Federal Trade Commission Announcements

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FTC Investigation: Mobile Money Code

The Mobile Money Code scam was highlighted about in multiple press releases from Federal Trade Commission, as the FTC filed a case against all those involved in the scam in the U.S. District Court for the Middle District of Florida. Initial investigations highlighted that the alleged marketers, who were using a "get-rich-quick-scheme," were deceiving potential customers and were violating multiple advertising and spamming prohibition laws.

The Mobile Money Code Scam

  • On December 28, 2017, the FTC released an official press release describing the case and the allegations against the individuals and the companies involved in the Mobile Money Code fraud.
  • "The Commission alleged that Ronnie Montano, Hyong Su Kim (also known as Jimmy Kim), Martin Schranz and their related companies bilked consumers out of millions of dollars by falsely promising they could earn hundreds to thousands of dollars a day using the defendants' Mobile Money Code products; however, in reality, the Mobile Money Code products were generic software applications that could help the user make mobile-friendly websites."
  • In addition to the allegations mentioned above, the FTC also accused the defendants of violating the FTC Act's prohibition against deceptive practices and the CAN-SPAM Act. These acts have mandated that "commercial e-mails must contain an accurate header and relevant and specific subject lines, they must identify itself as an ad and include a valid physical address, and offer recipients a way to opt-out of future messages."

Allegations Against the Companies

  • Specific allegations include spam mails by affiliate marketers, high pressure up selling, false promises about the earnings, deceptive claims, fake and paid testimonials about the products. Moreover, the defendants also dishonored their "60-day hassle-free money-back guarantee" by making it extremely difficult and next to impossible for the customers to take any refund from the alleged money code websites.
  • Additionally, the defendants' websites also have allegedly blocked consumers who wanted to opt-out of the website by using multiple pops up messages. "Consumers who agreed to make an initial purchase were asked to make additional purchases through upsells and add-ons." The companies were charged with commercial impropriety.

FTC Warnings

  • Consumers, companies, and affiliate marketers have been warned about false promises and deceptive claims about products. A blog article on the FTC website offered insights on how consumers can avoid such frauds, which primarily included tips like "do not trust easy gain offers," and "less detailed and vague product descriptions are suspicious."
  • Companies are required to keep a check on the kind of advertising their affiliate marketers are doing on their behalf, and affiliate marketers are advised to be very careful about their advertisement claims. Regarding the Can-Spam act violations, both the company and the affiliate marketer will be held responsible.


  • Final settlements from the case included a $7 million judgment; however, this judgment will be suspended upon payment of a total of $698,500. The final amount will be used for refunding consumers who were caught up in the defendants' scheme.
  • "The defendants also are prohibited from marketing or selling money-making software, from making misrepresentations in the promotion, marketing, or sale of any good or service, from violating the CAN-SPAM Act, and from using any consumer information they collected."
  • The refunds have arisen from a settlement with the operators of the Mobile Money Code scheme; other names used by the operators included eMobile Code, Auto Mobile Code, Easy Cash Code, Full Money System, and Secret Money System.
  • There were a total of three press releases from FTC about the case and two blog posts about the same. The first-ever press release was made on December 28, 2017; the second one was released in the month of June 2018, and the final one about the refunds was released on March 11, 2019.
  • "The Commission vote approving the stipulated final orders for the settlement was by 5-0, and proposed orders were filed in the U.S. District Court for the Middle District of Florida, Orlando Division."

Media Releases

  • No media coverage about the case was made by any of the top tier media houses; however, some local media publications, including Orlando Sentinel, have covered the fraud case. Other than the FTC itself, only a few law firms have published information about this case.
  • The news article by Orlando Sentinel was a mere copy of the official press release and included the same level of details as the official press release by FTC.

Social Media Reaction

  • The accused companies do not have any verified social media accounts; for instance, GSD Master AG does not have any social media accounts, and no press releases or mentions were found about the case.
  • Verified social media accounts of the defendants were unavailable mainly due to the fact that there are multiple companies with the same names, and the details about these companies, which were found in the case files of the Mobile Money Codes case, do not match any of the available social media profiles.
  • FTC also has posted on Facebook about the case, one post was found on the official Facebook account of the Federal Trade Commission, and the post was about the refunds that were made in the case by the FTC.

