________________________________________________ 

________________________________________________ 

202 3138 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of 

CREDIT KARMA, LLC, a limited liability company. DOCKET NO. C-4781

COMPLAINT 

The Federal Trade Commission (“Commission”), having reason to believe that Credit 

Karma, LLC (“Respondent”) has violated the provisions of the Federal Trade Commission Act 

(“FTC Act”), and it appearing to the Commission that this proceeding is in the public interest, 

alleges: 

1. Respondent Credit Karma, LLC is a Delaware limited liability company with its principal 

office or place of business at 1100 Broadway, STE 1800, Oakland, California 94607. In 

December 2020, Respondent merged with Credit Karma, Inc., Credit Karma, Inc. ceased to 

exist at that time, and Respondent became the successor to Credit Karma, Inc. 

2. Respondent has marketed third-party financial products, such as credit cards, to consumers. 

3. The acts or practices of Respondent alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the FTC Act, 15 U.S.C. § 44. 

Respondent’s Claims that Consumers were 

“Pre-approved” for Third-Party Financial Products 

4. Respondent’s website, www.creditkarma.com, and mobile application market credit 

monitoring and other tools such as financial calculators for approximating the effect of 

certain credit choices (like obtaining a loan) on a consumer’s score. 

5. To access most of these tools, a consumer must sign up for a Credit Karma account and 

become a member. When signing up for an account, a consumer must provide to Respondent 

a variety of personal information, including name, date of birth, and last four digits of a 
 

 

 

 

 

 

 

 

Social Security number, and also agree to Respondent’s Privacy Policy and Terms of 

Service, which state that Respondent may collect additional information about them from 

other sources. Respondent has amassed over 2,500 data points, including credit and income 

information, per member. 

6. Respondent sends members advertisements and recommendations for third-party financial 

products. 

7. At least since February 2018 through April 2021, through its website, mobile app, and email 

marketing campaigns, Respondent has represented in advertisements and recommendations 

to members that they have been “pre-approved” for third-party financial products such as 

credit cards. 

8. For example, in numerous instances, Respondent’s email advertisements prominently have 

represented that consumers have been pre-approved for third-party financial products, 

including but not limited to representations in Exhibits A and B. One such email, attached as 

Exhibit A, includes a subject line stating “Congrats! ... You’re pre-approved for an American 

Express Card.” When opened, the body of this email prominently reiterates, in large 

boldface, the following statements and depictions: 

Exhibit A at 1 

9. Similarly, another email advertisement from Respondent, attached as Exhibit B, includes the 

subject line “You’re pre-approved for this Amex Card.” The body of this email reinforces 

this message with the following statements and depictions: 

Page 2 of 5 
 

 

 

 

 

 

 

 

 

 

Exhibit B at 1 

10. From emails such as these, the consumer could select the link “Apply now” or, in other 

instances, “Take offer” and go to a website to where they could take final steps to take the 

offer for which they purportedly had already been approved. 

11. Respondent also has made prominent pre-approval claims in advertisements and marketing 

materials displayed on its website and mobile application, including but not limited to the 

“Pre-Approved” credit offers attached as Exhibits C and D. 

12. Despite the preapproval claims in Respondent’s emails and other marketing materials, 

financial product companies have not already approved the consumers to whom Credit 

Karma sent these offers. As one of these companies explained: “The Company does not 

preapprove, prequalify, or preselect consumers to whom to offer the [Company’s credit card] 

via Credit Karma.” 

13. In fact, for many of these offers, almost a third of consumers who received and applied for 

“pre-approved” offers were subsequently denied based on the financial product companies’ 

underwriting review, i.e., the actual process by which they made approval determinations. 

Additionally, in some instances, roughly a quarter of consumers were denied approval 

because of disqualifying financial and credit characteristics, like insufficient credit histories, 

account charge-offs, and bankruptcies. Further, the financial product companies’ 

underwriting review includes a “hard inquiry” on consumers’ credit reports, which, in many 

instances, lowered the credit scores of those whose applications were denied. Thus, in 

response to Respondent’s pre-approval claims, numerous consumers have unnecessarily 

applied for the advertised products and damaged their credit scores, wasting significant time 

and harming their ability to secure other financial products in the future. 

