A Report to Congress

March 15, 2023

Consumer Issues

Affecting American Indian

and Alaska Native

Communities
ii

Acknowledgements

The primary drafters of this report are Rosario Méndez, Kira Krown, Jennifer Leach, and Karen 

Hobbs, Division of Consumer and Business Education, and Patti Poss and Emma Fletcher, Division of 

Consumer Response and Operations. This report reflects the work of staff throughout the Federal Trade 

Commission’s Bureau of Consumer Protection, Bureau of Economics, and Regional Offices, including:

Heather Allen Karina Layugan

Faye Chen Barnouw Ryne Marksteiner

Anna Burns Deborah Marrone

Emily Cope Burton Nicholas May

Stacy Cammarano Sammi Nachtigal

Helen Clark Denise Oki

Nicole Christ Rhonda Perkins

Barbara Chun Devesh Raval

Kati Daffan Natalya Rice

Fil de Banate Lisa Rothfarb

William Efron Matthew Schiltz

Lourdes Fuentes Maricela Segura

Michelle Grajales Kelle Slaughter

Lois Greisman Laura Solis

Seena Gressin Jon Steiger

Taelor Hardesty Naomi Takagi

Charles Harwood Joannie Wei

Samuel Jacobson Matthew Wernz

Adrienne Jenkins Nicole Worley

Todd Kossow Nicholas Xu

Vincent Law Evan Zullow
iii

Table of Contents

Acknowledgements............................................................................................................ ii

I. Introduction................................................................................................................1

II. Scams Affecting AI/AN Populations........................................................................2

A. Listening to AI/AN Communities .............................................................................................2

B. Learning through Research and Data Analysis .........................................................................6

1. Types of Fraud......................................................................................................................... 7

2. Contact Methods...................................................................................................................... 9

3. Payment Methods .................................................................................................................. 11

III. Collaboration and Outreach...................................................................................12

A. Collaborations with Partners Trusted in AI/AN Communities ...............................................12

1. Webinars and Podcasts.......................................................................................................... 13

2. Presentations for Legal Aid, Community Development Financial Institutions, and Others . 14

3. Conferences ........................................................................................................................... 15

4. Work with Federal Agencies................................................................................................. 15

B. Working with Community Media............................................................................................16

IV. Consumer Education ...............................................................................................19

A. New Dedicated Page for AI/AN Communities .......................................................................20

B. Sampling of the FTC’s Consumer Education Resources ........................................................21

1. Consumer Alerts.................................................................................................................... 21

2. Pass It On Campaign ............................................................................................................. 22

3. Consumer.gov........................................................................................................................ 23

4. Protecting Small Businesses.................................................................................................. 23

V. Law Enforcement Affecting AI/AN Populations..................................................24
iv

A. Related Casework ....................................................................................................................24

1. Auto Buying and Financing Issues........................................................................................ 24

2. Predatory Lending and Other Financial Issues...................................................................... 27

3. Tech Support.......................................................................................................................... 28

4. Internet Services .................................................................................................................... 29

B. Relevant Rulemakings.............................................................................................................29

1. Impersonation ........................................................................................................................ 29

2. Junk Fees ............................................................................................................................... 30

3. Telemarketing of Tech Support Services .............................................................................. 30

4. Auto ....................................................................................................................................... 30

VI. Recommendations....................................................................................................31

A. Continue to Fight Lawbreaking through Enforcement............................................................31

B. Continue Education and Outreach Efforts...............................................................................32

C. Conduct and Encourage Further Research ..............................................................................32

VII. Appendix...................................................................................................................33

A. Selected Recent Listening Sessions with AI/AN Advocates, Organizations, Tribal 

Government Representatives, and U.S. Government Agencies .............................................33

B. Selected Recent Outreach Events by FTC Staff......................................................................34

C. Sampling of FTC Events Shared by Partners: FTC Presentation to Dineh Chamber of 

Commerce (Aug 2022) ...........................................................................................................36

D. Sampling of FTC Events Shared by Partners: ONAC Webinar on Identity Theft and FTC 

Resources (Oct 2022) .............................................................................................................37

E. News Briefing for Native American Media: Invitation...........................................................38

F. Scripts for Live Announcer and Radio Spots Placed on AI/AN Media Outlets......................39
1

I. Introduction

The Federal Trade Commission (“FTC” or “Agency”) is the country’s primary consumer 

protection agency and has a broad mandate to protect consumers, including American Indian and 

Alaska Native (AI/AN) populations,1from unfair or deceptive acts or practices in the 

marketplace. The FTC does this by conducting research and outreach to identify fraud trends and 

the impact of fraud on communities; collecting consumer reports on frauds, scams, and bad 

business practices; harnessing consumer education and outreach to warn consumers of emerging 

frauds; and filing law enforcement actions to stop unlawful practices and return money to 

consumers when possible. 

Fulfilling the FTC’s mission requires an understanding of how communities are affected

— and at times, differently affected — by consumer protection issues. In 2014, the FTC 

launched the Every Community (EC) Initiative to modernize, expand, and bring together under a 

cohesive strategic vision the Agency’s work to address the disproportionate impact of fraud and 

other practices on historically underserved communities. The FTC has developed strategies to 

combat consumer problems for many of these communities, including AI/AN populations.

Although the FTC has worked with AI/AN communities for years, in 2022, the Agency targeted 

outreach and education efforts to gain a broader understanding of the particular consumer 

protection challenges they experience and how the Agency may work to further support these

communities. This effort included listening to and collaborating with sources trusted in AI/AN 

communities including tribal government leaders, business leaders, advocacy groups, legal aid 

offices, and community media. The FTC also analyzed its consumer report data to identify fraud 

trends reported by AI/AN individuals to the Agency.