Research Strategy

To provide a robust overview of the FTC investigation on the Mobile Money Code case, we searched through a variety of sources, which included top tier news publications, FTC database, court briefs from the Federal Court of Middle District of Florida, company databases and social media resources. However, the investigated companies, including JK Marketing LLC and Montano Enterprises LLC, do not have an official website available in the public domain, and so press releases from these companies about the case could not be located. While GSD Master AG, which is also one of the investigated companies, has an official website, it still does not offer any official social media accounts or any press releases or any relevant mentions about the case in particular.

Since the official websites were unavailable, we opted to search for media statements from the owners of these companies, which include Ronnie Montano, Jimmy Kim, and Martin Schranz. For this, we searched through both the top tier publications (like Reuters, WSJ, CNN, Time, The New York Times) and local publications in Orlando, Nevada, and New York (locations where the company is based). However, no official statements were found from any of the owners about the company or the case.

To obtain additional information about these companies such as the executives, who could have possibly provided an official statement about the company's involvement in the case, we searched through company databases such as Hoover D&B, Pitchbook, Manta, Zoominfo; however, none of these had any verified profiles of these companies.

We also searched through Instagram and Facebook to find any company profiles that match the profile details of the companies alleged in the case. While we found multiple companies with the same names, none of the profiles matched any of the details provided in the court briefs about the alleged companies.
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FTC Investigation: University of Phoenix

Federal Trade Commission investigation findings of the adverts made by the University of Phoenix between 2012 and 2014 were found to be deceptive. It attracted a settlement of $191 million.

Overview of the Allegations/FTC Warnings to Customers

  • The University of Phoenix (UOP) was alleged to have falsely advertised that they work hand-in-hand with reputable companies to provide jobs for students of the institution. The university also made a false claim that these companies were also instrumental to the development of the institution's course curriculum.
  • Federal Trade Commission (FTC) noted that the false claims were made between 2012 and 2014, and the companies the university mentioned in their advertisements that they partner with include Adobe, Microsoft, Yahoo, and American Red Cross.
  • Four campaigns with false claims were identified namely: Let’s Get To Work, Parking Lot, Train Stops and Hall of Success advertisement campaigns.
  • The university also made radio and internet claims in 2013 that certain companies worked with the institution to develop their curriculum because they are interested in employing the University of Phoenix's students.
  • FTC has warned students to do proper findings and inquiries about their prospective educational institutions of choice. The website of the US department of education's college navigator has been recommended because it provides basic details about educational institutions. In addition, prospective students should do an online review of their schools of interest.

How FTC's Findings were Announced/Result of Their Findings and Settlement

  • Federal Trade Commission released a press statement on December 10, 2019, and this release contained the findings of the allegations.
  • The findings revealed that the companies the University of Phoenix claimed to work with never had any form of partnership with the institution, with regard to creating job opportunities or development of training curriculum.
  • FTC used their Facebook, LinkedIn, and Twitter accounts to further announce the charges made against the University of Phoenix via one of their posts on these media platforms on the 10th of December, 2019.
  • The University of Phoenix was sanctioned with a settlement of $191 million because of the false advertisements made. UOP has to pay $50 million cash to FTC (this will be distributed to former students for compensation) and also forgive $141 million debts owed by the students who first enrolled in the school between October 1, 2012, and December 31, 2016.

Media and Public Reaction

  • The Federal Trade Commission's announcement received attraction from top media outlets such as the New York Times, WSJ, Forbes, Reuters and the Washington Post.
  • These media outlets gave an overview of the deceptive ad campaigns and described the settlements to be paid by the University of Phoenix. It was noted that the school started the campaigns when its students' enrollment started dwindling as a result of increased competition.
  • The campaigns were said to have occurred and completed during under the previous leadership of the university before FTC started its investigation. While some of the advertisements were aimed at Hispanic and military students, Andrew Smith (director of the FTC’s Bureau of Consumer Protection) has said that the settlement made by the school is the largest gotten so far by the commission in cases made against for-profit institutions.
  • The coverage around the announcements was only during the week they were made on Twitter. Most of the comments were focused on the fact that loan forgiveness does not apply to federal government loans.