14. Respondent knows that its prominent pre-approval claim conveys false “certainty” to 

consumers and has employed it deliberately to influence consumers’ behavior. For instance, 

Respondent conducted A/B testing – a method of comparing two versions of a claim or 

Page 3 of 5 

 

VIOLATION OF THE FEDERAL TRADE COMMISSION ACT 

Count I 

False, Misleading, or Unsubstantiated Claims that Consumers are Pre-Approved 

17. In numerous instances, in connection with the advertising, promotion, or offering of financial 

products, Respondent has represented, directly or indirectly, expressly or by implication, 

that: 

A. Consumers were “Pre-Approved” for credit products; and 

B. Consumers had “90% odds” of approval. 

18. In fact, in numerous instances in which Respondent has made the representations set forth in 

Paragraph 17, such representations were false or misleading, or were not substantiated at the 

time the representations were made. 

Violations of Section 5 

19. Therefore, the acts and practices of Respondent as alleged in this complaint constitute 

deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the FTC 

Act, 15 U.S.C. § 45(a). 

THEREFORE, the Federal Trade Commission, this 19th day of January, 2023, has 

issued this Complaint against Respondent. 

By the Commission. 

April J. Tabor 

Secretary 

Page 5 of 5 
Exhibit A 



Exhibit B 



Exhibit C 

Exhibit D 

Exhibit E 




Exhibit F 


Exhibit G 




 

________________________________________________ 

202 3138 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of DECISION AND ORDER 

CREDIT KARMA, LLC, a limited liability company. DOCKET NO. C-4781

________________________________________________ 

DECISION 

The Federal Trade Commission (“Commission”) initiated an investigation of certain acts 

and practices of Respondent named in the caption. The Commission’s Bureau of Consumer 

Protection (“BCP”) prepared and furnished to Respondent a draft Complaint. BCP proposed to 

present the draft Complaint to the Commission for its consideration. If issued by the 

Commission, the draft Complaint would charge the Respondent with violations of the Federal 

Trade Commission Act. 

Respondent and BCP thereafter executed an Agreement Containing Consent Order 

(“Consent Agreement”). The Consent Agreement includes: 1) statements by Respondent that it 

neither admits nor denies any of the allegations in the Complaint, except as specifically stated in 

this Decision and Order, and that only for purposes of this action, it admits the facts necessary to 

establish jurisdiction; and 2) waivers and other provisions as required by the Commission’s 

Rules. 

The Commission considered the matter and determined that it had reason to believe that 

Respondent has violated the Federal Trade Commission Act, and that a Complaint should issue 

stating its charges in that respect. The Commission accepted the executed Consent Agreement 

and placed it on the public record for a period of 30 days for the receipt and consideration of 

public comments. The Commission duly considered any comments received from interested 

persons pursuant to Section 2.34 of its Rules, 16 C.F.R. § 2.34. Now, in further conformity with 

the procedure prescribed in Rule 2.34, the Commission issues its Complaint, makes the 

following Findings, and issues the following Order: 

1 
 

 

 

 

 

 

 

 

 

 

Findings 

1. The Respondent is Credit Karma, LLC, a Delaware limited liability company, with its 

principal office or place of business at 1100 Broadway, STE 1800, Oakland, California 

94607. Respondent has been the successor to Credit Karma, Inc. since December 2020. 

2. The Commission has jurisdiction over the subject matter of this proceeding and over the 

Respondent, and the proceeding is in the public interest. 

ORDER 

Definitions 

For purposes of this Order: 

A. “Covered Product or Service” means any product, service, plan, or program 

represented, expressly or by implication, to: 

1. provide any consumer, arrange for any consumer to receive, or assist any 

consumer in receiving, a loan or other extension of credit (other than a loan 

secured by real property); or 

2. provide any consumer, arrange for any consumer to receive, or assist any 

consumer in receiving, credit or stored value cards. 

B. “Respondent” means Credit Karma, LLC, a Delaware limited liability company and 

the successor to Credit Karma, Inc. since December 2020, and its successors and 

assigns. 

