American Association of Language Specialists

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IN THE MATTER OF THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS CONSENT ORDER . ETC. , IN REGARD TO ALLEGED VIOLATION OF SEC. 5 OF THE FEDERAL TRADE COMMISSION ACT Docket C-3524. Complaint. Aug. 1994--Decision. Aug. , 1994 This consent order prohibits, among other things, the professional association of interpreters, based in Washington, D. , from fixing or otherwise interfering with any fann of price or fee competition among language specialists in the future; from maintaining any agreement or plan to limit or restrict the specialists working time or condition; for ten years, from making statements at an association meeting concerning fees; and, for three years, from compiling and distributing aggregate infonnation concerning fees already charged. Appearances For the Commission: Michael McNeeLy and Kent Cox. For the respondent: Charles D. Ossola, Lowe, Price, LeBlanc & Becker Alexandria, VA.

COMPLAINT Pursuant to the provisions of the Federal Trade Commission Act and by virtue of the authority vested in it by said Act, the Federal Trade Commission, having reason to believe that respondent The American Association of Language Specialists, a corporation, has violated the provisions of said Act, and it appearing to the Commssion that a proceeding by it in respect thereof would be in the public interest, hereby issues its complaint stating iis charges in that respect as follows:

PARAGRAPH 1. Respondent The American Association of Language Specialists (hereafter ' '1 AALS" ) is a corporation organized, existing and doing business under and by virtue of the laws of the District of Columbia, with its principal place of business located at 1000 Connecticut Avenue, N. , Washington, D.C. T AALS is a voluntary professional association of individuals engaged in confer- THE AMERICAN ASSOCIATION OF LANGUAGE SPECIALISTS 423 422 Complaint ence interpreting, translating, precis writing, and other language services.

PAR. 2. Conference interpreting is the practice of expressing, in spoken form, ideas in a language different from an original spoken statement made at conferences or other high level business, scientific humanitaran, cultural, governmental, or intergovernmental meetings. PAR. 3. Translating is the practice of expressing, in written form, ideas in a language different from an original writing. Precis writing is the practice of expressing, in written form, summaries minutes, or highlights of conferences or other high level business scientific, humanitaran, cultural, governmental, or intergovernmental meetings.

PAR. 4. Except to the extent that T AALS has restrained competition as described herein, T AALS members have been and are in competition among themselves and with other interpreters translators, precis writers, and other language specialists. PAR. 5. T AALS engages in substantial activities that further its members' pecuniary interests including, among other things: A. Advising members on operating translation and interpretation businesses;

B. Promoting members ' interpretation and translation businesses by distributing an annual directory of member translators and interpreters to members and consumers;

C. Providing referrals of members to consumers seeking language services;

D. Promulgating work rules and fee schedules; and E. Vouching for the qualifications of its members by maintaining rigorous membership requirements including sponsorship by current members.

PAR. 6. By virtue of its purposes and activities, T AALS is a corporation within the meaning of Section 4 of the Federal Trade Commission Act, 15 U.sc. 44.

PAR. 7. T AALS' acts and practices, including the able and practices alleged herein, are in or affect commerce, as "commerce is defined in the Federal Trade Commission Act. PAR. 8. The TAALS General Assembly is TAALS' supremc decision making body. It consists of all T AALS members and meets Complaint 118 F. annually. The General Assembly makes decisions by vote of members at meetings, with absent members voting by proxy. PAR. 9. T AALS maintains a set of Work Rules contained in the "T AALS Professional Code for Language Specialists " the Appendix to the Professional Code for Language Specialists " the Working Conditions for Interpreters Working Conditions for Translators " and "Working Conditions for Precis Writers." The T AALS Work Rules are binding on members everywhere and require T AALS members to refuse to work under conditions not in accordance with those laid down by the association. Members sign a pledge to abide by the Work Rules when they join TAALS. PAR. 10. The TAALS Work Rules were drawn up and adopted by TAALS members at General Assembly meetings. PAR. I I. T AALS members are required to obtain a waiver from T AALS before deviating from the Work Rules. T AALS members can be expelled from the association for violating the Work Rules absent a waiver.

