The AAI responded to an FTC request for comments on its Guides for Advertising Allowances and Other Merchandising Payments and Services (the “Fred Meyer Guides”). AAI’s comments describe relevant changes in business practice that the FTC should consider. The comments were principally authored by Gregory Gundlach, a director of the AAI and professor of marketing at the University of North Florida.
In late 2012, as part of the Federal Trade Commission’s (FTC) review of current regulations and guides, public comments were requested for review of its Guides for Advertising Allowances and Other Merchandising Payments and Services. Also known as the “the Fred Meyer Guides,” the Guides were designed to assist businesses in complying with sections 2(d) and 2(e) of the Clayton Act, as amended by the Robinson-Patman Act. The FTC sought input on, among other questions, “the effect on the Guides of any technological, economic, or other industry changes” since the Guides were last published in 1990. Guided by the principle that knowledge of business practice should inform the FTC’s review, the AAI submitted a comment that describes relevant changes in business practice to marketing channel management, distribution strategy, retailing (e.g., Internet), and trade promotion.
