Chamber Signs Letter Requesting Extension on FTC Non-Compete Clause Rule

Re: Notice of Proposed Rulemaking, Federal Trade Commission; Non-Compete Clause Rule; 88 Fed. Reg. 3482 (RIN: 3084-AB74) (January 19, 2023)

Dear Ms. Tabor:

The 100 undersigned organizations request that the Federal Trade Commission (“FTC”) extend the comment period to the above-referenced notice of proposed rulemaking (“NPRM”) for an additional 60 days. The regulated community should be given sufficient time to assess the potential consequences of the rulemaking and develop insightful comments for the Commission to consider.

This rulemaking, as the FTC itself acknowledges, will impact a significant portion of the economy. Given the breadth of the rule, a sufficient comment period is needed to ensure the regulated community can fully assess its effects.

Moreover, there are significant legal questions that must be addressed by commenters. Among the issues raised by the FTC action is whether the Commission has the legal authority to issue such a rulemaking, the rule’s potential preemption of the numerous state laws and regulations on this issue, and how such preemption will alter the regulated community’s legal obligations.

Considering the potential impact of this proposal, the undersigned organizations urge the FTC to extend the comment period an additional 60 days. Doing so would ensure the regulated community can fully and confidently provide comprehensive comments to the Commission. Thank you for your consideration of this matter.

Sincerely,

Greater Cheyenne Chamber of Commerce