Suppose I am selling magazine subscriptions. I basically already follow all of the FTC’s new rules, because I’m not trying to cheat. But the new rules are pages and pages of amendments to pages and pages of existing rules. Those rules are complicated and detailed. How can I be _sure_ that _all_ of my marketing materials are compliant with these new rules, which detail exactly what information I must disclose to my customers and potential customers. I have to first understand the new rules, then review all my existing marketing materials, possibly with the aid of legal advice. Maybe I have to reword some things so that I’m using exactly the language specified by the FTC. Changing a website is cheap, but what about my printed materials? I’ve got 6 editions in various stages of completion for each of my dozen different brands.
Those costs are definitely going to be passed along to the consumer in some form or another. Fewer sales, fewer discounts, higher subscription prices, higher advertising prices, thinner magazines, it doesn’t matter. It all flows down to the consumers in the end. I don’t see how you can argue that these costs _can’t_ be passed down to the consumers.
And it’s definitely going to cost more than $1,000. The FTC estimates that there are over a hundred thousands entities offering subscriptions of some kind to customers in the US. 100,000 × $1,000 = $100,000,000. That’s the threshold beyond which rules changes need additional review.