PAR. 12. TAALS enforces member compliance with the Work Rules through the T AALS "Committee to Ensure Respect for the Code," which investigates alleged infractions of the Work Rules and recommends penalties, including expulsion from T AALS, for such infractions. The General Assembly imposes penalties based on the recommendation of the Committee to Ensure Respect for the Code. COUNT I PAR. 13. Each of the allegations in paragraphs one through twelve herein are incorporated in this Count I as though set forth in full.

PAR. 14. Since at least 1973 , TAALS has periodically created and distributed fee schedules entitled "Reports of Fees Currently Being Paid in the Americas" (hereafter "Fee Reports ). The T AALS Fee Reports list minimum fees for interpretation and translation services sold to private sector purchasers. PAR. IS. The private sector interpretation fees listed in the Fee Reports were adopted by vote of the T AALS general membership at General Assembly meetings. T AALS requires its members to refrain from accepting private sector fees below those specified in the Fee Reports.

THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS 425 422 Complaint PAR. 16. The T AALS Work Rules prescribe identical compensation for interpreters working on the same interpretation team and performing the same function regardless of differences in interpreters ' experience, skil, or other characteristics. PAR. 17. The TAALS Work Rules deter members from providing services free of charge by requiring that in such cases members must pay their own travel and subsistence expenses. PAR. 18. The TAALS Work Rules require members to calculate conference interpretation fees on an indivisible full-day basis regardless of the duration of the actual assignment during the day. PAR. 19. The T AALS Work Rules require members to charge an additional fee when they lead an interpretation team. PAR. 20. The T AALS Work Rules require members to charge 160 percent of the minimum fee when interpreting alone. PAR. 21. The T AALS Work Rules prescribe mandatory minimum standards for:

A. Transportation to and from conferences at which members work, including class of air travel and excess baggage allowance for air travel;

B. The quality of lodging at conferences at which members work;

C. The amount and type of subsistence expense allowances for conferences at which members work;

D. The rate of compensation for travel time, briefing time, and other time not worked; and E. The amount and applicability of cancellation fees. The Work Rules prohibit members from accepting engagements on terms inferior to those prescribed.

PAR. 22. TAALS promulgates the Fee Reports and the Work Rules for the purpose and with the intended effect of raising and sustaining the general level of fees and other compensation paid to interpreters, translators, precis writers, and other language specialists in the United States so that interpreters, translators, precis writers and other language specialists ean earn more money and greater profi ts.

PAR. 23. T AALS members and other interpreters, translators and precis writers use the Fee Reports and Work Rules when setting their own fees and other compensation.

Complaint 118 F.Te. PAR. 24. Respondent TAALS has been and is acting as a combination of its members or in conspiracy with its members and others, to restrain price competition, to fix or stabilize fees, and to prevent discounting of fees in the provision of interpretation translation, precis writing, and other language services. PAR. 25. The combination or conspiracy and TAALS' acts or practices described above constitute price fixing, whose purpose and effects have been and are to restrain competition unreasonably and to injure consumers by, among other ways, depriving consumers of the benefits of competition on fees among interpreters, translators, precis writers, and other language specialists in the provision of interpretation, translation, precis writing, and other language services. PAR. 26. The acts and practices herein alleged were and are to the prejudice and injury of the public, will continue in the absence of the relief herein requested, and constitute unfair methods of competition in or affecting commerce in violation of Section 5 of the Federal Trade Commission Act.

COUNT II PAR. 27. Each of the allegations in paragraphs one through twelve herein are incorporated in this Count II as though set forth in full.

PAR. 28. The TAALS Work Rules require members to declare a single professional domicile and prohibit members from changing professional domiciles more than twice per year. The T AALS Work Rules also require that travel expenses to a job be charged based on a member s professional domicile, regardless of the member s actual location and even if no travel was actually involved. The Work Rules further require all members to notify T AALS of all professional domicile changes at least sixty days in advance. These domicile restrictions, in conjunction with the minimum standards for travel reimbursement alleged in paragraph twenty-one, reduce price competition on travel charges and deprive consumers of the benefits of reduced charges based on a translator s actual geographic proximity to a job.

