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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DMSION 

UNITED STATES OF AMERICA, ) 

) 

Plaintiff, ) 

) 

~ ) 

) 

PLS FINANCIAL SERVICES, INC., ) 

an Illinois corporation, ) 

) 

PLS GROUP, INC., a Delaware ) 

corporation, and ) 

) 

THE PAYDAY LOAN STORE OF ) 

ILLINOIS, INC., an Illinois corporation, ) 

) 

Defendants. ) 

CASE NO. 1:12~v-8334 

STIPULATED FINAL JUDGMENT 

AND ORDER FOR PAYMENT OF 

CIVIL PENALTIES, PERMANENT 

INJUNCTION, AND OTHER 

EQUITABLE RELIEF 

Plaintiff, the United States of America, acting upon notification and authorization to the 

Attorney General by the Federal Trade Commission (FTC or Commission), has commenced this 

action by filing the Complaint, and Defendants have waived service of the Summons and the 

Complaint The parties, represented by the attorneys whose names appear hereafter, have agreed 

to settlement of this action without adjudication of any issue offact or law and without 

Defendants admitting liability for any of the violations alleged in the Complaint. 

THEREFORE, it is ORDERED, ADJUDGED AND DECREED as follows: 

FINDINGS 

1. This Court has jurisdiction over the subject matter and the parties pursuant to 

28 U.S.C. §§ 1331, 1337(a), 1345, and 1355, and under 15 U.S.C. §§ 45(a), 53(b), 56(a), and 

1681s(a). 
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2. Venue in this district is proper under 15 U.S.C. § 53(b) and under 28 U.S.C. 

§§ 139l(b)-(c) and 1395(a). 

3. The activities of the Defendants are in or affecting commerce, as defined in 

Section 4 of the Federal Trade Commission Act (FTC Act), 15 U.S.C. § 44. 

4. The Complaint states claims upon which relief may be granted against Defendants 

under Sections 5(a), 13(b), and 16(a) of the FTC Act, 15 U.S.C. §§ 45(a), 53 (b), and 56( a); 

Sections 62l(a) and 628 of the Fair Credit Reporting Act (FCRA), 15 U.S.C. §§ 168ls(a) and 

168lw, and the Disposal Rule, 16 C.P.R. Part 682; Title V, Subtitle A of the Gramm-LeachBliley Act (GLB Act), 15 U.S.C. §§ 6801-6809, and the Safeguards Rule, 16 C.P.R. Part 314; 

and the Privacy Rule, 16 C.F .R. Part 3 13. 

5. Defendants have entered into this Stipulated Final Judgment and Order For 

Payment of Civil Penalties, Permanent Injunction, and Other Equitable Relief (Order) freely and 

without coercion. Defendants further acknowledge that they have read the provisions of this 

Order and are prepared to abide by them. 

6. Defendants waive all rights to seek appellate review or otherwise challenge or 

contest the validity of this Order and waive and release any claims they may have against the 

Commission, its employees, its representatives, or its agents. 

7. The parties agree that each shall bear its own costs and attorneys' fees incurred in 

connection with this action. Defendants agree that the entry of this Order does not entitle them 

to seek or to obtain attorneys' fees under the Equal Access to Justice Act, 28 U.S.C. § 2412, as 

amended by Pub. L. 104-121, 11 0 Stat. 84 7, 863-64 (1996), and they further waive any rights to 

attorneys' fees that may arise under said provision oflaw. 

8. Entry of this Order is in the public interest. 

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DEFINITIONS 

For purposes of this Order, the following defmitions shall apply: 

. I. "PLS" means PLS Financial Services, Inc., and its successors and assigns. PLS is 

part of a common enterprise that includes entities that hold themselves out as PLS Loan Stores 

and PLS Check Cashers. 

2. "Group" means PLS Group, Inc., and its successors and assigns. Group is part of 

a common enterprise that includes entities that hold themselves out as PLS Loan Stores and PLS 

Check Cashers. 