The FTC plans to continue expanding outreach and encouraging research to identify 

emerging issues that may disproportionately affect AI/AN populations. In addition, by furthering 

established relationships with AI/AN communities, and by continuing to seek new partnerships, 

the Agency will work to create the kinds of trusted relationships that lead to open 

communication about the consumer abuses experienced by AI/AN people. These relations, in 

turn, will lead to expanded — and more targeted — work to prevent and protect AI/AN 

communities from unfair or deceptive acts or practices. For example, in Tate’s Auto,

2

as 

discussed in more detail in Section V of this report, the FTC charged a group of auto dealers 

operating near the border of the Navajo nation with a range of illegal activities. This was 

accomplished in great part thanks to the collaboration of the Navajo Nation Human Rights 

1 This report uses “American Indian and Alaska Native” in accordance with the U.S. Department of the Interior’s 

Bureau of Indian Affairs’ Editorial Guide, which notes, “Most tribal nations prefer to use ‘American Indian and 

Alaska Native.’ This term is synonymous with the term ‘Native American.’ On first reference, you should use 

‘American Indian and Alaska Native (AI/AN).’ For subsequent references, you should use ‘AI/AN.’” See 

https://www.bia.gov/guide/editorial-guide.

2 FTC v. Tate’s Auto Ctr., No. 3:18-cv-08176 (D. Ariz. filed July 31, 2018), available at https://www.ftc.gov/

enforcement/cases-proceedings/162-3207/tates-auto-center.
2

Commission. Expanded outreach and stronger partnerships will allow the Agency to be more 

effective in its enforcement work. 

The FTC submits this report to the Committee on Energy and Commerce and the 

Committee on Natural Resources of the U.S. House of Representatives, and the Committee on 

Commerce, Science, and Transportation and the Committee on Indian Affairs of the U.S. Senate,

to fulfill the reporting requirement of Section 402(a) of the Protecting Indian Tribes from Scams

Act of 2022. The law requires the FTC to report on unfair or deceptive practices that target 

AI/AN populations. This report includes a summary of the FTC’s efforts to identify consumer 

protection issues AI/AN communities experience through data analysis and outreach, consumer 

education about emerging trends and other issues, law enforcement actions to hold to account 

those seeking to prey upon these communities, and recommendations to continue expanding and 

building upon this work.

II. Scams Affecting AI/AN Populations

Through the Protecting Indian Tribes from Scams Act, Congress asked the FTC to report 

on unfair or deceptive practices targeting AI/AN populations. To do this effectively, FTC staff 

engaged with partners trusted in AI/AN communities to gain a better understanding of the scams, 

frauds, and bad business practices they encountered or experienced. As a complement to these 

listening sessions, staff also analyzed FTC consumer reporting data from majority AI/AN 

communities. This analysis both builds on and supports the understanding gained from the 

listening sessions. It also suggests that the fraud experiences of people living in AI/AN 

communities are similar to those reported by people from other communities. 

A.Listening to AI/AN Communities 

During the past year, through its team at headquarters and in eight regional offices, the 

FTC met with dozens of national, regional, and local organizations serving and/or representing 

AI/AN populations.

3 During these listening forums, the FTC provided an overview of the 

Agency’s consumer protection role, and FTC staff asked three key questions: 

1. What consumer protection issues are impacting AI/AN individuals and 

communities?

2. How can the FTC effectively share information about these issues?

3. Who else should FTC staff talk to?

The discussions generated during these forums highlighted emerging issues and created

and strengthened connections for ongoing collaboration.

3 See Appendices A and B for a sampling of organizations serving AI/AN populations that FTC staff met with. 
3

Many of the advocates that FTC staff met with cited problems with auto purchasing and 

financing, including deceptive car advertising and a lack of clarity about fees at the dealership. 

They emphasized the need to raise awareness, potentially through AI/AN radio, to counter

deceptive claims made in auto advertisements. Another challenge identified by advocates was 

the prevalence of predatory lending — for example, related to housing in urban areas or student 

loan consolidation. One organization pointed out that AI/AN populations are more likely to be 

un- or underbanked than other racial and ethnic groups in the U.S., a fact confirmed by a 2019 

Federal Deposit Insurance Corporation (FDIC) study.

4 Unbanked individuals may depend on 

businesses outside the traditional banking system for loans, potentially exposing them to 

predatory lending practices. These practices underscore the need for vigorous enforcement of 

consumer protection and fair lending laws, coupled with consumer education that informs 

consumers of their rights and promotes financial literacy. As discussed later in this report, the 

FTC has done robust enforcement work in these areas through law enforcement actions against 

auto dealerships and lenders for charging junk fees5and hidden fees,6as well as through outreach 

that includes placing advertisements in community media, among other activities.

AI/AN organizations working with small businesses, tribal colleges and universities, and 

Urban Indian Organizations, which provide health care to AI/AN individuals living in urban 

areas, described experiencing ransomware attacks and online phishing scams — and

specifically, phishing scams disguised as an invoice. Organizations identified a need for more

training for and information-sharing with businesses and staff related to cybersecurity measures

and online safety education. Several groups suggested working with tribal Chambers of 

Commerce and organizations like the National Indian Education Association. 

FTC staff also benefitted from surveys conducted by the Seminole Tribe of Florida’s 

Native Learning Center (NLC),

7

a national organization that offers training and technical 

4 See Federal Deposit Insurance Corporation (FDIC), How America Banks: Household Use of Banking and 

Financial Services, 2019 FDIC Survey (October 2020), available at https://www.fdic.gov/analysis/householdsurvey/2019report.pdf. 

5 See FTC Press Release, FTC Takes Action Against Passport Automotive Group for Illegally Charging Junk Fees 

and Discriminating Against Black and Latino Customers (Oct. 18, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/10/federal-trade-commission-takes-action-against-passport-automotive-groupillegally-charging-junk-fees; see also FTC Press Release, FTC Takes Action Against Multistate Auto Dealer 

Napleton for Sneaking Illegal Junk Fees onto Bills and Discriminating Against Black Consumers (Apr. 1, 2022), 

available at https://www.ftc.gov/news-events/news/press-releases/2022/04/ftc-takes-action-against-multistate-autodealer-napleton-sneaking-illegal-junk-fees-bills.