PAR. 29. The TAALS Work Rules prescribe mandatory standards for:

THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS 427 422 Decision and Order A. The maximum hours worked per day and per shift by interpreters, translators, and precis writers; B. The composition of interpreting teams, including the minimum number of interpreters per language spoken at a conference and the designation of a team leader; and C. The minimum number of precis writers per conference team. The Work Rules prohibit members from accepting engagements on tenns inferior to those prescribed.

PAR. 30. The TAALS Work Rules prohibit members from engaging in all fonns of personal publicity, including advertising. PAR. 31. TAALS has established rules limiting its members use of portable electronic simultaneous interpretation equipment. PAR. 32. By enacting and enforcing the Work Rules, respondent T AALS has been and is acting as a combination of its members or in conspiracy with its members and others, to restrain competition by attempting to control the output and marketing of interpretation translation, precis writing, and other language services. PAR. 33. The combination or conspiracy and TAALS' acts or practices described above have had and continue to have the purpose and effect of restraining competition unreasonably and injuring consumers by, among other ways, depriving consumers of the benefits of competition among interpreters, translators, precis writers and other language specialists in the provision of interpretation translation, precis writing, and other language services. PAR. 34. The acts and practices herein alleged were and are to the prejudice and injury of the public, will continue in the absence of the relief herein requested, and constitute unfair methods of competition in or affecting commerce in violation of Section 5 of the Federal Trade Commission Act.

DECISION AND ORDER The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondent named in the caption hereof, and the respondent having been furnished thereafter with a copy of a draft of complaint which the Bureau of Competition proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondent with a violation of the Federal Trade Commission Act; and Dccision and Order 118 F.T.c. The respondent, its attorneys, and counsel for the Commission having thereafter executed an agreement containing a consent order an admission by the respondent of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an admission by respondent that the Jaw has been violated as alleged in such complaint, and waivers and other provisions as required by the Commission s Rules; and The Commission having considered the matter and having determined that it had reason to believe that the respondent has violated the said Act, and that a complaint should issue stating its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of sixty (60) days, and having duly considered the comments filed thereafter by interested persons pursuant to Section 34 of its Rules, now in further conformity with the procedure prescribed in Section 2.34 of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings and enters the following order:

I. Respondent T AALS is a corporation organized, existing and doing business under and by virtue of the laws of the District of Columbia, with its offices and principal place of business located at 1000 Connecticut Avenue, N. , Washington, D. 2. The Federal Trade Commssion has jurisdiction of the subject matter of this proceeding and of the respondent, and the proceeding is in the public interest.

ORDER It is ordered That for purposes of this order, the following defini tions shall apply:

Respondent or TAALS" mean The American Association of Language Specialists, its directors, trustees, general assemblies councils, committees, working groups, boards, divisions, chapters officers, representatives, delegates, agents, employees, successors and assigns.

THE AMERICAN ASSOCIATION OF LANGUAGE SPECIALISTS 429 422 Decision and Order Fees means any cash or non-cash charges, rates, prices, benefits or other compensation received or intended to be received for the rendering of interpretation, translation, or other language services including but not limited to, salaries, wages, transportation, lodging, meals, allowances (including subsistence and travel allowances), reimbursements for expenses, cancellation fees, compensation for time not worked, compensation for travel time and preparation or study time, cancellation fees, and payments in kind. Canceliationfee means any fee intended to compensate for the termination, cancellation or revocation of an understanding, contract agreement, offer, pledge, assurance, opportunity, or expectation of a job.

Interpretation means the act of expressing, in oral form, ideas in a language different from the language used in an original spoken statement.

Translation means the act of expressing, in written form, ideas in a language different from the language used in an original writing. Other language service means any service that has as an element the conversion of any form of expression from one language into another or any service incident to or related to interpretation or translation, including briefing or conference preparation, equipment rental, conference organizing, teleconferencing, precis writing, supervision or coordination of interpreters, reviewing or revising translations, or providing recordings of interpretations. Interpreter means one who practices interpretation. Translator means one who practices translation. Language specialist means one who practices interpretation translation, or any other language service. Unbiased" means lacking any systematic errors that would result from the selection or encouragement of one outcome or answer over others.

Person means any individual, partnership, association company, or corporation, and includes any tmstee, receiver, assignee lessee, or personal representative of any person herein defined. II.