University of Phoenix's Response to the Announcement

  • The University of Phoenix responded to the announcement by FTC by releasing a press statement on December 10, 2019. The University maintained that the campaigns were appropriate, but had to agree with the settlement to focus on its mission. In addition, questions and answers were also provided about the announcements on the University's website.
  • The school also posted information about the announcement on their Facebook and Twitter accounts.

Research Strategy

We started the research by looking at the websites of The University of Phoenix and Federal Trade Commission. We were able to get most of the required information by looking at the news and press release sections of these websites. We then expanded the search by looking at media articles to know the media attention drawn by the announcement by FTC. We searched Forbes, Washington Post and the New York Times. We further searched the social media pages of the Federal Trade Commission and the University of Phoenix to determine the public reaction to the announcements. We had to get creative and determined the predominant reaction by the most recurring comment type after reading the reply sections of the social media posts.

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FTC Investigation: Match.com

The Federal Trade Commission filed a complaint against Match Group, Inc., the company behind the dating website Match.com, for allegedly using unfair practices to trick users into purchasing a subscription and keeping the subscription. The case is still pending in federal court in Northern District Texas. This announcement by the FTC has received coverage from major mainstream media outlets, such as The Washington Post, Forbes, and The New York Times, among others. Below are more details about the FTC investigation and announcements against Match Group, Inc.

Investigation Overview

  • The Federal Trade Commission (FTC) sued Match Group, Inc., the company that owns the dating site Match.com, in an allegation that Match.com had been operating using five deceptive or unfair practices to trick consumers into purchasing a Match.com subscription and keeping their subscriptions.

FTC's Announcement of the Findings

  • The FTC released a press release regarding its complaint against Match Group, Inc. in English and Spanish on September 25, 2019. These press releases were published together with a consumer and business blog posts regarding Match.com and romance scams in general.
  • The case is still pending in federal court in Northern District of Texas, and the docket report of the case can be accessed here.

Description of the Findings

  • According to the complaint, between 2013 until mid-2018, the defendant sent fake love interest advertisements to non-subscribers, making them believe that someone was interested in establishing a dating relationship with them. However, only paid subscribers were able to send other users personalized emails and instant messages and view the profiles of users who sent them any form of interest. Nonsubscribers, on the other hand, could only send limited communications, such as "likes," "favorites," and "winks." Nonsubscribers could not also see the identities of the users who interacted with them through likes, favorites, or winks. The defendant sent advertisements to non-subscribers, notifying them of these "interests" and encouraging them to upgrade their subscriptions so they can view and respond to these communications. As a result, nonsubscribers often purchased a Match.com subscription so they can communicate with users who have expressed interest in them.
  • The FTC said that Match.com consumers who were considering purchasing a subscription were generally not aware that 25 to 30 percent of the Match.com registrations each day were from people using the platform to perpetrate different kinds of scams, such as stealing personal information through phishing, romance scams, extortion scams, and promoting dubious or unlawful products or services.
  • The complaint also stated that the website promised subscribers to a free six-month subscription renewal if they did not "meet someone special." However, FTC alleged that Match failed to adequately disclose the requirements that consumers must meet to qualify for the "guarantee." However, their "Learn More" link to the "guarantee" contains "a dense block of text listing the many strings Match attached to that guarantee," resulting in many consumers being charged for another six-month subscription when they expected it to be free.
  • Due to the deceptive advertising and billing, subscribers often disputed charges. The complaint alleged that despite unsuccessfully disputing the charges and paying for the services, the website banned these users from accessing the services.
  • Lastly, the FTC said that the website violated the Restore Online Shoppers’ Confidence Act (ROSCA) by not providing a simple method to its consumers to stop recurring charges from being placed on their cards or bank accounts. The FTC said that the cancellation process was complex and confusing, ultimately preventing their consumers from canceling their subscriptions. The FTC stated that Match's own employees described the process as "hard to find, tedious, and confusing," leading to some subscribers believing that they have already canceled their subscription when they have not.

