The Federal Trade Commission (FTC) promotes consumer protection and enforces laws related to fair competition. Its main purpose is to prevent deceptive, unfair, and anticompetitive business practices, such as false advertising, monopolies, and fraud. The FTC investigates complaints, enforces antitrust laws, and ensures that markets remain competitive and consumers are not misled or harmed by unfair business practices. Additionally, the FTC helps educate consumers and businesses about their rights and responsibilities in the marketplace.

Candeub begins by giving an overview of the history of antitrust laws, which I’ll skip here.

“Beyond antitrust injury, we are witnessing in today’s markets the use of economic power—often market and perhaps even monopoly power—to undermine democratic institutions and civil society. Practices such as Environmental, Social, and Governance (ESG) requirements on publicly traded corporations and their inclusion in business agreements, the so-called “de-banking” of industries and individuals, and the interference of large internet firms with democratic political discourse undermine liberal democracy, a truly open society, and, indeed, rule of law. Without rule of law, markets themselves will wither.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 903, paragraph 2.)

Candeub is arguing here that corporations are using their economic power in ways that could threaten democracy itself, but fails to give any examples of what he’s talking about. He criticizes the use of ESG criteria, which are standards for measuring a company’s environmental impact, social responsibility, and governance practices. He suggests that when these requirements are imposed on corporations, they can interfere with free markets and limit business decisions.

“De-banking” refers to the practice of financial institutions refusing to offer services to certain industries or individuals. He gives no examples of this, either.

Candeub also refers to the influence of big tech companies in shaping or moderating political discourse, seeming to argue that when these companies control or influence public debate, it can harm democratic processes and civil liberties.

He concludes by warning that these practices, if unchecked, could erode the fundamental principles of liberal democracy (such as free speech, open markets, and equal access) and the rule of law. In his view, without a stable legal framework that applies fairly to everyone, markets themselves will suffer, potentially leading to economic instability.

I couldn’t find a single example of a U.S. Bank “De-banking” an entire industry, and the cited examples of individuals being “de-banked” occurred mostly in Canada and the U.K.

Candeub then quotes Milton Friedman’s essay, “The Social Responsibility of Business is to Increase Its Profits.”

Given that, Candeub appears to be arguing for allowing businesses to forego any other forms of social responsibility, especially those that cut into their profits (such as adhering to environmental regulations.)

“Business managers appropriate shareholder wealth when they use corporate resources to further their personal political beliefs, even when pursuing what they consider a “socially responsible” or “moral” agenda. The business of American business is business, not ideology.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 903, paragraph 5.)

I don’t buy this argument. Nobody forces shareholders to invest in one company or another. If you disagree with one company’s philosophy, you don’t have to give them money. It’s called voting with your wallet.

Business ethicists call this the “separation fallacy” – the idea that business can be separated from ethics (they argue that it can’t.) I could definitely make an argument that business practices which are harmful to the environment or to consumers in the name of profit are unethical. At heart, humans are social creatures. Most of us don’t want to have relationships with – or do business with – people that we perceive as unethical.

“The continued emergence of evidence documenting collusion—between the Big Tech internet platforms and the Biden White House and administrative agencies—to censor criticism, scientific fact, and uncomfortable political truths demonstrates this unfortunate development.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 904, paragraph 2.)

He again gives no examples of what he’s talking about here, and as I pointed out in Section 4.1¹, the Supreme Court threw out a lawsuit that would have restricted communicating with internet giants over what it saw as “misinformation”, because the Republican-led states and social media users who filed the lawsuit couldn’t prove their case. The majority opinion was written by conservative Justice Amy Coney Barrett.

During a GOP Congressional Hearing about this, the GOP accidentally debunked their own claims – it was the Trump White House, not Biden’s, who has tried to censor social media:

“If the Oversight Committee hearing was supposed to prove the claims in the Twitter Files to be true and showcase Twitter’s alleged bias against conservatives, it couldn’t have gone any worse for the new Republican majority. The hearing, titled “Protecting Speech from Government Interference and Social Media Bias, Part 1: Twitter’s Role in Suppressing the Biden Laptop Story,” backfired in spectacular fashion, revealing that Republicans — including Trump himself — have been quietly trying to get Twitter to suppress criticism of them.” [Source]²

On to Candeub’s suggested reforms:

“Congress should investigate ESG practices as a cover for anticompetitive activity and possible unfair trade practices.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 905, paragraph 5.)