It is further ordered That respondent, directly or indirectly, or through any person, corporation, or other device, in or in connection Decision and Order 118 F.Te. with its activities in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, cease and desist from: A. Creating, formulating, compiling, distributing, publishing, recommending, suggesting, encouraging adherence to, endorsing, or authorizing any list or schedule of fees for interpretation, translation or any other language service, including but not limited to fee guidelines, suggested fees, proposed fees, fee sheets, standard fees or recommended fees;

B. Entering into, adhering to, or maintaining any contract agreement, understanding, plan, program, combination, or conspiracy to construct, fix, stabilize, standardize, raise, maintain, or otherwise interfere with or restrict fees for interpretation, translation, or other language services;

C. Suggesting, urging, encouraging, recommending, or attempting to persuade in any way interpreters, translators, or other language specialists to charge, pay, offer, or adhere to any existing or proposed fee, or otherwise to charge or refrain from charging any particular fee;

D. For a period of ten (IO) years after the date this order becomes final, continuing a meeting of interpreters, translators, or other language specialists, after I) any person makes a statement, addressed to or audible to the body of the meeting, concerning the fees charged or proposed to be charged for interpretation, translation, or any other language service and T AALS fails to declare such statement to be out of order, 2) any person makes two such statements and TAALS fails to eject him or her from the meeting, or 3) two people make such statements;

E. Prohibiting, restricting, regulating, impeding, declaring unethical, interfering with, or advising against any form of price competition, including but not limited to offering to do work for less remuneration than a specific competitor, undercutting a competitor actual fec, offering to work for less than a customer s announced fee advertising discounted rates, or accepting any particular lodging or travel arrangements;

F. Advising against, restricting, or prohibiting interpreters translators, or other language specialists from accepting hourly fees half-day fees, weekly fees, or fees calculated or payable on other than a full-day basis;

THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS 43 I 422 Decision and Order G. Advising against, restricting, or prohibiting interpreters translators, or other language specialists from performing services free of charge or at a discount, or from paying their own travel lodging, meals, or other expenses; and H. Prohibiting, restricting, regulating, impeding, declaring unethical, interfering with, or advising against any fonns of personal publicity, including but not limited to advertising by inlerpreters translators, or other language specialists. Provided, that nothing contained in this paragraph II shall prohibit respondent from:

I. Compiling or distributing accurate aggregate historical market information concerning past fees actually charged in transactions completed no cartier than three (3) years after the date this order becomes final, provided that such information is compiled and presented in an unbiased and nondeceptive manner that maintains the anonymity of the parries to the transactions; 2. Collecting or publishing accurate and otherwise publicly available fees paid by governmental and intergovemmental agencies if such publication states the qualifications and requirements to be eligible to receive such fees;

3. Continuing a meeting following statements concerning historical, governmental, or intergovernmental fees that are made in order to underrake the activities pennitted in paragraphs 11.1 and II. of this order; or 4. Formulating, adopting, disseminating to its organizational subdivisions and to its members, and enforcing reasonable ethical guidelines governing the conduct of its members with respect to advertising, including unsubstantiated representations, that respondent reasonably believes would be false or deceptive within the meaning of Section 5 of the Federal Trade Commission Act. It isfurther ordered, That, respondent shall clearly and conspicuously state the following in any publication of fees made pursuant to paragraphs II. 1 and 11.2 of this order:

Decision and Order 118 F.T.e. BY ORDER OF THE FEDERAL TRADE COMMISSION, T AALS IS PROHIBITED FROM RECOMMENDING, SUGGESTING, OR ENFORCING FEES APPLICABLE IN THE UNITED STATES. UNDER UNITED STATES LAW, INTERPRETERS AND OTHER LANGUAGE SPECIALISTS MUST UNILATERALLY AND INDEPENDENTLY DETERMINE THEIR OWN FEES.

IV.