Media and Public Reaction

  • The FTC announcement against Match.com received coverage by top-tier mainstream media outlets, like Reuters, The Washington Post, CNN, Forbes, and the New York Times.
  • The coverage mainly talked about Match.com or Match Group using deceptive or unfair practices to entice nonsubscribers to purchase a subscription. The coverage also noted how much Match Group's stock went down when the FTC announcement was made. Some said it went down 5 percent, some said 7 percent, and some said 8 percent.
  • In these news articles, the director of the FTC's Bureau of Consumer Protection, Andrew Smith, was often quoted, saying, "We believe that Match.com conned people into paying for subscriptions via messages the company knew were from scammers."
  • An unnamed Match Group spokesperson was also quoted, saying "Fraud isn't good for business. We catch and neutralize 85% of potentially improper accounts in the first four hours, typically before they are even active on the site, and 96% of improper accounts within a day."
  • The announcement also received several attention from social media, especially from Twitter, with many people tweeting and retweeting the news articles about the complaint. Even if the complaint was filed in September last year, there were still several recent tweets about the case, with the latest one on January 27, 2020.

How Match.com Responded to the Announcement

  • In a response to the FTC filing, Match issued a statement on its Media Room on its website, stating "For nearly 25 years Match has been focused on helping people find love, and fighting the criminals that try to take advantage of users. We’ve developed industry-leading tools and AI that block 96% of bots and fake accounts from our site within a day and are relentless in our pursuit to rid our site of these malicious accounts. The FTC has misrepresented internal emails and relied on cherry-picked data to make outrageous claims and we intend to vigorously defend ourselves against these claims in court."
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FTC Investigation: Zurixx

The Federal Trade Commission (FTC) accused Zurixx of making false promises to consumers. Specifically, the FTC claimed that Zurixx lured consumers into participating in real estate seminars and claiming it would teach the attendees ways to quickly get rich through real estate. Due to the allegation, a federal high court placed a temporary restriction on Zurixx and its associate companies' businesses.

FTC Allegations on Zurixx

  • The FTC alleged that Zurixx "markets and sells a flipping system that says it lets people generate substantial income by flipping houses."
  • It claimed that Zurixx representatives displayed stories that portray the success of those who have enrolled in their real estate business classes on TV ads endorsed by celebrities.
  • In the FTC complaint against Zurixx, it noted that the class attendees were promised that they would learn how to make money from the real estate business at the expense of others.
  • The FTC found that Zurixx promoted a "free event that was, instead, a sales presentation for its three-day workshops that cost $1,997." It also discovered that the company forced some consumers they refunded to sign an agreement not to communicate with the FTC, attorney general, the Better Business Bureau, or post negative reviews about Zurixx.
  • Another important accusation from the FTC is that Zurixx deceived the seminar attendees and asked them to get a new credit card or increase the credit limit in their old cards, which would enable them to place deals for real estate. Unfortunately, "in many instances, Zurixx will tell people to use this new credit to pay for its “advanced training” packages costing about $41,000."
  • After investigating Zurixx's activities, the FTC described the company's activities as "deceptive."
  • The FTC settled this by taking Zurixx to court. On October 4, 2019, a federal court issued a temporary restriction to Zurixx's activities.
  • The court also banned Zurrix from "making unsupported marketing claims and from interfering with consumers’ ability to review Zurixx and its products."
  • The court also ordered that Zurixx's assets should be monitored and reserved by David K. Broadbent. Due to this, Zurixx cannot withdraw or sell its money or assets without authorization by Broadbent.

Announcement of Their Findings

  • The FTC published one press release about its findings on October 4, 2019, after a court order was issued.
  • They also made a second publication on their blog on October 10, 2019, where an FTC correspondent explained the allegations against Zurixx in detail.