Provisions 

I. Prohibited Misleading and Unsubstantiated Representations 

IT IS ORDERED that Respondent, and Respondent’s officers, agents, employees, and 

attorneys, and all other persons in active concert or participation with any of them, who receive 

actual notice of this Order, whether acting directly or indirectly, in connection with the 

advertising, promotion, offering, or recommendation of any Covered Product or Service, must 

not make any representation, expressly or by implication, about: 

A. approval, including pre-approval; or 

B. a consumer’s odds or likelihood of being approved; 

unless the representation is non-misleading, including that, at the time such representation is 

made, Respondent possesses and relies upon a reasonable basis for the representation. 

2 
 

 

 

II. Monetary Relief 

IT IS FURTHER ORDERED that: 

A. Respondent must pay to the Commission $3,000,000. 

B. Such payment must be made within eight (8) days of the effective date of this Order by 

electronic fund transfer in accordance with instructions provided by a representative of 

the Commission. 

III. Additional Monetary Provisions 

IT IS FURTHER ORDERED that: 

A. Respondent relinquishes dominion and all legal and equitable right, title, and interest in 

all assets transferred pursuant to this Order and may not seek the return of any assets. 

B. The facts alleged in the Complaint will be taken as true, without further proof, in any 

subsequent civil litigation by or on behalf of the Commission to enforce its rights to any 

payment pursuant to this Order, such as a nondischargeability complaint in any 

bankruptcy case. 

C. The facts alleged in the Complaint establish all elements necessary to sustain an action by 

or on behalf of the Commission pursuant to Section 523(a)(2)(A) of the Bankruptcy 

Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for 

such purposes. 

D. All money paid to the Commission pursuant to this Order may be deposited into a fund 

administered by the Commission or its designee to be used for relief, including consumer 

redress and any attendant expenses for the administration of any redress fund. If a 

representative of the Commission decides that direct redress to consumers is wholly or 

partially impracticable or money remains after redress is completed, the Commission may 

apply any remaining money for such other relief (including consumer information 

remedies) as it determines to be reasonably related to Respondent’s practices alleged in 

the Complaint. Any money not used is to be deposited to the U.S. Treasury. Respondent 

has no right to challenge any activities pursuant to this Provision. 

IV. Customer Information 

IT IS FURTHER ORDERED that Respondent must directly or indirectly provide 

sufficient customer information to enable the Commission to efficiently administer consumer 

redress. If a representative of the Commission requests in writing any information related to 

3 
 

 

 

 

redress, Respondent must provide it, in the form prescribed by the Commission representative, 

within 14 days. 

V. Acknowledgments of the Order 

IT IS FURTHER ORDERED that Respondent obtain acknowledgments of receipt of 

this Order: 

A. Respondent, within 10 days after the effective date of this Order, must submit to the 

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

B. Respondent must deliver a copy of this Order to: (1) all principals, officers, directors, and 

LLC managers and members; (2) all employees, agents, and representatives having 

managerial responsibilities for 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 Provision 

titled Compliance Report and Notices. Delivery must occur within 10 days after the 

effective date of this Order for current personnel. For all others, delivery must occur 

before they assume their responsibilities. 

C. From each individual or entity to which Respondent delivered a copy of this Order, 

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

of this Order. 

VI. Compliance Report and Notices 

IT IS FURTHER ORDERED that Respondent make timely submissions to the 

Commission: 

A. One year after the issuance date of this Order, Respondent must submit a compliance 

report, sworn under penalty of perjury, in which Respondent must: (1) identify the 

primary physical, postal, and email address and telephone number, as designated points 

of contact, which representatives of the Commission, may use to communicate with 

Respondent; (2) identify all of Respondent’s businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; (3) describe the activities of 

each business; (4) describe in detail whether and how Respondent is in compliance with 

each Provision of this Order, including a discussion of all of the changes Respondent 

made to comply with the Order; and (5) provide a copy of each Acknowledgment (or 

documents showing electronic Acknowledgment) of the Order obtained pursuant to this 

Order, unless previously submitted to the Commission. 

B. For 5 years after the issuance date of this Order, Respondent must submit a compliance 

notice, sworn under penalty of perjury, within 14 days of any change in: (1) any 

designated point of contact; or (2) the structure of Respondent or any entity that 

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

compliance obligations arising under this Order, including: creation, merger, sale, or 

4 
 

 

 

 

 

dissolution of the entity or any subsidiary, parent, or affiliate that engages in any acts or 

practices subject to this Order. 