It is further ordered, That respondent, directly or indirectly, or through any person, corporation, or other device, in or in connection with its activities in or affecting commerce, as "commerce" is defined in the Federal Trade Commission Act, cease and desist from entering into, adhering to, or maintaining any contract, agreement, understanding, plan, program, combination, or conspiracy to: A. Limit, restrict, or mandate the Jength of time that interpreters, translators, or other language specialists work in a given period, or for which they are paid for preparation or study; B. Limit, restrict, or mandate the number of interpreters, translators, or other language specialists used for a given job or type of job; C. Limit, restrict, or mandate the reimbursement of or payment to interpreters, translators, or other language specialists for travel expenses or time spent traveling, or otherwise prevent consumers from receiving any advantages, based on interpreters, translators or other language specialists' actual travel arrangements or geographic location, by restricting, requiring declarations of, or regulating the number or duration of residences or domiciles of members or by other means; or D. Limit, restrict, or mandate the equipment used in performing interpretation, translation, or other language services. Provided, that nothing contained in paragraph IV of this order shall prohibit respondent from providing information or its nonbinding and the hours of noncoercive views concerning interpretation equipment, work or preparation, or the number of language specialists used for types of jobs.

THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS 433 422 Decision and Order It is further ordered That respondent shall, within thirty (30) days after the date this order becomes final, amend its Professional Code For Language Specialists and all appendices to conform to the requirements of paragraphs II and IV of this order and amend its bylaws to require each member, chapter, or other organizational subdivision, to observe the provisions of paragraphs II and IV of this order.

VI.

It is further ordered That respondent shall: A. Within thirty (30) days after the date this order becomes final distribute to each T AALS member, affiliate, chapter, organizational subdivision, or other entity associated directly or indirectly with TAALS, copies of: (I) this order, (2) the accompanying complaint (3) Appendix A to this order, (4) and any document that TAALS revises pursuant to this order; and B. For a period of ten years after the date this order becomes final, distribute to all new T AALS offcers, directors, and members, and any newly created affiliates, chapters, or other organizational subdivisions, within thirty days of their admission, election appointment, or creation, a copy of: (1) this order, (2) the accompanying complaint, (3) Appendix A to this order, and (4) any document that T AALS revises pursuant to this order. VII.

It is further ordered That respondent shall: A. Within ninety (90) days after the date this order becomes final, and annually for five (5) years thereafter on the anniversary of the date this order becomes final, file with the Secretary of the Federal Trade Commission a verified written report setting forth in detaij the manner and form in which respondent has complied and is complying with this order, and any instances in which respondent has taken any action within the scope of the provisos in paragraphs 11.1 11.2, 11., or II.4 of this order;

Decision and Order 118 F. B. For a period of five (5) years after the date this order becomes final, collect, maintain and make available to the Federal Trade Commission for inspection and copying: records adequate to describe in detail any action taken in connection with the activities covered in this order; all minutes, records, reports or tape recordings of meetings of the Council, General Assembly, and all committees, subcommittees, working groups, or any other organizational subdivisions of TAALS; and all TAALS mailings to the TAALS Councilor general membership;

C. For a period of five (5) years after the date this order becomes final, provide copies to the Federal Trade Commission, within thirty (30) days of its adoption, of the text of any amendment to the T AALS Bylaws, TAALS Professional Code for Language Specialists or Appendix thereto, Working Conditions for Interpreters, Working Conditions for Translators, Working Conditions for Precis-Writers and any new rules, regulations or guidelines of respondent; and D. Notify the Federal Trade Commission at least thirty (30) days prior to any proposed change in respondent, such as dissolution or reorganization of itself or any chapter, division, or of any proposed change resulting in the emergence of a successor corporation or association, or any other change in the corporation or association that may affect compliance obligations arising out of this order. By the Commission. I 1 Prior to leaving the Commission, former Commissioner Owen registered her vote in the affrmative for the Complaint and the Decision and Order in this matter. THE AMERICAN ASSOCIA non OF LANGUAGE SPECIALISTS 435 422 Decision and Order APPENDIX A (DATEJ ANNOUNCEMENT The American Association of Language Specialists ("T AALS" has entered into a consent agreement with the Federal Trade Commission. Pursuant to this consent agreement, the Commission issued an order on (DATE) that prohibits TAALS, including its chapters, committees, or organizational subdivisions, from: (1) Creating, distributing, authorizing, or endorsing any list or schedule of fees or other charges for interpretation, translation, or other language services;

(2) Entering into, or maintaining any agreement, plan, or program, to construct, fix, stabilize, raise, maintain, or otherwise interfere with fees or other charges for interpretation, translation, or other language services;