Candeub gives no possible examples of how companies could use ESG practices to limit competition or violate fair trade laws. He suggests above that such a practice could include “de-banking”, but I found no real-world examples of this happening in the United States.

“Managers who insert their own values into underwriting agreements, contracts for professional services, or other business transactions coopt shareholder value for their own personal utility.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 906, paragraph 3.)

Another argument for the separation of business from ethics.

“As a corollary, businesses that make general offers of service to the public forego profits by refusing to service a lawful activity, i.e., fossil fuel extraction or gun manufacturing, raising similar concerns. When banks or internet platforms refuse customers based on their political or social views (as distinguished from religious views), they forgo profits.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 906, paragraph 4.)

Candeub is arguing here that businesses, particularly banks or internet platforms, may be foregoing profits and potentially engaging in discriminatory practices by refusing to provide services to lawful industries like fossil fuel extraction or gun manufacturing based on political or social views. The concern is that such refusals could undermine market fairness and raise ethical issues, as these businesses are selectively excluding certain activities or customers, not on legal grounds but on ideological ones, which may conflict with principles of free commerce.

Again, no examples are provided of either a bank or an internet platform refusing service to an entire industry. The bigger question is, can private businesses operate as they see fit, or can’t they? The right to refuse service is well-established. Is 7-11 “discriminating against” people who have objections to wearing shirts and shoes? No. It’s “No shirt, no shoes, no service.” Restaurants often post publicly that they have the right to refuse service to anyone for any reason. The authors of Project 2025 are a bit all over the place on this point. You can’t champion the idea that businesses should operate independently of most government regulation, then turn around and regulate who they’re allowed to do business with or the social and ethical practices they wish to follow.

I will point out here that it’s not that Candeub simply isn’t in the habit of providing examples. Every single time he brings up social media censorship, he cites the erroneous and debunked idea that the Biden Administration attempted to censor political views on Facebook and Twitter. This leads me to believe that since he hasn’t provided examples of the other things he’s claiming are problems, it’s because no such examples of these problems exist; debunked or no.

“The FTC should examine platforms’ advertising and contract-making with children as a deceptive or unfair trade practice, perhaps requiring written parental consent.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 907, paragraph 3.)

This is an argument that minors shouldn’t be allowed on social media without parental consent. This would be difficult to enforce. He goes on to argue the COPPA (Chld Online Privacy Protection Act) only protects children under the age of 13, so he really does mean all minors under 18 should require parental consent for social media.

I don’t disagree in principle that social media can be harmful to children and teenagers, but this feels like a parenting issue to me – if that’s the way you feel, don’t allow your children to be on social media. This is not to say I disagree with protecting children online. Quite the opposite. But an ounce of prevention, as they say.

“In addition, some of the methods used to regulate children’s internet access pose the risk of unintended harms. For instance, age verification regulations would inevitably increase the amount of data collection involved, increasing privacy concerns. Users would have to submit to platforms proof of their age, which raises the risks of data breach or illegitimate data usage by the platforms or bad actors.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 908, paragraph 2.)

I agree that collecting age is useless (because it’s too easy to lie unless you’re requiring a legal ID, which is definitely a privacy concern), but this is a problem looking for a solution. Has any bad actor EVER breached a social media company’s database for the sole purpose of victimizing children, which would have been prevented by them not sharing their age?

“Second, while consumers may report that they like social media, hedonics tells a different story, suggesting that social media and other online activities diminish human happiness. This evidence, while mixed at first, appears to have become quite solid: Social media makes Americans less happy.” (Project 2025, Section 5.4: Federal Trade Commission, Adam Candeub, page 909, paragraph 6.)

Since he’s not really making any kind of argument or suggestion, I’ll chalk this up as an interesting observation. It’s a shame Candeub doesn’t believe in business ethics, or he could make an argument for real public harm, here.