6 See FTC Press Release, FTC Charges Lending Club with Deceiving Consumers (April 25, 2018), available at 

https://www.ftc.gov/news-events/news/press-releases/2018/04/ftc-charges-lending-club-deceiving-consumers.

7 The Native Learning Center (NLC) offers free Training and Technical Assistance to Native Americans and those 

working within Indian Country. The NLC is a model activity program of the Seminole Tribe of Florida (STOF) 

Housing Department and was established in cooperation with the Department of Housing and Urban Development 

and Eastern Woodlands Office of Native American Programs (EWONAP) in 2008. See https://www.nativelearning

center.com/.
4

assistance services for all tribes. In three informal surveys, NLC asked AI/AN individuals about 

any scams, frauds, and bad business practices they had encountered, as well as their input on 

how best to disseminate consumer education resources in AI/AN communities.

8 Anecdotal 

evidence in the responses included reports of impersonator scams, many of which originated

over the phone. Many impersonators pretended to be a family member in an emergency, a U.S. 

or tribal government representative, or a utility company. Some callers used threats of arrest or

account cancelation if the target did not pay. Impersonator scams are often among the top three 

fraud types reported to the FTC.9 As part of the Agency’s ongoing efforts to address 

impersonator scams, the FTC has issued a Notice of Proposed Rulemaking,

10 which would give 

the FTC additional tools to fight fraud and return money to consumers harmed by 

impersonators. This proposed rulemaking is discussed in more detail later in this report.

Tech support scams were also mentioned by respondents, and several said that after 

being contacted by a scammer through phone, email, or social media, they were told to pay using

gift cards — often a specific card — and were then instructed to share the PIN, which gave the 

scammer access to all funds on the card. A number of respondents suggested working with tribal 

governments to disseminate scam alerts on these topics through tribal newsletters. Several

respondents noted that the scams they referenced had impacted, and in some cases targeted, older 

adults in particular. They cited a need for training, particularly for caregivers, on how to help 

older adults spot and avoid scams. As outlined later in this report, the FTC is addressing tech 

support scams through law enforcement and policy initiatives, including a proposed expansion of 

the Telemarketing Sales Rule.11 To address gift cards scams, the FTC uses a multi-pronged 

8 Two informal surveys were offered to attendees of NLC trainings for tribal housing agencies; the NLC distributed 

the third survey through its listserv of nearly 7,000 subscribers.

9 See FTC Data Spotlight, Government imposter scams top the list of reported frauds (Jul. 1, 2019), available at 

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2019/07/government-imposter-scams-top-listreported-frauds; see also FTC Data Spotlight, Amazon tops list of impersonated businesses (Oct. 20, 2021), 

available at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2021/10/amazon-tops-listimpersonated-businesses.

10 See FTC Press Release, FTC Proposes New Rule to Combat Government and Business Impersonation Scams

(Sept. 15, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/09/ftc-proposes-new-rulecombat-government-business-impersonation-scams. 

11 See FTC Press Release, Federal Trade Commission Proposes Small Business Protections Against Telemarketing 

Tricks and Traps (Apr. 28, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/04/

federal-trade-commission-proposes-small-business-protections-against-telemarketing-tricks-traps.
5

approach involving outreach to businesses, community groups, and local governments,12 as well 

as the publication of data analyses that help raise awareness.13

Legal aid representatives are often on the front lines of helping their clients deal with 

challenging situations and are thus well positioned to know what consumer protection issues 

communities are experiencing.14 To better understand those challenges, FTC staff met with legal 

aid organizations that serve AI/AN clients across the country. 

Among the scams affecting AI/AN clients, these organizations identified Facebook 

Marketplace or Amazon scams. They explained that residents of rural communities, often 

distant from retail centers, are sometimes more reliant on online shopping. Their clients who 

bought items through Facebook Marketplace or Amazon often received a lower-quality version 

of what they ordered — or, in some cases, nothing at all. 

The attorneys reported that their clients get text messages or online pop-ups claiming

they have won a prize, lottery, or sweepstakes. However, to get their non-existent winnings,

they have to pay a fee, taxes, or duty on their prize, which is the hallmark of a scam. Several 

organizations also mentioned online romance scams15 as an issue, including with older adults.

In these cases, romance scammers create fake profiles on dating sites and apps, strike up a 

relationship with someone to build up trust, and then make up a story and ask for money. Several 

legal aid organizations noted that their clients experienced these scams on dating sites marketed

specifically to AI/AN individuals. 

As a partial solution, many of the legal aid attorneys stressed the importance of having 

consumer education resources in-language and suggested working through tribal government 

agencies to communicate scam alerts to members.

12 See FTC article, Gift Cards Scams (Aug. 2022), available at https://consumer.ftc.gov/articles/gift-card-scams and 

FTC’s consumer education campaign in collaboration with partner organizations to fight scams that use gift cards, 

materials available at https://www.ftc.gov/stopgiftcardscams.

13 See FTC Data Spotlight, Scammers prefer gift cards, but not just any card will do (Dec. 8, 2021), available at 

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2021/12/scammers-prefer-gift-cards-not-justany-card-will-do; see also FTC Data Spotlight, Gift cards top scammers’ wish lists (Dec. 21, 2020), available at

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2020/12/gift-cards-top-scammers-wish-lists.

14 In 2021, the FTC launched the Community Advocate Center to support legal services organizations’ fraud 

reporting and strengthen the FTC’s connections with historically underserved communities. Five of the legal service 

providers who are members operate programs dedicated to service AI/AN communities. Information about the 

Community Advocate Center is available at https://reportfraud.ftc.gov/#/community. 

