer, Review Branch,
or proposed order, or to modify in any DEA, NIDDK, National Institutes of Health,
access key and secret key management way the proposed order’s terms. Room 7023, 6707 Democracy Boulevard,
and secure cloud storage; (b) review, Bethesda, MD 20892–5452, (301) 594–4719,
assessment, and response to third-party By direction of the Commission.
guox@extra.niddk.nih.gov.
security vulnerability reports, including Donald S. Clark,
Name of Committee: National Institute of
through a ‘‘bug bounty’’ or similar Secretary. Diabetes and Digestive and Kidney Diseases
program; and (c) prevention, detection, [FR Doc. 2018–08600 Filed 4–24–18; 8:45 am] Special Emphasis Panel; The NIDDK DDK–D
and response to attacks, intrusions, or BILLING CODE 6750–01–P Member Conflict SEP.
systems failures. Date: June 6, 2018.
Part III of the proposed order requires Time: 9:00 a.m. to 3:00 p.m.
Uber to undergo biennial assessments of Agenda: To review and evaluate grant
its mandated privacy program by a third DEPARTMENT OF HEALTH AND applications.
party. Part III has been revised from the HUMAN SERVICES Place: Bethesda North Marriott Hotel and
August 2017 proposed consent Conference Center, Montgomery County
agreement to require Uber to submit to National Institutes of Health Conference Center Facility, 5701 Marinelli
Road, North Bethesda, MD 20852.
the Commission each of its assessments National Institute of Diabetes and Contact Person: Xiaodu Guo, MD, Ph.D.,
rather than only its initial assessment. Digestive and Kidney Diseases; Notice Scientific Review Officer, Review Branch,
Part IV of the proposed order requires DEA, NIDDK, National Institutes of Health,
of Closed Meetings
Uber to submit a report to the Room 7023, 6707 Democracy Boulevard,
Commission if Uber discovers any Pursuant to section 10(d) of the Bethesda, MD 20892–5452, (301) 594–4719,
‘‘covered incident’’ involving Federal Advisory Committee Act, as guox@extra.niddk.nih.gov.
unauthorized access or acquisition of amended, notice is hereby given of the Name of Committee: National Institute of
consumer information. This Part is new. following meetings. Diabetes and Digestive and Kidney Diseases
Parts V through IX of the proposed The meetings will be closed to the Special Emphasis Panel; Fellowships in
order are reporting and compliance public in accordance with the Digestive Diseases and Nutrition.
provisions. Part V requires Date: June 7–8, 2018.
provisions set forth in sections
dissemination of the order now and in Time: 8:00 a.m. to 5:00 p.m.
552b(c)(4) and 552b(c)(6), Title 5 U.S.C., Agenda: To review and evaluate grant
the future to all current and future as amended. The grant applications and applications.
principals, officers, directors, and the discussions could disclose Place: Residence Inn Bethesda, 7335
managers, and to persons who confidential trade secrets or commercial Wisconsin Avenue, Bethesda, MD 20814.
participate in conduct related to the property such as patentable material, Contact Person: Jian Yang, Ph.D., Scientific
subject matter of the order, including all and personal information concerning Review Officer, Review Branch, DEA,
employees, agents, and representatives individuals associated with the grant NIDDK, National Institutes of Health, Room
who regularly access personal applications, the disclosure of which 7111, 6707 Democracy Boulevard, Bethesda,
information. Part VI mandates that Uber MD 20892–5452, (301) 594–7799, yangj@
would constitute a clearly unwarranted
submit a compliance report to the FTC extra.niddk.nih.gov.
invasion of personal privacy.
one year after issuance of the order and Name of Committee: National Institute of
submit additional notices as specified. Name of Committee: National Institute of Diabetes and Digestive and Kidney Diseases
Diabetes and Digestive and Kidney Diseases Special Emphasis Panel; DDK–C Conflicts.
Parts VII and VIII require Uber to retain Special Emphasis Panel; NIDDK–KURe–K12
documents relating to its compliance Date: June 8, 2018.
Telephone Review. Time: 8:00 a.m. to 12:00 p.m.
with the order, and to provide such Date: May 7, 2018. Agenda: To review and evaluate grant
additional information or documents as Time: 12:00 p.m. to 1:30 p.m. applications.
are necessary for the Commission to Agenda: To review and evaluate grant Place: Residence Inn Bethesda, 7335
monitor compliance. Part IX states that applications. Wisconsin Avenue, Bethesda, MD 20814.
the order will remain in effect for 20 Place: National Institutes of Health, Two Contact Person: Jian Yang, Ph.D., Scientific
years. Democracy Plaza, 6707 Democracy Review Officer, Review Branch, DEA,
These provisions include Boulevard, Bethesda, MD 20892 (Telephone NIDDK, National Institutes of Health, Room
modifications from the August 2017 Conference Call). 7111, 6707 Democracy Boulevard, Bethesda,
sradovich on DSK3GMQ082PROD with NOTICES

Contact Person: Xiaodu Guo, MD, Ph.D., MD 20892–5452, (301) 594–7799, yangj@
proposed consent agreement. Part V Scientific Review Officer, Review Branch, extra.niddk.nih.gov.
expands the acknowledgement of order DEA, NIDDK, National Institutes of Health, Name of Committee: National Institute of
provision to require Uber to obtain Room 7023, 6707 Democracy Boulevard, Diabetes and Digestive and Kidney Diseases
signed acknowledgements from all Bethesda, MD 20892–5452, (301) 594–4719, Special Emphasis Panel; O’Brien Urology
employees, agents, and representatives guox@extra.niddk.nih.gov. Centers.
who regularly access personal This notice is being published less than 15 Date: July 10–11, 2018.
information that Uber collects or days prior to the meeting due to the timing Time: 3:00 p.m. to 6:00 p.m.

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Category		Regulatory Information
Collection		Federal Register
sudoc Class		AE 2.7: GS 4.107: AE 2.106:
Publisher		Office of the Federal Register, National Archives and Records Administration
Section		Notices
Action		Proposed consent agreement.
Dates		Comments must be received on or before May 14, 2018.
Contact		Ben Rossen (202-326-3679) and James Trilling (202-326-3497), Bureau of Consumer Protection, 600 Pennsylvania Avenue NW, Washington, DC 20580.
FR Citation		83 FR 18061