C. Respondent must submit notice of the filing of any bankruptcy petition, insolvency 

proceeding, or similar proceeding by or against such Respondent within 14 days of its 

filing. 

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

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

concluding: “I declare under penalty of perjury 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, 

Bureau of Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue 

NW, Washington, DC 20580. The subject line must begin: In re Credit Karma, LLC, 

Docket No. C-. 

VII. Recordkeeping 

IT IS FURTHER ORDERED that Respondent must create certain records for 5 years 

after the issuance date of the Order, and retain each such record for 5 years, unless otherwise 

specified below. Specifically, Respondent must create and retain the following records: 

A. accounting records showing all revenues, the costs incurred in generating those revenues, 

and resulting net profit or loss; 

B. personnel records showing, for each person providing services in relation to any aspect of 

the Order, whether as an employee or otherwise, that person’s: name; addresses; 

telephone numbers; job title or position; dates of service; and (if applicable) the reason 

for termination; 

C. records of all consumer complaints concerning the subject matter of the Order, whether 

received directly or indirectly, such as through a third party, and any response; 

D. a copy of each materially different advertisement or other marketing material making a 

representation subject to this Order; 

E. records of any market, behavioral, or psychological research, or user, customer, or 

usability testing, including any A/B or multivariate testing, copy testing, surveys, focus 

groups, interviews, clickstream analysis, eye or mouse tracking studies, heat maps, or 

session replays or recordings concerning the subject matter of the Order; 

5 
 

 

F. copies of all subpoenas and other communications with law enforcement, if such 

communication relate to Respondent’s compliance with this Order; 

G. all records, whether prepared by or on behalf of Respondent, that demonstrate noncompliance OR tend to show any lack of compliance by Respondent with this Order; and 

H. all records necessary to demonstrate full compliance with each provision of this Order, 

including all submissions to the Commission. 

VIII. Compliance Monitoring 

IT IS FURTHER ORDERED that, for the purpose of monitoring Respondent’s 

compliance with this Order: 

A. Within 30 days of receipt of a written request from a representative of the Commission, 

Respondent must: submit additional compliance reports or other requested information, 

which must be sworn under penalty of perjury, and produce records for inspection and 

copying. 

B. For matters concerning this Order, representatives of the Commission are authorized to 

communicate directly with Respondent. Respondent must permit representatives of the 

Commission to interview anyone affiliated with Respondent who has agreed to such an 

interview. The interviewee may have counsel present. 

C. The Commission may use all other lawful means, including posing through its 

representatives as consumers, suppliers, or other individuals or entities, to Respondent or 

any individual or entity affiliated with Respondent, 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, 57b-1. 

IX. Order Effective Dates 

IT IS FURTHER ORDERED that this Order is final and effective upon the date of its 

publication on the Commission’s website (ftc.gov) as a final order. This Order will terminate 20 

years from the date of its issuance (which date may be stated at the end of this Order, near the 

Commission’s seal), or 20 years from the most recent date that the United States or the 

Commission files a complaint (with or without an accompanying settlement) in federal court 

alleging any violation of this Order, whichever comes later; provided, however, that the filing of 

such a complaint will not affect the duration of: 

A. Any Provision in this Order that terminates in less than 20 years; 

B. This Order’s application to any Respondent that is not named as a defendant in such 

complaint; and 

6 
C. This Order if such complaint is filed after the Order has terminated pursuant to this 

Provision. 

Provided, further, that if such complaint is dismissed or a federal court rules that Respondent did 

not violate any provision of the Order, and the dismissal or ruling is either not appealed or 

upheld on appeal, then the Order will terminate according to this Provision as though the 

complaint had never been filed, except that the Order will not terminate between the date such 

complaint is filed and the later of the deadline for appealing such dismissal or ruling and the date 

such dismissal or ruling is upheld on appeal. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

ISSUED: January 19, 2023

7 
 

 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Model response "A"

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

Your comment expresses concerns about potentially misleading credit offers presented to 

you by Credit Karma. Therefore, we have added your comment to our agency’s complaint 

database, which assists us in tracking complaints and making informed law enforcement 

decisions, as well as identifying consumers who are potentially eligible for monetary relief. 

