The Federal Trade Commission’s proposed click to cancel rule amendments would impose a one-time cost of $2.7 billion on businesses and have an annual effect on the national economy of at least $100 million, whether considering the amendments’ cost or benefits, according to an economic report the online advertising industry’s association presented to the FTC Wednesday.

The $100 million threshold is significant because it would require the FTC to conduct and submit a cost-benefit analysis of its proposal to the Office of Management and Budget for review. The Interactive Advertising Bureau, which submitted the economic analysis, opposes the proposed amendments.