15 According to FTC data, in 2022 nearly 70,000 people reported a romance scam, and reported losses hit a 

staggering $1.3 billion. See FTC Data Spotlight, Romance scammers’ favorite lies exposed (Feb. 9, 2023), available 

at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2023/02/romance-scammers-favorite-liesexposed.
6

B.Learning through Research and Data Analysis

In addition to conversations with community members and those who serve them, 

analyses of reports from the public help the FTC to understand how fraud is affecting AI/AN and 

other communities. The FTC collects reports from consumers about fraud through its Consumer 

Sentinel Network (“Sentinel”) database. A variety of agencies and organizations contribute 

consumer reports,16 and the FTC takes reports directly from the public through its call center and 

online reporting system at ReportFraud.ftc.gov. From 2018 to 2022, the agency took in about 11 

million fraud reports with over $20 billion in reported fraud losses.17

Analysis of Sentinel data using home ZIP code information from consumers can provide 

insights into the communities that report to the FTC,18 such as what types of fraud they report 

encountering, the contact and payment methods reported, and other details about consumers’ 

experiences. Previous FTC research and analysis has demonstrated differences in fraud reporting 

by different demographic communities.19 New analysis reported below explores reports 

submitted to Sentinel from 2018 to 2022 by consumers living in communities identified as 

majority AI/AN (“AI/AN communities”) using Census data.20 The results show both 

commonalities and differences in the experiences reported by these communities as compared to 

all other U.S. communities (“other communities”).21

From 2018 to 2022, consumers living in AI/AN communities filed 7,368 fraud reports. 

As with other communities, most fraud reports from AI/AN communities were about fraud 

people spotted or encountered but avoided losing any money to. However, 29% of these fraud 

reports indicated the loss of money (“loss reports”). Reported fraud losses by AI/AN 

communities totaled $12.5 million. The median reported fraud loss for AI/AN communities was 

$500, compared to $435 for other communities. Residents of AI/AN communities were about 

16 Data contributors are listed at https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors.

17 These figures and figures throughout this report do not include reports about unwanted calls or reports about 

identity theft.

18 From 2018-2022, 81% of reports included the consumer’s ZIP code. 

19 See FTC Staff Report, Serving Communities of Color, at 41-46 (Oct. 2021), available at https://www.ftc.gov/

system/files/documents/reports/serving-communities-color-staff-report-federal-trade-commissions-efforts-addressfraud-consumer/ftc-communities-color-report_oct_2021-508-v2.pdf.

20 Majority AI/AN communities are defined here as ZIP codes corresponding with Census ZCTAs with a population 

of more than 50% American Indian and Alaska Native alone. Census ZCTA demographics are based on the 2016-

2020 American Community Survey 5-Year Estimates. This method identified 342 majority AI/AN ZIP codes with a 

total population of 594,359 and an American Indian and Alaska Native alone population of 482,315.

21 Figures throughout this report pertaining to “other communities” are based on reports from consumers who 

provided a U.S. ZIP code, excluding reports from majority AI/AN ZIP codes.
7

half as likely as residents of other communities to have filed a fraud report.22 But when they did 

report, AI/AN communities were more likely to submit their report using mobile devices than 

other communities.23

Reports to Sentinel from both AI/AN communities and other communities show fraud is 

a problem that affects people of all ages. Controlling for population size, younger adults (ages 

20-59) living in AI/AN communities reported losing money to fraud at nearly the same rate as 

older adults. However, people 70 and older reported much higher median individual dollar losses 

than other age groups in these communities.24

1. Types of Fraud

The types of fraud most often reported by AI/AN communities were also frequently 

reported by other communities, but some frauds accounted for a larger share of reports by AI/AN 

communities. Figure 1 below shows the top fraud types ranked by the share of reports submitted 

to Sentinel by AI/AN communities from 2018 to 2022. Government imposter scams were the 

most frequently reported fraud type by AI/AN communities — 24% of their fraud reports were 

about these scams, compared to 18% of reports by other communities. These reports most often 

described phone calls from scammers impersonating the Social Security Administration. Prize, 

sweepstakes and lottery scams were the second most frequently reported fraud type by AI/AN 

communities, and the share of reports, at 17%, was nearly twice that of other communities. 

These scams were far more likely to be reported by older adults — one in four loss reports filed

22 From 2018-2022, AI/AN communities filed 1,240 fraud reports per 100,000 population, while other communities 

filed 2,609 fraud reports per 100,000 population. This suggests AI/AN communities may be less likely to report to a 

government agency or other Sentinel data contributor about fraud. This is not conclusive, however, because AI/AN 

communities could have had fewer experiences with fraud. Many factors affect Sentinel reporting rates, and 

underreporting is a concern for all communities. One study has shown that only about 4.8 percent of the victims of 

mass-marketing consumer fraud complained to a government agency or the Better Business Bureau. See Keith 

Anderson, To Whom Do Victims of Mass-Market Consumer Fraud Complain? at 1 (May 2021), available at

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3852323. 

23 From 2018-2022, 40% of AI/AN reports directly to the FTC were submitted using a mobile device, 32% were 

submitted online using a computer, and 27% were submitted by contacting the FTC’s call center. Other communities 

submitted 34% of their reports using mobile devices, 43% of their reports online using a computer, and 22% by 

contacting the FTC’s call center.

24 From 2018-2022, the reported median individual fraud loss for people 70 and older living in AI/AN communities 

was $1,520, compared to $500 for all reports from AI/AN communities. This age-related pattern is similar to that 

seen in reports from other communities. See FTC Staff Report, Protecting Older consumers 2021-2022, at 29-30

(Oct. 2022), available at https://www.ftc.gov/system/files/ftc_gov/pdf/P144400OlderConsumersReportFY22.pdf.
8

by those 70 and over living in AI/AN communities were about prize, sweepstakes, and lottery 

scams.25

While Figure 1 is based on all Sentinel fraud reports, including those that did not indicate 

any money was lost, an analysis of loss reports and total reported losses gives a fuller 

understanding of the harm caused by fraud in AI/AN communities. This is illustrated in Figure 2 

below, which shows the top fraud types reported by AI/AN communities from 2018 to 2022 

ranked by the share of loss reports. More than one in four fraud loss reports by AI/AN 

communities were about online shopping fraud, far more than any other fraud type.26 But AI/AN 

25 For comparison, about 7% of loss reports from people 60-69 living in AI/AN communities and 1% of loss reports 

from people 20-59 in these communities were about prize, sweepstakes, and lottery scams. These reports most often 

described phone calls about nonexistent winnings from scammers impersonating well-known businesses.