(3) Suggesting, recommending, or encouraging, in any way, that interpreters, translators, or other language specialists charge, adhere , or refrain from charging any existing or proposed fee; (4) For a period of ten (10) years after this order becomes final continuing a meeting after I) any person makes any statement to the body of the meeting concerning the fees charged or proposed to be charged for interpretation, translation, or any other language service and T AALS fails to declare such statement to be out of order, 2) any person makes two such statements and T AALS fails to eject him or her from the meeting, or 3) two people make such statements; (5) Prohibiting, restricting, regulating, or advising against any form of price competition among its members or other interpreters translators, or other language specialists, including undercutting a competitor s actual fee or a customer s announced fee, advertising discounted rates, or accepting any particular lodging or travel arrangements;

(6) Advising against, restricting, or prohibiting interpreters translators, or other language specialists from accepting hourly fees, weekly fees, or fees calculated or payable on other than a full-day basis;

, Decision and Order 118 F.Te. (7) Advising against, restricting, or prohibiting interpreters translators, or other language specialists from performing services free of charge or from paying their own travel, lodging, meals, or other expenses; or (8) Prohibiting, restricting, impeding, declaring unethical, or advising against any forms of personal publicity, including but not limited to advertising by interpreters, translators, or other language specialists.

In addition, the order prohibits TAALS from maintaining any agreement, understanding, plan or program to: (J) Limit, restrict, or mandate the length of time that interpreters, translators, or other language specialists work in a given period, or for which they are paid for preparation or study; (2) Limit, restrict, or mandate the number of interpreters, translators, or other language specialists used for a job or type of job; (3) Limit, restrict, or mandate the payment or reimbursement for travel or the travel time of interpreters, translators, or other language specialists, or otherwise prevent consumers from receiving any advantages, based on travel arrangements or geographic location, by regulating domiciles of members or by other means; or (4) Limit, restrict, or mandate the equipment used in performing interpretation, translation, or other language services. Under the order fees" are defined to include all cash or non-cash charges, rates, benefits, or other compensation for interpretation translation or other language services, including but not limited to, lodging, meals, subsistence and travel allowances, reimbursements for expenses, cancellation fees, and compensation for time not worked, travel lime or briefing time. "Language specialist" means one who performs "other language services " which are defined to refer to any services that involve the conversion of any form of expression from one language into another or any services incident to or related to interpretation and translation. Consequently, when the order mentions "language specialists " it includes anyone who rcnts equipment, organizes conferences, performs teleconferencing or precis writing, supervises or coordinates interprelers, reviews or revises translations, or provides recordings of interpretations. THE AMERICAN ASSOCIATION OF LANGUAGE SPECIALISTS 437 422 Decision and Order Further, under the order, T AALS must amend its professional code to conform to the requirements of paragraphs II and IV of the attached order, which are summarized above. T AALS must also amend its bylaws to require each member, chapter, and organizational subdivision to observe the requirements of the order. In addition, the order requires T AALS to provide to the Federal Trade Commission the text of each amendment to the TAALS Bylaws, Professional Code or Working Conditions, and the text of any new rules, regulations or guidelines.

We note, however, that the order does not prevent TAALS from adopting and enforcing reasonable ethical guidelines prohibiting advertising that would be false or deceptive within the meaning of Section 5 of the Federal Trade Commission Act. In addition, T AALS will be permitted to compile and dislribute accurate aggregate historical market infonnation concerning past fees that were actually charged no earlier than three years after this order becomes final, if presented in an unbiased and nondeeeptive manner that maintains the anonymity of the parties to the transactions underlying such reports. Similarly, the order does not prohibit TAALS from collecting and publishing accurate, puhlicly available information on fees paid by governmental and intergovernmental agencies if such publication states the qualifications and requirements for such fees. With any publication of fees permitted by the order, T AALS must include a statement that it is prohibited from recommending fees applicable in the United States and that interpreters must indepcndently determine their own fees. In addition, the order states that it does not prohibit TAALS from providing information or its nonbinding and noncoercive views concerning interpretation equipment, the hours of work or preparation, or the number of language specialists used for a type of job.

For more specific information, members should refer to the order itself, which is enclosed.

Counsel American Association of Language Specialists Complaint 118 F.Te.