3. "PLS-Illinois" means The Payday Loan Store of Illinois, Inc., and its successors 

and assigns. PLS-Illinois is part of a common enterprise that includes entities that hold 

themselves out as PLS Loan Stores and PLS Check Cashers. 

4 "Defendants" means PLS, Group, and PLS-Illinois, individually, collectively, or 

in any combination. 

5. "Covered Entity" means any business entity that Group controls, directly or 

indirectly, which collects, handles, or stores personal information. Because PLS-Illinois is a 

Covered Entity, ''Non-Defendant Covered Entity" means any Covered Entity other than PLSIllinois. 

6. "Fair Credit Reporting Act" or "FCRA" refers to 15 U.S.C. §§ 1681-1681x, as 

amended. 

7. The terms "person," "consumer," and "consumer report" are as defined in 

Sections 603(b), (c), and (d), respectively, of the FCRA, 15 U.S.C. §§ 168la(b), 168la(c), and 

168la(d). 

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8. "Personal information" means individually identifiable information from or about 

an individual consumer including but not limited to: (a) a frrst and last name; (b) a home or 

other physical address, including street name and name of city or town; (c) an email address or 

other online contact information, such as an instant messaging user identifier or a screen name; 

(d) a telephone number; (e) a Social Security number; (f) a driver's license or other state-issued 

identification number; (g) a financial institotion account number; (h) credit or debit card 

information; (i) a persistent identifier, such as a customer number held in a "cookie," a static 

Internet Protocol ("IP'') address, or processor serial number; or G) any information that is 

combined with any of (a) through (i) above. 

9. "Disposal Rule" means the rule regarding the Disposal of Consumer Report 

Information and Records, 16 C.F .R. § 682. I et seq. 

IO. "Consumer information" is as defined in the Disposal Rule, I6 C.P.R.§ 682.1(b), 

i.e., "any record about an individual, whether in paper, electronic, or other form, that is a 

consumer report or is derived from a consumer report. Consumer information also means a 

compilation of such records. Consumer information does not include information that does not 

identity individuals, such as aggregate information or blind data." 

I I. "Safeguards Rule" means the rule regarding the Standards for Safeguarding 

Customer Information, 16 C.F .R. § 3 I 4.1 et seq. 

I2. "Grarnm-Leach-Bliley Act" or "GLB Act" refers to 15 U.S.C. §§ 680I -6809. 

13. "Commerce" is as defined in Section 4 of the FTC Act, I 5 U.S.C. § 44. 

14. "Privacy Rule" means the rule regarding the Privacy of Consumer Financial 

Information, I6 C.P.R.§ 313.1 et seq. 

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ORDER 

I. CIVIL PENALTY 

IT IS ORDERED that: 

A. Judgment in the amount of$ 101,500.00 (One hundred one thousand five hundred 

dollars) is entered against PLS and PLS-Illinois,jointly and severally, as a civil penalty, pursuant 

to Section 621(a) of the FCRA, 15 U.S.C. § 1681s(a), as adjusted by 16 C.P.R.§ 1.98(m). 

B. PLS, PLS-IIlinois, and their attorneys represent that, prior to or concurrently with 

their execution of this Order, PLS and PLS-IIlinois have transferred the amount specified in 

paragraph A of this Section I to their attorneys, who shall hold the sum in escrow for no purpose 

other than payment to the Treasurer of the United States after entry of this Order by the Court. 

Within seven (7) days of entry of this Order, PLS's and PLS-IIlinois's attorneys shall transfer the 

sum in the form of a wire transfer or certified or cashier's check made payable to the Treasurer 

of the United States. Wire transfers made pursuant to Section I of this Order shall be made in 

accordance with instructions provided by the Department of Justice. The check or written 

confirmation of the wire transfer shall be delivered to the Director, Consumer Protection Branch, 

U.S. Department of Justice, Civil Division, P.O. Box 386, Washington, DC 20044. The cover 

letter accompanying the check shall include the title of this litigation. In addition, PLS's and 

PLS-IIlinois's attorneys shall send written confrrmation of the payment to the FTC's counsel of 

record: Maria Del Monaco, Federal Trade Commission, 1111 Superior Avenue, Suite 200, 

Cleveland, OH 44114, Re: United States of America v. PLS Financial Services, Inc. 