Announcement Coverage

Zurixx Response to The FTC Announcements

  • On November 1, 2019, Zurixx posted information on the restriction ordered by the court on its website and announced that both Zurixx and associate companies will no longer be doing business.
  • In the post, it mentioned that the court had placed Zurixx and its entities into receivership and named David K. Broadbent as the receiver. They further advised customers who purchase goods and services from them using credit cards to contact their credit card providers for any remedies regarding the recent court order.

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FTC Investigation: Response

On November 5, 2019, the FTC filed a claim against Utah company Nudge LLC (and its affiliates) alleging unethical advertising and business practices promising consumers specialized, expensive real estate training will result in big profits from real estate projects. A month later, a federal court issued a preliminary injunction against Nudge, and the case is pending its final ruling.

Overview of Allegations and What FTC Warned Consumers About

  • The FTC partnered with Utah Division of Consumer Protection responding to claims by a company, Nudge LLC, promising people that they could earn money by 'flipping' houses.
  • Two affiliates of Nudge were also included in the suit: Response Marketing Group, LLC and BuyPD, LLC.
  • Nudge was selling real estate training programs promising consumers that with their training, they would see "proven" results in real estate investing.
  • Nudge used celebrity endorsements in its advertising to imply that the same level of wealth could be achieved with Nudge's training.
  • Additionally, Nudge also promised consumers purchasing its advanced training programs access to properties being sold at discounted prices, when in fact the properties were being brokered at inflated rates.
  • The FTC claims that 95% of Nudge's customers spent more on the company's training than they earned in real estate profits.
  • The suit claims that Nudge has violated these statutes: FTC Act, FTC’s Telemarketing Sales Rule, the Utah Consumer Sales Practices Act; the Business Opportunity Disclosure Act; and the Telephone Fraud Prevention Act.

How Announced Findings & Results

  • The initial case was filed on November 5, 2019. The FTC asked for federal courts to stop Nudge from doing business, freeze their assets, assign fines and order restitution for frauded customers. The announcement was made via a press release on the FTC website and a quote released from the FTC Bureau of Consumer Protection.
  • The only other update to the case, to date, came on December 18, 2019, when the court issued its preliminary findings. It restricted Nudge from effectively doing business, taking in any more money, declaring bankruptcy or insolvency and other legal actions. It also froze all company assets. This preliminary order is to stay in effect until a final judgment is issued.

Coverage of FTC Announcement (Including Who Quoted)

  • The suit received limited national and local coverage, warning consumers against this and similar programs. The articles quote FTC Bureau of Consumer Protection director Andrew Smith and Nudge attorney Jeffrey Knowles.

Social Media Reaction

  • The case did not receive much attention on social media, either from consumers or the industry. One tweet regarding the announcement was found (and it received no engagement).
  • The FTC's tweet about the case received 2 comments, 9 retweets and 12 likes.
  • Most Facebook posts about the topic are from local news websites merely posting their coverage of the case. Comments from the public on these posts are centered around lack of sympathy for consumers who paid for the training.

How Investigated Companies Responded

  • When the suit was announced, Nudge's attorney Jeffrey Knowles told the media: "The FTC’s groundless lawsuit and overreaching rush to shut down a legitimate company operating lawfully for many years are grossly unfair and do not reflect reality...They will fight these allegations and look forward to telling their side of the story and setting the record straight."
  • No other public responses could be found on Nudge or its affiliates' websites or social media pages.
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FTC Investigation: Apex Capital Group

The Federal Trade Commission (FTC) accused Apex Capital Group, LLC, and two of its executives of engaging in unfair practices in an alleged international internet marketing scam, acting in violation of Section 5 of the FTC Act and the Online Shoppers' Confidence Act (ROSCA). Other details about the coverage and announcement of findings of the FTC's investigation are outlined in the following section.

