What reporting obligations are generally imposed on respondents?
In cases in which respondents have a post-order divestiture obligation, they are generally required to keep the Commission and the Compliance Division staff informed of their divestiture efforts. In the consent agreement itself, respondents generally agree to submit an “Initial Compliance Report” either at the time that the Commission considers whether to accept the consent order for placement on the public record, or within a short time thereafter. Subsequent reports on the divestiture effort are required either monthly or bi-monthly. To the extent there are obligations in the order beyond the divestiture obligation, respondents are usually required to submit annual reports to the Commission on their continued compliance with those obligations. Compliance Division staff is always available to speak with respondents on their compliance efforts, and the Compliance Division encourages representatives of respondents to maintain communication with the staff.