26 Online shopping fraud reports soared during the COVID-19 pandemic for both AI/AN communities and other 

communities. Many of these reports were about items purchased online that were never received, often after seeing 

an ad on social media. See FTC Data Spotlight, Pandemic purchases lead to record reports of unreceived goods

(July 1, 2020), available at https://www.ftc.gov/news-events/blogs/data-spotlight/2020/07/pandemic-purchaseslead-record-reports-unreceived-goods.
9

communities reported losing the most money in the aggregate to romance scammers — 34% of 

their 2018 to 2022 reported fraud losses.27

2. Contact Methods

As shown in Figure 3, AI/AN communities identified a phone call as the contact method 

used in 47% of fraud reports filed from 2018 to 2022, more than any other contact method. 

Nearly 60% of these reports were about government impersonation scams.28 However, just 12% 

of reports about phone fraud by AI/AN communities indicated any money was lost.29

27 Reported losses to romance scams were striking for all communities during this period. See FTC Data Spotlight, 

Reports of romance scams hit record highs in 2021 (Feb. 10, 2022), available at https://www.ftc.gov/newsevents/data-visualizations/data-spotlight/2022/02/reports-romance-scams-hit-record-highs-2021.

28 From 2018-2022, 58% of phone fraud reports from AI/AN communities were classified as government 

impersonation scams, followed by prize, sweepstakes, and lottery scams at 20%. These figures exclude reports 

classified as unspecified.

29 For comparison, 62% of 2018-2022 reports by AI/AN communities about fraud originating online indicated 

money was lost. 
10

Online contact methods were responsible for the largest share of loss reports by AI/AN 

communities during this period,30 and 43% of these loss reports were categorized as online 

shopping scams. Social media was the most frequently reported online contact method — more 

than one in five loss reports from AI/AN communities indicated the fraud started on social 

media.

31 Reports about scams originating on social media have soared in recent years, including 

in AI/AN communities.32

30 Both older and younger adults in all communities reported losses to online fraud more frequently than losses to 

phone fraud, but the share of reports about losses to phone fraud was highest for older adults. See FTC Data 

Spotlight, Who experiences scams? A story for all ages (December 8, 2022), available at https://www.ftc.gov/newsevents/data-visualizations/data-spotlight/2022/12/who-experiences-scams-story-all-ages. 

31 This figure excludes reports that did not indicate a contact method.

32 See FTC Data Spotlight, Social media a gold mine for scammers in 2021 (Jan 25, 2022), available at

https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2022/01/social-media-gold-mine-scammers2021.
11

3. Payment Methods

Figure 4, below, shows the top payment methods ranked by the share of fraud losses 

reported by AI/AN communities from 2018 to 2022. Gift cards

33 were the top fraud payment 

method reported by AI/AN communities — 28% of fraud loss reports indicated a gift card as the 

payment method, compared to 17% for other communities. Reports of gift card payments were 

particularly common in scams that impersonated government agencies or well-known 

businesses. Just 12% of fraud reports from AI/AN communities identified credit cards as the 

method of payment, compared to 22% of reports from other communities. This is an important 

distinction because the law provides additional fraud protections for credit card transactions that 

may enable people to get their money back.

33 The gift card payment method includes cards that hold a specific cash value that can be used for purchases and 

reload cards such as MoneyPak that are used to add value to these cards. 
12

III. Collaboration and Outreach

To deliver consumer protection messages effectively, it is critical to collaborate with 

people and organizations already trusted in communities. This includes community media, which 

are often among the most trusted sources of information in many historically underserved 

communities. 

The FTC has spent years building trusted partnerships in AI/AN communities. In 2014, 

the Agency held a Native American Issues: A Common Ground Conference, convening legal aid 

attorneys, advocates, and representatives of state, federal, and tribal governments in Albuquerque 

to discuss issues facing AI/AN consumers.34 In 2019, an Oklahoma Ethnic Media Roundtable 

included participation from both Cherokee and Potawatomi Nations.35 In 2020, the FTC, the 

FDIC, and the Oklahoma Native Assets Coalition, Inc. (ONAC) — a Native-led nonprofit 

working to create greater opportunities for the economic self-sufficiency of Native families —

presented a webinar on scams affecting Native American communities. And in 2021, the FTC’s

Montana Ethnic Media Roundtable included tribal community participation.

36 FTC staff have 

also presented on consumer issues on the Blackfeet Reservation in Montana. 

Over the past year, in addition to creating and disseminating consumer education

materials, FTC staff have continued to build partnerships with tribal governments and 

organizations serving AI/AN populations. This has been complemented by the Agency’s robust 

efforts to connect with AI/AN media outlets that reach individuals both on tribal lands and in 

urban areas.

A.Collaborations with Partners Trusted in AI/AN

Communities

The COVID-19 pandemic brought both challenges and opportunities to extend the FTC’s 

reach through virtual connections across the country. As outlined in previous sections, in 2022 

alone, Agency staff met virtually and in person with dozens of organizations serving AI/AN 

populations, including tribal governments, to share resources about spotting and avoiding 

scams.

37 Through these contacts, FTC staff continue to learn about emerging trends and 

34 See Conference Agenda, Native American Issues: A Common Ground Conference (May 23, 2014), available at 

https://www.ftc.gov/system/files/documents/public_events/570561/2014.05.23_albuquerquefinal.swr_.pdf. The full 

list of FTC’s Common Ground Events is available at https://www.consumer.gov/commonground.

35 See Spotting and Avoiding Scams Targeting Diverse Communities in Oklahoma (Mar. 7, 2019), available at

https://consumer.gov/sites/www.consumer.gov/files/ftc_invite_oklahoma.pdf.

36 See Spotting and Preventing Pandemic Related Scams and Other Fraud in Montana/The Mountain West (Mar. 24, 

2021), available at https://www.consumer.gov/sites/www.consumer.gov/files/ftc_invite_montana.pdf. 

