The privacy code of conduct developed by the National Telecommunications and Information Administration (NTIA) multistakeholder process will apply to many more consumers and firms than can be directly involved in the process. Therefore, code provisions should be analyzed in much the same way as a regulation in order to assure that they produce benefits in excess of costs. By adopting a process for cost-benefit analysis, the agency can ensure the interests of all stakeholders, including present and future Internet users, are represented.