C. Defendants relinquish all dominion, control, and title to the funds paid to the 

fullest extent permitted by law. Defendants shall make no claim to or demand return of these 

funds, directly or indirectly, through counsel or otherwise. 

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D. Defendants agree that the facts as alleged in the Complaint filed in this action 

shall be taken as true, without further proof, in any subsequent civil litigation filed by or on 

behalf of the Commission to enforce its rights to any payment or money judgment pursuant to 

this Order. 

II. PROHIBITED BUSINESS ACTMTIES 

IT IS FURTIIER ORDERED that: 

A. Defendants and their agents, servants, and employees and all persons in active 

concert or participation with any one or more of them, including all Covered Entities, whether 

acting directly or through any sole proprietorship, partnership, limited liability company, 

corporation, subsidiary, branch, division, or other entity who receive actual notice of this Order 

by personal service or otherwise, are hereby permanently restrained and enjoined, in connection 

with their advertising, marketing, promotion, or offering of any service or product in or affecting 

commerce, from making any representation, in any manner, expressly or by implication, about 

the extent to which Defendants maintain and protect the security, privacy, confidentiality, or 

integrity of any personal information collected from or about consumers, unless the 

representation is true, and non-misleading. 

B. Defendants and their agents, servants, and employees and all persons in active 

concert or participation with any one or more of them, including all Covered Entities, whether 

acting directly or through any sole proprietorship, partnership, limited liability company, 

corporation, subsidiary, branch, division, or other entity who receive actual notice of this Order 

by personal service or otherwise, are hereby permanently restrained and enjoined from: 

I. Violating Section 628 of the FCRA or the Disposal Rule, including but not 

limited to, by maintaining or otherwise possessing consumer information for a business purpose 

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and failing to properly dispose of such information by taking reasonable measures to protect 

against unauthorized access to or use of the information in connection with its disposal. 

2. Violating Title V, Subtitle A of the GLB Act or the Safeguards Rule, 

including but not limited to, by failing to develop, implement, or maintain a comprehensive 

written information security program containing reasonable administrative, technical and 

physical safeguards, including safeguards used to access, collect, distribute, process, protect, 

store, use, transmit, dispose of, or otherwise handle customer information; and 

3. Violating Title V, Subtitle A of the GLB Act or the Privacy Rule, 

including but not limited to, by failing to provide consumers, no later than when a customer 

relationship arises and annually for the duration of that relationship, a clear and conspicuous 

notice that accurately reflects its privacy policies and practices, including its security policies and 

pmctices. 

C. In the event that any of the statutory sections and/or rules identified in paragmph 

B are hereafter amended or modified, compliance with that statutory section or rule as so 

amended or modified shall not be a violation of this Order. 

ill. REQUIRED INFORMATION SECURITY PROGRAM 

IT IS FURTHER ORDERED that Defendants, for themselves and all Non-Defendant 

Covered Entities, shall, no later than the date of entry of this Order, establish and implement, and 

thereafter maintain, a comprehensive information security program that is designed to protect the 

security, confidentiality, and integrity of personal information collected from or about 

consumers. Such program, the content and implementation of which must be fully documented 

in writing, shall contain administrative, technical, and physical safeguards appropriate to 

Defendants' and the Covered Entity's size and complexity, the nature and scope of Defendants' 

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and the Covered Entity's activities, and the sensitivity of the personal information collected from 

or about consumers, including: 

A. The designation of an employee or employees to coordinate and be accountable 

for the information security program; 

B. The identification of material internal and external risks to the security, 

confidentiality and integrity of personal information that could result in the unauthorized 

disclosure, misuse, loss, alteration, destruction, or other compromise of such information, and the 

assessment of the sufficiency of any safeguards in place to control the risks. At a minimum, this 

risk assessment should include consideration of the risks in each relevant area of operations, 

including but not limited to (1) employee training and management; (2) information systems, 

including network and software design, information processing, storage, transmission, and 

disposal; and (3) prevention, detection, and response to attacks, intrusions, or other system 

failures; 