37 See Appendices A and B for a list of organizations the FTC met with.
13

challenges faced by AI/AN individuals and communities. This not only helps the FTC know how 

best to respond to these challenges, but also helps staff craft and seek opportunities to convey 

consumer protection information that’s relevant, useful, and trustworthy. Below are examples of

partner organizations sharing FTC messages through social media channels and newsletters. 

Examples of FTC Messages Featured in AI/AN Partners’ Social Media and Newsletters

Other organizations have invited FTC staff to present at webinars for their AI/AN 

constituencies, on podcasts, and at other outreach activities. A small sampling of outreach events

that resulted from these listening sessions is highlighted below.

38

1. Webinars and Podcasts

Through formal presentations and podcasts hosted by partners, the FTC has been able to

offer tailored information for particular audiences; for example, business owners.

NLC’s Hoporenkv Podcast: NLC invited FTC staff to participate in a series of episodes of its

Hoporenkv Podcast.39 Episodes focused on different topics, including: the top scams reported in 

2021; how to spot and avoid bogus money-making opportunities; spotting and avoiding phone 

scams; and payday loans, cash advances, car title loans, and managing debt. The episodes 

originally aired in November 2022. They are available on all major podcast platforms as well as

on the NLC’s YouTube channel.40

38 See Appendix B for a more comprehensive list of outreach activities.

39 Available at https://hoporenkvpodcast.com/. 

40 See NLC’s YouTube channel, available at https://www.youtube.com/@NativeLearningCenter.
14

ONAC: FTC staff partnered with ONAC to present a 

webinar on avoiding and recovering from identity 

theft.41 This webinar also piqued media interest from 

Indian Country Today, which later interviewed the 

FTC staff presenter for a feature story on identity theft 

and holiday scams.

42

Dineh Chamber of Commerce: Through a connection 

made with National Center for American Indian 

Enterprise Development (NCAIED), FTC staff were 

invited to present to the Dineh Chamber of Commerce. FTC shared information with the 

Chamber’s Executive Board and members about common scams targeting small businesses and

cybersecurity principles to help protect data and information. 

Invitation to FTC/ONAC Webinar

2. Presentations for Legal Aid, Community Development 

Financial Institutions, and Others

The FTC has worked with legal aid offices, Community Development Financial 

Institutions, and other organizations to share consumer education resources that they in turn can 

make available to their clients. 

Various Legal Aid Organizations: Through a connection with Michigan Indian Legal Services, 

FTC staff were invited to present on FTC resources, including spotting and avoiding scams,

during a National Association of Indian Legal Services (NAILS) monthly meeting in February 

2023.

43 FTC staff have also built an ongoing partnership with DNA People’s Legal Services, 

which provides legal services to persons living in poverty on the Navajo, Hopi, and Jicarilla 

Apache Reservations, and in parts of Northern Arizona, Northwest New Mexico, and Southern 

Utah. This partnership led to, among other things, a DNA attorney and client participating in the 

FTC’s November 2022 news briefing for Native American media, discussed later in this report. 

Native CDFI Network (NCN): FTC staff were invited to present virtually to members of the

NCN. The presentation focused on common scams and FTC resources available to AI/AN 

communities. FTC staff also met separately with representatives from particular community 

development financial institutions (CDFIs), including the Native360 Loan Fund and the Mni 

41 See Appendix D for event materials. The webinar, “Identity Theft and FTC Resources,” was recorded, posted on 

ONAC’s website, and emailed to ONAC’s listserv, as well as distributed through several partners. The webinar is 

available for viewing at https://www.oknativeassets.org/our_work/2022. 

42 See Indian Country Today media interview (Oct. 17, 2022), available at https://indiancountrytoday.com/

newscasts/10-17-22-energy-solutions-for-tribes.

43 NAILS is part of the Native American Section of the National Legal Aid and Defender Association.
15

Sota Fund, and provided information about free FTC resources on scam prevention, financial 

literacy, debt collection, and other topics. 

Minnesota Indian Affairs Council (MIAC): FTC staff gave a virtual training on FTC consumer 

education resources during the Minnesota Indian Affairs Council’s quarterly meeting. This, in 

turn, prompted interest from a writer from The Circle, a Minneapolis-based publication for 

Native Americans, in reporting on fraud and scams.

44

3. Conferences

The FTC has also built partnerships by attending, exhibiting, and distributing FTC 

consumer and business print publications at conferences, fairs, and other in-person events.

Alaska Federation of Natives Annual Convention: Continuing a practice that began before the 

pandemic, FTC staff distributed resources during the Alaska Federation of Natives 2022 Annual 

Convention in October, sharing a booth with the Indian Arts and Crafts Board. This event draws 

approximately 6,000 attendees each year and is the largest representative annual gathering of 

Native peoples in the United States.

45

Native American Finance Officers Association’s (NAFOA) Annual Conference: FTC staff 

attended NAFOA’s annual conference in October 2022, where they distributed publications and 

connected with members about key consumer protection issues impacting them, recommended 

organizations for the FTC to meet with, and opportunities for further outreach.

Eastern and Midwestern Conference on the Workforce Innovation and Opportunities Act: The

North Carolina Commission of Indian Affairs invited FTC staff to present on job scams, fake 

check scams, spotting bogus work-at-home opportunities, and how to report fraud to the FTC. 

The conference offers training sessions for AI/AN jobseekers and members of tribal government 

employment offices.

4. Work with Federal Agencies

In addition to connecting with local, regional, and national AI/AN organizations, staff 

reached out to other U.S. federal agencies — many of which have pre-established relationships 

and communication channels with tribal governments. 

U.S. Department of the Interior’s Bureau of Indian Affairs (BIA): In December 2022, FTC staff 

met with representatives from the Division of Economic Development to provide input on 

44 See The Circle, FTC Warns Indian Country About Scams (Dec. 6, 2022), available at https://thecirclenews.org/

cover-story/ftc-warns-indian-country-about-scams/.

