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 On October 20, 2022, the Federal Trade Commission (FTC) announced that it was exploring a new proposed rule on “Unfair or Deceptive Fees” to crack down on supposed junk fees proliferating through the economy. The Commission then voted 3-1 approving publication of the advance notice of proposed rulemaking (ANPRM), which received over 12,000 comments.  On November 9, 2023, the FTC published a notice of proposed rulemaking (NPRM) entitled “Rule on Unfair or Deceptive Fees,” which would prohibit unfair or deceptive practices relating to fees for goods or services, specifically misrepresenting the total costs of goods and services by omitting mandatory fees from advertised prices and misrepresenting the nature and purpose of fees.
With the announcement of the new rule, the FTC opened a 60-day public comment period that closed on January 8, 2024, but was extended an additional 30-days to February 7, 2024.  On the last day before the extended comment period closed, the Federal Motor Carriers Safety Administration (FMCSA), a division of the Department of Transportation (DOT), submitted comments in support of the proposed rule stating in part:
“The proposed regulation may significantly benefit FMCSA’s regulated community, specifically as it relates to the predatory towing practices that have a substantial financial impact on CMV owner operators.” Further, the comments state “FMCSA believes that these predatory towing fee practices fall within the purview of FTC’s proposed regulation on unfair or deceptive fees and offers the following support and suggestions for consideration” and go on to suggest additional regulations to target what they perceive to be predatory towing practices. (Emphasis added)
As of midnight on February 7, 2024, the comment period has closed and no more comments can be submitted. To this day, no one from the towing and recovery industry submitted comments, participated in the rule making process, or informed our vast community about the potential devastating impact these rules will have on our businesses and livelihood. 
These circumstances end today. 


We created the National Open Commerce and Safer Highways Coalition (NOCSHC) – to fight this unnecessary and likely devastating government action, participate in the process, defend and inform the industry, and prepare for any and all action necessary to respond.  NOCSHC is a coalition of committed towing and recovery companies, allied businesses and emergency responder communities employed and dedicated to keeping our roads open and safe. We are taking immediate action to:

· Retain the highest caliber legal representation to engage the FTC rulemaking process where it stands today, assess the risk and liability the rule poses to the industry, and prepare to take any and all legal actions to protect and defend our interests at the Federal level. 
· Retain federal lobbying representation to engage Members of Congress regarding their oversight of the regulatory process, engage the FTC, FMCSA, and DOT, and tirelessly advocate for the coalition to ensure our voice is heard.   

· Inform the industry.  Everyone deserves to know the impact and liability your business faces and what is being done to address the proposed rule.  The NOCSHC will be your source of information and your voice in Washington, DC.  


For far too long there has been silence and inaction from the towing and recovery industry.  The NOCSHC will speak with a united voice and an unwavering commitment to fight this erroneous and unnecessary regulatory action so that this industry will never be silent. We will be prepared to fight back.  We are facing a grave and immediate threat from powerful and well-funded opposition working in concert with our industry’s same government regulators.  WE CAN NOT BE SILENT AND WE MUST TAKE ACTION NOW.  We need your help.  This battle requires an “all hands on deck” approach.  The consequences of this federal action are real and the process is well underway. We need EVERY towing and recovery company, every state association, every allied business, and our emergency responder partners to join this crucial effort today!  Please email to get involved today!!

NOHCSH Chairmen of the Board and CEO of central towing & Transport, Quinn Piening, had this to say about the launch of NOCSHC:


"Throughout my decades of experience in the towing and recovery industry, I have never seen a proposed regulatory action as egregious as the one proposed by the FTC.  The comments filed by the FMCSA to the NPRM, which are completely inaccurate and misleading, threaten not only our country's supply chain and highway safety, but the livelihoods of many hard-working blue-collar Americans. The industry now speaks with one unified voice against this proposed government overreach and, like centurions at the gate, we will protect against any and all future threats to our industry."


About NOCSHC : NOCSHC is an organization of committed towing and recovery companies, state trade associations, allied businesses, and the men and women employed to keep our roads open and safe. 

The coalition will provide industry and unified effort to ensure it has a voice in the policymaking process-both legislative and regulatory- through active education of both its members and policymakers about the impacts of proposed legislation and regulatory proceedings. Furthermore, the NOCSHC will provide proactive engagement and advocacy services for its members with agencies such as the FTC or legislative bodies like congress as they craft policies that could have harmful effects-whether intended or unintended-on the towing and recovery industry, its partners, or its workforce 




For far too long the towing and recovering industry has been under-represented and without proactive engagement to solve these problems. This newly formed coalition will speak with a united voice and an unwavering commitment to fight this erroneous and unnecessary regulatory action and prepare the industry for the battlles ahead. This industry will never be silent again. Be sure, this is a 911 emergency for our industry that requires an “all hands on deck” approach. This regulation, if enacted, will negatively impact our operations, livelihood and industry, and has the potential to be profound and devastating. Therefore, we need EVERY Tower to join this crucial effort and support this fight.





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