C. The design and implementation of reasonable safeguards to control the risks 

identified through risk assessment, and regular testing and monitoring of the effectiveness of the 

safeguards' key controls, systems, and procedures; 

D. The development and use of reasonable steps to select and retain service providers 

capable of appropriately safeguarding personal information received from Defendants and the 

Covered Entity, and requiring service providers by contract to implement and maintain 

appropriate safeguards; and 

E. The evaluation and adjustment of the information security program in light of the 

results of the testing and monitoring required by paragraph C of this Section III, any material 

changes to operations or business arrangements, or any other circumstances that Defendants or 

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the Covered Entity knows or has reason to know may have a material impact on the effectiveness 

of the information security program. 

IV. ASSESSMENT REQUIREMENTS 

IT IS FURTHER ORDERED that: 

A. In connection with their compliance with Sections II(B)(l), II(B)(2) and III of this 

Order, Defendants shall obtain initial and biennial assessments and reports (Assessments) for 

Defendants and any Non-Defendant Covered Entity from a qualified, objective, independent 

third-party professional who uses procedures and standards generally accepted in the profession. 

Professionals qualified to prepare such assessments shall be: a person qualified as a Certified 

Information System Security Professional (CISSP) or as a Certified Information Systems Auditor 

(CISA); a person holding Global Information Assurance Certification (GIAC) from the 

SysAdmin, Audit, Network, Security (SANS) Institute; or a similarly qualified person or 

organization approved by the Associate Director of Enforcement, Bureau of Consumer 

Protection, Federal Trade Commission, Washington, DC 20580. The reporting period for the 

Assessments shall cover: (1) the first one hundred and eighty (180) days after service of the 

Order for the initial Assessment; and (2) each two (2) year period thereafter for twenty (20) years 

after service of the Order for the biennial Assessments. Each Assessment shall: 

I. Set forth the specific administrative, technical, and physical safeguards 

that Defendants or the Covered Entity has implemented and maintained during the reporting 

period; 

2. Explain how such safeguards are appropriate to Defendants' or the 

Covered Entity's size and complexity, the nature and scope of Defendants' or the Covered 

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Entity's activities, and the sensitivity of the personal information collected from or about 

consumers; 

3. Explain how the safeguards that have been implemented meet or exceed 

the protections required by Section 628 of the FCRA, the Disposal Rule, the Safeguards Rule, 

and Section III of this Order; and 

4. CertifY that Defendants' or the Covered Entity's security program is 

operating with sufficient effectiveness to provide reasonable assurance that the security, 

confidentiality, and integrity of personal information is protected and has so operated throughout 

the reporting period. 

B. Each Assessment shall be prepared and completed within sixty (60) days after the 

end of the reporting period to which the Assessment applies. Defendants and any Covered Entity 

shall provide the initial Assessment to the Associate Director of Enforcement, Federal Trade 

Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580, within ten (10) days after 

the Assessment has been prepared. All subsequent biennial Assessments shall be retained by 

Defendants until the Order is terminated and provided to the Associate Director of Enforcement 

within ten (10) days of request. Unless otherwise dire.cted by a representative of the 

Commission, initial and biennial Assessments shall be sent by overnight courier (not the U.S. 

Postal Service) to the Associate Director, Division of Enforcement, Bureau of Consumer 

Protection, Federal Trade Commission, 600 Pennsylvania Avenue, NW, Washington, DC 20580, 

with the subject line USA v. PLS Financial Services, Inc., FTC File Number 1023172. Provided, 

however, that, in lieu of overnight courier, Assessments may be sent by first class mail, but only 

if an electronic version of such Assessments is contemporaneously sent to the Commission at 

DEBrief@ftc.gov. 

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~ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendants obtain acknowledgments of receipt of 

this Order: 

A. Each Defendant, within 7 days of entry of this Order, must submit to the 

Commission an acknowledgment of receipt of this Order sworn under penalty of perjury. 