Overview of FTC's Allegations

  • The Federal Trade Commission (FTC), in its filed complaint, accused Apex Capital Group, LLC, of setting up illegal shell companies both in the US and UK, using them as cover-ups to open merchant accounts.
  • According to FTC, "those merchant accounts allegedly were used to process millions of dollars in consumer payments for the defendants' products, allowing the defendants to avoid detection by the credit card networks and law enforcement for several years."
  • The Commission accused the defendants running the operation, Phillip Piekos and David Barnett, of duping the public and conducting online subscriptions since early 2014. Over the period, they illegally marketed and sold about 50 different products to consumers.
  • The products were supposedly "free trials" of personal care products and dietary supplements. They claimed that these products help with hair growth, weight loss, muscle development, clear skin, cognitive abilities, and sexual performance.
  • In filling the case, the FTC argued that the "defendants claim to offer "free" trials of these products for just the cost of shipping and handling, typically $4.95. Defendants charge consumers' credit and debit cards the full price of the products — approximately $90 — roughly two weeks after consumers order the trials".
  • The defendants also enrolled customers (without their consent) into continuity programs charging them $90 monthly for additional supplies.
  • The FTC said that the defendants engaged in unfair practices, violating different laws and regulations, including Section 5 of the FTC Act, Electronic Fund Transfer Act (EFTA), and Restore Online Shoppers' Confidence Act (ROSCA).
  • In one of its blog posts, the FTC also mentioned this case and used visuals to explain the defendants' unfair practices of operating illegally and falsely marketing to consumers. It further warned warns consumers to be wary of any operations conducted similar.

FTC's Announcement of Findings

  • The FTC had multiple press releases surrounding this case.
  • The first press release was released on November 28, 2018, and laid out the allegations, specified the defendants and mentioned which section of the FTC Act was violated.
  • The second press release was released on May 31, 2019. It announced an amendment to the allegations and introduced a new defendant (Latvian financial institution and its CEO) to the case.
  • The third press release was released on September 20, 2019, providing information on the court order against Apex Capital Group and other defendants. It also laid out the settlement and restated the allegations, providing more information than previous press releases.
  • The fourth (latest) press release was released on January 17, 2020. It again spelled out the allegations and discussed the final court order.

Description of Findings

  • In the last press release by the FTC, it described the findings in the final court order as a resolve to the Commission's charges against the defendants.
  • In the settlement agreement, the Apex Capital defendants agreed to surrender assets valued at between $3 million and $6 million. They also agreed to cease the alleged unfair practices and illegal conduct.
  • According to FTC's press release in September 2019, "the order against Phillip and the Apex Capital corporate defendants imposes a financial judgment of $60.3 million, which will be partially suspended after these defendants surrender their interests in substantially all of their assets, including all the corporate defendants’ liquid assets, Phillip’s house, certain of his personal assets, and his financial rights in various companies."

Media/Public Reaction

  • Good Morning America (GMA): In reporting on FTC's investigation into the case against the Apex Capital Group, GMA majorly focused on FTC's allegations against the defendants, citing 'credit card laundering' as being part of the alleged international internet marketing scam.
  • The news piece also highlighted the federal court's decision to halt US operations by the Apex Capital Group. The article seems to be communicating how "deceptive 'free trial' offers and fake celebrity endorsements" have become rampant in the internet marketing space.
  • Lexology: Lexology's news article dubbed "FTC Settles Allegations of Deceptive "Free Trial" Scheme Against Foreign Payment Processor and Its CEO," covered FTC's allegations against Apex Capital Group, LLC and Latvian financial institution SIA Transact Pro and its former CEO Mark Moskvins.
  • It also details the defendants' deliberate actions to unlawfully market and sell supposed 'free trials' of diet supplements and personal care products.
  • The Director of the Bureau of Consumer Protection, Andrew Smith, is quoted highlighting how some defendants in the case drained customers' accounts without their consent.
  • KGW8: The NBC-affiliated television station, KGW8 highlights FTC's case with Apex Capital Group and communicating how "free trials aren't free, they're costing billions."
  • The article highlights statistics of people (37,000) who have launched complaints about free trials over the past three years.
  • In the article, Federal Trade Commission's Chuck Harwood is quoted saying that "the problem is not that their free. The problem is that they are a trap for repeated payments."

Social Media Reaction

Apex Capital Group, LLC's Response.