45 See statement from the organization’s website, available at https://www.nativefederation.org/.
16

updating the “How to Avoid Getting Scammed” page on BIA’s website46 and content for their 

upcoming newsletter. 

U.S. Department of Housing and Urban Development’s Office of Native American Programs 

(ONAP): FTC staff are working with ONAP to publish consumer protection information in a

“Dear Tribal Leader” letter, which ONAP will distribute to its tribal contacts. This will include a 

poster promoting ReportFraud.ftc.gov that tribal housing entities can use to alert people about 

common scams and where to report them. 

U.S. Department of Justice’s Office of Victims of Crime (OVC), American Indian and Alaska 

Native Victim Services Resources: OVC’s July 2022 newsletter included FTC information on 

consumer education resources, and how to report scams, frauds, and bad business practices. The 

newsletter is distributed to their grantees and all of the 574 federally-recognized tribes which

have registered to receive it. 

B.Working with Community Media 

Radio and newspapers were cited by many partner organizations as an effective — and in 

some cases the most effective — way to reach AI/AN populations with consumer protection

information. Building on past ethnic media work in AI/AN communities, the FTC hosted a news 

briefing47 in November 2022 for AI/AN media on spotting and avoiding scams. This event gave 

journalists ready access to FTC experts, as well as to storytellers who shared their experiences.

Journalists also had the opportunity to relay similar experiences from their own communities. 

The briefing covered FTC law enforcement cases, consumer protection issues like government 

and business impersonators, and the importance of reporting fraud and bad business practices. A 

total of 18 reporters attended from the Seminole Tribune, Indian Voices, Lakota Times, Hoopa 

Tribal Radio, Native Broadcast Enterprise, and other outlets.48 This event resulted in articles 

published in print newspapers, social media, and online.

49 TV and radio stations also streamed 

46 Updated website available at https://www.bia.gov/service/starting-business/how-avoid-getting-scammed. 

47 See invitation in Appendix E.

48 Attendees included reporters from KWLP Radio, Native Broadcast Enterprise/KTNN Radio, ChargePoint, Ethnic 

Media Services, FNX-TV, Indian Voices, KIDE Hoopa Tribal Radio, KWDR.org, Rez Radio 91.3 – KPRI, 

Seminole Tribune, the Native Learning Center, The Circle, KWSO, Smoke Signals – The Confederated Tribes of

Grand Ronde, Lakota Times, several freelancers, and representatives from DNA-People’s Legal Services, Inc., and 

the Seminole Police Department. 

49 See, e.g., Lakota Times (Nov. 30, 2022), available at https://drive.google.com/file/d/1MnDbMgZv8KYiSj_3UAE

Z_NElcK7g5Ioo/view; Native Voice One (Nov. 24, 2022), available at https://www.linkedin.com/posts/kokopele_

ftc-battles-highway-robbery-in-indian-country-activity-7000843382520516608-xIz2/?utm_source=share&utm

_medium=member_desktop; Rex Radio 91.3 (Nov. 10, 2022), available at https://drive.google.com/file/

d/1P0i8XR2r7IISqlc6VnNWK900pBNbfkWl/view; Smoke Signals (Nov. 15, 2022), available at
17

the event and made it available to their AI/AN audiences.

50 The FTC plans to continue building 

connections with these reporters through ongoing outreach, encouraging them to sign up to 

receive press releases and Consumer and Business Alerts, and making the Agency’s experts 

available to them.

In addition to the news briefing for AI/AN media outlets, starting in November 2022, the 

FTC engaged in a paid advertising campaign for radio, print, and digital media outlets that 

primarily reach AI/AN communities, which are sources trusted in the target audience. The FTC’s

campaign focused on raising awareness about gift card scams and reporting fraud through

advertisements and advertorials in 25 print publications, websites, and tribal newsletters across 

the country. The FTC also placed related fifteen- and thirty-second radio spots51 on more than

300 radio stations across the United States and Canada.

52

https://www.smokesignals.org/articles/2022/11/15/is-the-irs-really-texting-you-nope/; The Circle (Dec. 6, 2022),

available at https://thecirclenews.org/cover-story/ftc-warns-indian-country-about-scams/; Korean News (Nov. 29, 

2022), available at https://drive.google.com/file/d/19mvNVi1Mn2oDW8P7Nk-x3Bv49-PcgJkS/view; 

ChineseInLA.com (Nov. 28, 2022), available at https://www.chineseinla.com/hotnews/2410196.html.

50 See, e.g., FNX TV (Nov. 10, 2022), video available at https://vimeo.com/773060314/6f823d6a25; KIDE-FM 

Hoop Tribal Radio (Nov. 10, 2022), recording available at https://drive.google.com/file/d/1JUi0fLPxFk7SM6srrqk

7XFr5-BMpjke7/view; KTPY (Nov.10, 2022), recording available at https://drive.google.com/file/d/19PT8jkf8

YLghpzBBO78IBRa3dqFpUkRH/view.

51 See Appendix G for scripts of radio spots.

52 These included radio spots on over 300 AI/AN radio stations across the country including in Alaska, Arizona, 

Arkansas, British Colombia, California, Colorado, Idaho, Illinois, Indiana, Louisiana, Maine, Massachusetts, 

Michigan, Minnesota, Mississippi, Montana, Nebraska, Nevada, New Mexico, New York, North Carolina, North 

Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, South Dakota, Texas, Utah, Vermont, Washington, Wisconsin, and 

Wyoming.
18

Paid Advertorials Placed in AI/AN Newspapers and Newsletters

Building on the success of a previous American Rescue Plan-funded ad campaign53 with 

iHeartMedia on scams related to financial impacts of the COVID-19 pandemic, the FTC also 

engaged in a paid campaign to reach 31 radio stations54 with a frequency around reservations 

across the country through that streaming platform. The campaign included digital banners and 

radio spots.55

53 H.R.1319 - 117th Congress (2021-2022): American Rescue Plan Act of 2021, H.R.1319, 117th Cong. (2021), 

available at https://www.congress.gov/bill/117th-congress/house-bill/1319. Through ARP funds the Agency was 

able to host 15 virtual Financial Impact Listening Sessions with advocates, leaders, and organizations that work with 

diverse communities in 26 states and the District of Columbia.