Further, if you have any additional information regarding these practices, we would encourage 
 

 

you to submit a complaint to the Commission at our website, reportfraud.ftc.gov, or by calling 

our Consumer Response Center at (877) 382-4357. In the coming months, the FTC’s staff will 

also be working to identify consumers who may be eligible to receive monetary relief in this 

matter. For detailed information on the Commission’s processes for identifying eligible 

consumers and sending money to them, please see this website. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Model response "B"

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express general support for the FTC’s action in this case. We 

appreciate this support and remain committed to combatting unlawful practices in the credit 

marketplace. Having considered all the facts of this case and all of the comments submitted in 

response to the proposed consent order, the Commission has now determined that the public 

interest would best be served by issuing the Complaint and the Decision and Order in final form 
 

without any modifications. The final Decision and Order and other relevant materials are 

available from the Commission’s website at http://www.ftc.gov. The Commission thanks you 

again for your comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Model response "C"

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express general concern about Credit Karma’s alleged conduct in 

this case. We share your concerns and emphasize that the proposed order will prohibit the 

deceptive conduct at issue in this matter and provide monetary relief to affected consumers. 

Having considered all the facts of this case and all of the comments submitted in response to the 

proposed consent order, the Commission has now determined that the public interest would best 
 

be served by issuing the Complaint and the Decision and Order in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Model response "D"

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express concern about aspects of your experience with Credit 

Karma beyond the conduct detailed in the Commission’s proposed complaint in this matter. 

Therefore, we have added your comment to our agency’s complaint database, which assists us in 

tracking complaints and helps inform our law enforcement decisions. Further, if you have any 

additional information regarding these practices, we would encourage you to submit a complaint 
to the Commission at our website, reportfraud.ftc.gov, or by calling our Consumer Response 

Center at (877) 382-4357. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Model response "E"

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express the view that the relief secured by the Commission in the 

proposed order is insufficient. The Commission has determined, however, that the proposed 

order in this case provides important protections for consumers – which would both prohibit 

Credit Karma from making deceptive approval-related claims in the future and secure $3 million 

in monetary relief for consumers who wasted time applying for purportedly-“pre-approved” 
offers for which they were denied. Additionally, the company will be subject to the 

Commission’s final order for twenty years and liable for civil penalties of up to $46,517 per 

violation should it violate that order, pursuant to Section 5(l) of the FTC Act, 15 U.S.C. § 45(l). 

Further, while the Commission has successfully secured significant monetary relief in this 

matter, the Supreme Court’s decision in AMG Capital Mgmt.,141 S. Ct. 1341 (2021), limited the 

agency’s authority to obtain money under the FTC Act. Therefore, in addition to obtaining 

money in cases such as this one, the FTC has advocated for federal legislation restoring the 

FTC’s broad ability to obtain redress for consumers. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Kenneth H. Ryesky, Esq.

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express support for the FTC’s proposed complaint and order in this 

case – and state that the requirements of the order are appropriate to stop the unlawful conduct 

alleged in this matter. We appreciate your support for the proposed complaint and order and 

remain committed to combatting unlawful practices in the credit marketplace. Having 

considered all the facts of this case and all of the comments submitted in response to the 
 

proposed consent order, the Commission has now determined that the public interest would best 

be served by issuing the Complaint and the Decision and Order in final form without any 

modifications. The final Decision and Order and other relevant materials are available from the 

Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Elexus Robinson

Columbia, South Carolina

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express concern about your experiences with a third-party financial 

product company that is not the subject of the Commission’s proposed complaint and order in 

this matter. Therefore, we have added your comment to our agency’s complaint database, which 

assists us in tracking complaints and helps inform our law enforcement decisions. Further, if you 

have any additional information regarding these practices, we would encourage you to submit a 
complaint to the Commission at our website, reportfraud.ftc.gov, or by calling our Consumer 

Response Center at (877) 382-4357. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Eva M. Mayorga

Bakersfield, California

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you appear to ask about the accuracy of credit score information you 

received from Credit Karma. To ensure that credit report information is accurate, complete, and 

up-to-date, the Commission recommends that consumers check their credit reports from the three 

nationwide credit bureaus at least once a year. You are entitled to a free copy of your credit 

report every 12 months from each of the three nationwide credit bureaus. Additionally, through 
 