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FTC Announcements: Financial vs. Others

Comparison of two financial and two non-financial cases from the FTC press releases show that the same significant categories of summary, complaint and name of the company and individual defendants, defendant's actions, FTC legal actions, and settlement and terms, in roughly that order, are present in each release. In the one case, Areta Financial, where the complaint included a false marketing practice, the FTC added information for consumers on how to protect themselves.

Global Asset Financial Services Group

  • In its press release about this case, the FTC described a complaint against Global Asset Financial Services Group, LLC. It alleged that the company falsely claimed to be attorneys or working with attorneys. The company pressured "consumers into making payments on debts they did not owe, and threatened to take legal action against consumers if they did not pay."
  • The people charged were named. The press release then presented the settlement of the case, stating that the defendants agreed to settle the charges against them.
  • The defendants were banned from debt brokering activities, misleading consumers, and misrepresenting to consumers whether they are attorneys. The settlement also included fines of $25.5 million, which were suspended because of the defendant's inability to pay.
  • The structure of the announcement was as follows:
1) Summary.
2) Complaint and name of the company and individual defendants.

Areta Financial Group

  • The FTC's press release alleged that the Arete Financial Group and related companies promulgated radio, television and online ads, as well as telemarketing calls. In these calls they pretended "to be affiliated with the Department of Education, to promise to enroll consumers in student loan forgiveness, consolidation, and repayment programs to reduce or eliminate their monthly payments and principal balances. "
  • The defendants are charged with collecting illegal upfront fees as high as $1,800. According to the FTC, rather than providing service and without the consumer's knowledge or approval, the defendants turned to a "consumer's loan servicer to place the consumer's loans into temporary forbearance or deferment status.
  • The defendants were charged with violating the Telemarketing Sales Rule and the FTC Act.
  • The FTC then warned consumers to "never pay an advance fee to a company promising to deliver debt relief" and then provided information on avoiding scams.
  • The structure of the announcement was as follows.
1) Summary
2) Complaint and name of the corporation
5) Name of other corporations and individual defendants.

Success by Health

  • The FTC alleges that Success By Health operated a pyramid scheme that enticed thousands with false promises of wealth and income. The FTC found that the defendants have defrauded more than $7 million from consumers, and kept over $1.3 million for themselves.
  • The FTC announcement emphasizes that less than 2 percent of participating consumers received more money from the defendants than they paid to them and that those lucky few averaged less than $250 per month, while most lost money. While the companies marketing materials promised a million dollars per month in commissions, it failed to mention the member would have to recruit 100,000 affiliates working for them, most of whom would lose money.
  • The FTC also highlighted the fact that this was a repeat violation for the owner in that he was violating a previous court order.
  • The complaint also alleges that the company also sold the product directly to the market for the same price the affiliates were charged, which severely limited the affiliates' ability to apply the recommended 50% markup.
  • The complaint was filed in the U.S. District Court for the District of Arizona.
  • The announcement was structured as follows.
1) Summary.
2) The complaint, corporate name of the defendant, and names of individual defendants.

Grand Bahamas Cruise Line

  • The FTC alleges the defendants made millions of illegal calls to consumers nationwide, pitching free cruise vacations between Florida and the Bahamas. Starting in 2014, the defendants operated their in-house call center, employing telemarketers to contact consumers nationwide.
  • Through 2017, the operation hired various call centers, including several other defendants, which marketed the cruise vacation packages. The service allegedly bought call lists from lead generators. They then conducted illegal survey robocalls to identify potential customers.
  • Also, the defendants never scrubbed their lists against the agencies Do Not Call Registry, and called phone numbers on the Registry. The defendants also illegally contacted consumers who asked not to be called and did not provide accurate caller ID information.
  • Proposed settlement orders ban the defendants from robocalling, including assisting others in making robocalls. The orders imposed fines more than $7.8 million, which are suspended because of the defendants' inability to pay.
  • The FTC filed the complaint in the U.S. District Court for the Middle District of Florida.
  • The structure of the press release was as follows:
1) Summary.


From Part 03
From Part 06