B. For 20 years after entry of this Order, each Defendant must deliver a copy of this 

Order to: (1) all principals, officers, directors, and managers; (2) all employees, agents, and 

representatives who participate in conduct related to the subject matter of this Order; and (3) any 

business entity resulting from any change in structure as set forth in the Section titled 

Compliance Reporting. Delivery must occur within 7 days of entry of this Order for current 

personnel. To all others, delivery must occur before they assume their responsibilities. 

C. From each individual or entity to which Defendants delivered a copy of this 

Order, Defendants must obtain, within 30 days, a signed and dated acknowledgment of receipt of 

this Order. 

VI. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendants make timely submissions to the 

Commission: 

A. One year after entry of this Order, each Defendant must submit a compliance 

report, sworn under penalty of perjury. Each Defendant must: (a) designate at least one 

telephone number and an email, physical, and postal address as points of contact, which 

representatives of the Commission and Plaintiff may use to communicate with Defendant; (b) 

identifY all of Defendant's businesses by all of their names, telephone numbers, and physical, 

postal, email, and Internet addresses; (c) describe the activities of each business, including the 

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products and services offered, and the means of advertising, marketing, and sales, and the 

involvement of any other Defendant; (d) describe in detail whether and how that Defendant is in 

compliance with each Section of this Order; and (e) provide a copy of each Order 

Acknowledgment obtained pursuant to this Order, unless previously submitted to the 

Commission; 

B. For 20 years following entry of this Order, each Defendant must submit a 

compliance notice, sworn under penalty ofpetjury, within 14 days of any change in (a) any 

designated point of contact; or (b) the structure of any Defendant or any entity that Defendant 

has any ownership interest in or directly or indirectly controls that may affect compliance 

obligations arising under this Order, including: creation, merger, sale, or dissolution of the entity 

or any subsidiary, parent, or affiliate that engages in any acts or practices subject to this Order. 

C. Each Defendant must submit to the Commission notice of the filing of any 

bankruptcy petition, insolvency proceeding, or any similar proceeding by or against such 

Defendant within 14 days of its filing. 

D. Any submission to the Commission required by this Order to be sworn under 

penalty ofpetjury must be true and accurate and comply with 28 U.S.C. § 1746, such as by 

concluding: "I declare under penalty of petjury under the laws of the United States of America 

that the foregoing is true and correct Executed on: __ " and supplying the date, signatory's 

full name, title (if applicable), and signature. 

E. Unless otherwise directed by a Commission representative in writing, all 

submissions to the Commission pursuant to this Order must be emailed to DEbrief@ftc.gov or 

sent by overnight courier (not the U.S. Postal Service) to: Associate Director for Enforcement, 

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Bureau of Consumer Protection, Federal Trade Conunission, 600 Pennsylvania Avenue NW, 

Washington, DC 20580. The subject line must begin: USA v. PLS Financial Services, Inc. 

VII. RECORDKEEPING 

IT IS FURTHER ORDERED that Defendants must create certain records for 20 years 

after entry of the Order, and retain each such record for 5 years. Specifically, Defendants must 

maintain the following records: 

A. Accounting records showing the revenues from all goods and services sold, all 

costs incurred in generating those revenues, and the resulting net profit or loss; 

B. Personnel records showing, for each person providing services, whether as an 

employee or otherwise, that person's: name, addresses, and telephone numbers; job title or 

position; dates of service; and, if applicable, the reason for termination; 

C. Written complaints and refund requests, whether received directly or indirectly, 

such as through a third party, and any response; 

D. All records necessary to demonstrate full compliance with each provision of this 

Order, including all submissions to the Conunission; and 

E. A copy of each advertisement or other marketing material. 

VIII. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendants' 

compliance with this Order, including any failure to transfer any assets as required by this Order: 

A. Within 14 days of receipt of a written request from a representative of the 

Commission or Plaintiff, each Defendant must: submit additional compliance reports or other 

requested information, which must be sworn under penalty of perjury; appear for depositions; 

and produce documents for inspection and copying. The Conunission and Plaintiff are also 

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authorized to obtain discovery, without further leave of court, using any of the procedures 

prescribed by Federal Rules of Civil Procedure 29,30 (including telephonic depositions), 31, 33, 

34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission and Plaintiff are authorized to 

communicate directly with each Defendant. Defendants must permit representatives of the 

Commission and Plaintiff to interview any employee or other person affiliated with any 

Defendant who has agreed to such an interview. The person interviewed may have counsel 

present. 

