Superseded Informal Interpretations

The following Informal Interpretations no longer, in part or full, represent the positions of the PNO. You should not rely on them or cite them as current, valid advice from the PNO.

This list only include letters superseded since January 1, 2019. There are many other superseded interpretations in the database. Older superseded interpretations will use the phrase “This is no longer the position of the PNO,” in the Response/Comments field. If you have questions about the validity of an older interpretation, contact the PNO at HSRHelp@ftc.gov.

You should not rely on Informal Interpretations as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

  • Informal Interpretation 1904001 supersedes Informal Interpretation 1303005 (07/09/19)
  • Informal Interpretation 1905002 supersedes Informal Interpretation 1407004 (07/09/19)

Informal Interpretations updated through June 1, 2019.