 

December 2023, everyone in the U.S. can get a free credit report each week from all three 

nationwide credit bureaus. You can order your credit reports for free by visiting 

AnnualCreditReport.com, calling 1-877-322-8228, or completing the Annual Credit Report 

Request Form and mailing it to Annual Credit Report Request Service, P.O. Box 105281, 

Atlanta, GA 30348-5281. We would also encourage you to visit this FTC website for more 

detailed information on how to obtain and monitor your credit report, as well as how to dispute 

potential mistakes. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Trevor Hudock

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you state that, in your personal experience, you do not find the preapproval claims at issue in this case to be misleading, because you expect that you could be 

denied when you apply for such offers. Under the FTC Act, however, companies are responsible 

for every reasonable interpretation of their claims. Our proposed complaint alleges that when 

Credit Karma told consumers they were “pre-approved,” not only was this claim likely to 
mislead reasonable consumers, but that it did, in fact, mislead many consumers. Worse yet, the 

complaint alleges that the company knew that these claims conveyed false “certainty” to 

consumers, and that it deliberately used these deceptive claims to influence consumers’ behavior. 

Therefore, the Commission’s action is appropriate to stop the unlawful conduct alleged in this 

case. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary 
 

 

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

January 19, 2023

Stacy Nicotra

Pachogue, New York

Re: In the Matter of Credit Karma, LLC, Matter No. 202 3138 

We would like to thank you for commenting on the Federal Trade Commission’s 

(“Commission” or “FTC”) proposed consent order in the above-referenced proceeding. The 

Commission has placed your comment on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

agency’s Rules of Practice, 16 C.F.R. §4.9(b)(6)(ii). The Commission is committed to protecting 

consumers in the credit marketplace from deceptive practices, including the use of “dark 

patterns” to mislead consumers, so we greatly appreciate your feedback. 

The complaint in this matter alleges that Credit Karma misrepresented that consumers 

had been “pre-approved” for third-party financial products, such as credit cards. Despite these 

preapproval claims, financial product companies had not already approved these consumers. In 

fact, as alleged in the complaint, for many of these offers, almost a third of consumers who 

applied were subsequently denied based on the financial product companies’ underwriting 

review. The complaint further alleges that Credit Karma knew that its prominent pre-approval 

claims conveyed false “certainty” to consumers (based on the results of experiments known as 

A/B testing) and employed them deliberately to influence consumers’ behavior. In fact, to the 

extent the company revealed that consumers’ approval was anything less than certain, it 

allegedly did so by making additional false claims that consumers’ likelihood of approval was 

90%, or by using buried disclaimers. 

The proposed order would prohibit Credit Karma from making misleading or 

unsubstantiated claims about approval, including pre-approval, as well as about a consumer’s 

odds or likelihood of being approved. Further, the proposed order would require Credit Karma 

to pay $3 million in monetary relief – to be sent to consumers who wasted time applying for the 

offers described in the complaint. Additionally, to help prevent future use of deceptive dark 

patterns, the order would require Credit Karma to preserve records of any market, behavioral, or 

psychological research, or user, customer, or usability testing, including any A/B testing. 

In your comment, you express concern that this action “end[s]” in April 2021, and does 

not include loans. The action does not end in April 2021. The proposed complaint alleges that 

Credit Karma made deceptive claims through at least April 2021, and the proposed order would 

prohibit Credit Karma from making any deceptive approval-related claims about credit as well as 

most loans for a period of twenty years. 
We have added your comment to our agency’s complaint database, which assists us in 

tracking complaints and making informed law enforcement decisions, as well as identifying 

consumers who are potentially eligible for monetary relief. Further, if you have any additional 

information regarding these practices, we would encourage you to submit a complaint to the 

Commission at our website, reportfraud.ftc.gov, or by calling our Consumer Response Center at 

(877) 382-4357. 

Having considered all the facts of this case and all of the comments submitted in response 

to the proposed consent order, the Commission has now determined that the public interest 

would best be served by issuing the Complaint and the Decision and Order in final form without 

any modifications. The final Decision and Order and other relevant materials are available from 

the Commission’s website at http://www.ftc.gov. The Commission thanks you again for your 

comment. 

By direction of the Commission. 

April J. Tabor 

Secretary