C. The Commission and Plaintiff may use all other lawful means, including posing, 

through their representatives, as consumers, suppliers, or other individuals or entities, to 

Defendants or any individual or entity affiliated with Defendants, without the necessity of 

identification or prior notice. Nothing in this Order limits the Commission's lawful use of 

compulsory process, pursuant to Sections 9 and 20 of the FTC Act, 15 U.S.C. §§ 49 and 57b-1. 

IX. RETENTION OF JURISDICTION 

IT IS FURTHER ORDERED that this Court retains jurisdiction of this matter for 

purposes of construction, modification, and enforcement of this Order. 

( 

IT IS SO ORDERED: 

J AN . GOTTSCHALL 

TED STATES DISTRICT JUDGE 

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STIPULATED AND AGREED TO: 

OF COUNSEL: 

JON MILLER STEIGER 

Director, East Central Region 

MARIA DEL MONACO 

JONATHAN L. KESSLER 

Attorneys 

Federal Tfade Collll1lisslon 

1111 Sllperior Avenue, Suite 200 

ClewllUld, OH 44114 

Phone: (216) 263-3405 (Del Monaoo) 

Phone: (216)263-34lf6 (Kessler) 

Fax: (216) 263-342.6. 

tndelmortaco@ftC.goy 

jkessler@ftc.gov 

Dated: Octol!er 18, 2012 

FOR PLAINTIFF THE UNITED STATES OF 

AMERI€A 

STUART F. OELERY 

Acting Assistant Attorney Gl:lneral 

Civil Division 

MICHAEL S. BLUME 

Director 

RICHARD GOLDBERG 

Assistant Director 

Consumer Protection Branch 

By: ~':'-%'~~::=:~~~~~-­ JOHN 

Trial orney, Consumer Protection Branch 

United States Department of Justice 

t>.O. Box 386 

Washington, DC 20044 

Phone: 202-353•2001 

Fax: 202-514-8742 

josh.burke@usdoi.gov 

GARY S. SHAPIRO 

Acting United States Attorney 

Northern District of Illinois 

THOMAS P. WALSH 

Chief, Civil Division 

Northern District of nrmois 

219 South Dearborn, 5111 Floor 

Chleago, IL 60604 

Phone: 312-353-5312 

thomas.walsh2@usdol.gov 

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. ' ... 

Dated: _{.-~../_t~f--h'----1 L __ 

Dated: (/rr /tL .. .. 

Dated: ---','-'--'-'IJJ'-f-1-.fll. __ 

FOR DEFENDANT 

PLS FJNANCIAL SERVICES, INC.: 

ROBERT WOLFBERG, President 

FOR DEFENDANT PLS GROUP, INC.: 

ROBERT WOLFBERG, President 

FORDEFENDlAYDAYLOANSTORE 

OF ILLINP~· IN . 

/·.J;)v 

DAR'iEtWOLFBERG, President 

MARGO TANK, Esq. 

KIRK D. JENSEN, Esq. 

Buckley Sandler LLP 

1250 24th Street, NW, Suite 700 

Washington, DC 20037 

Phone: (202) 349-8050 (Tank) 

Phone: (202) 349-8048 (Jensen) 

Fax: (2Q2) 349-8080 

mtanls@buckleysandler.com 

kiensen@bucklevsandler.com 

Attorneys for Defendants PLS Fiuancial Services, 

Inc., PLS Group, Inc., and The Payday Loan Store 

oflllinois, Inc. 

16