54 These included KALZ-FM, KBKS-FM, KBOS-FM, KCOL-AM, KDFD-AM, KEEY-FM, KENI-AM, KEX-AM, 

KFBT-FM, KFBW-FM, KFBX-AM, KFYI-AM, KHOW-AM, KHUD-FM, KIIX-AM, KJAQ-FM, KJKJ-FM, 

KKRZ-FM, KMOD-FM, KNIX-FM, KNST-AM, KOHT-FM, KOLT-FM, KQNT-AM, KRDU-AM, KRQQ-FM, 

KRZR-AM, KTBT-FM, KTGX-FM, KTLK-AM, KZOK-FM.

55 See Appendix G for scripts of radio spots.
19

Digital Advertisements Placed on iHeartMedia Radio and Streaming Channels 

Reaching AI/AN Communities

IV. Consumer Education 

Making consumer education resources available in AI/AN communities is vital to helping

people spot and avoid fraud and scams. The FTC’s Division of Consumer and Business 

Education (DCBE) creates plain language consumer and business education materials in multiple 

formats, including printed materials, websites, blogs, videos, and audio recordings. These are 

most often developed in partnership with other divisions in the FTC’s Bureau of Consumer 

Protection (BCP) and with regional offices to ensure Agency messaging on scam trends is

current, clear, and relevant. DCBE has published content on all the consumer protection issues 

described in the sections above. These materials are in the public domain and available for use, 

translation, and customization by tribal leaders, government agencies, organizations, and others 

serving AI/AN populations. In addition, the FTC has published consumer education materials

related to the selling of counterfeit AI/AN art, which is an ongoing issue impacting artisans and 

vendors in these communities.56

In 2022, at least four tribal organizations, including two tribal police departments, 

ordered a variety of consumer education resources from the FTC through its Bulk Order 

website.57 The materials ordered covered topics like protecting your personal information, debt 

and credit, cybersecurity, choosing a college, identity theft, and gift card scams. The following 

56 See FTC article, Buying American Indian Arts and Crafts (Dec. 2021), available at https://consumer.ftc.gov/

articles/buying-american-indian-arts-crafts. The article was created in conjunction with the Indian Arts and Craft 

Board at the U.S. Department of the Interior and others.

57 Organizations and individuals can download, print, and order free FTC publications on scams, privacy, credit, and 

other topics at FTC’s Bulk Order website. See https://www.bulkorder.ftc.gov. 
20

sections include a sampling of the FTC’s consumer education resources and how AI/AN 

organizations have used them. 

A.New Dedicated Page for AI/AN Communities

To complement the Agency’s work, to better serve AI/AN communities, and as directed 

by Congress, the FTC has launched an informational website at ftc.gov/NativeAmerican. The 

resources found here help the Agency better reach and respond to the needs of AI/AN

populations. This website serves as a landing page for consumer and business education 

resources related to the topics identified above — for example, financing a car, managing debt, 

and predatory lending — helping AI/AN individuals and organizations access information from 

the FTC that is relevant to them. 

Because many of the topics identified during listening sessions were financial in nature, 

ftc.gov/NativeAmerican includes information from FTC’s Money Matters website,58 which 

features advice on protecting your money from scams. Topics include scams related to prizes and 

grants; buying and renting a home; debt and debt relief; shopping; car buying; looking for a job;

education and training; and consumer credit. The information at ftc.gov/NativeAmerican is easy 

to share and the FTC encourages partners to link to it from their own websites, share the articles 

and graphics on social media, and use the content in their newsletters and other communication 

channels. These efforts help amplify scam avoidance and protection messages to AI/AN 

communities, with the added benefit of having the information delivered by sources that are 

trusted in those communities. In addition, ftc.gov/NativeAmerican links to ready-to-use 

presentations that community educators, advocates, and other stakeholders can use in their own 

education programs. The materials are free of cost and available in English and Spanish. 

A frequent suggestion from partner organizations and tribal leaders is providing resources 

in AI/AN languages. The FTC acknowledges the interest in and demand for in-language 

resources and has discussed with many partners the challenges of meeting this interest. For 

example, the many Native languages spoken in the United States59 create challenges of scope, 

breadth, and dissemination; the Agency has limited human and financial resources to translate 

and share resources in print and online through well-maintained outreach channels. The FTC’s 

response thus far has been to encourage partners to adopt and customize FTC educational 

resources. This has several advantages for AI/AN communities: partners trusted in those 

58 See FTC Consumer Advice, Native American Communities: Spot, Avoid, and Report Scams (Mar. 2023), 

available at https://www.ftc.gov/NativeAmerican. See FTC Consumer Advice, Money Matters: How to Spot, Avoid, 

and Report Scams (Dec. 2022), available at https://www.ftc.gov/moneymatters (English) and

https://www.ftc.gov/asuntosdedinero (Spanish). The site was updated and relaunched in December 2022.

59 The U.S. Census American Community Survey (ACS) codes 169 Native North American languages. See U.S. 

Census American Community Survey Brief, Native North American Languages Spoken at Home in the United 

States and Puerto Rico: 2006 – 2010 (Dec. 2011), available at https://www2.census.gov/library/publications/2011/

acs/acsbr10-10.pdf.
21

communities deliver the messages; they can customize the messages and adapt materials into the 

language most appropriate for their audience; and they can add contacts for local reporting or 

assistance. The success of this approach can be seen in the example of the Arizona-based KWLP 

radio station, which serves the Hualapai Tribe, recently translating into Hualapai and airing a 

radio advertisement from the FTC.

B.Sampling of the FTC’s Consumer Education

Resources

1. Consumer Alerts

The FTC regularly publishes Consumer Alerts60 in English and Spanish about the latest 

scams, including advice on what people can do to protect themselves. Throughout the past year, 

these have covered many of the topics identified by organizations as impacting AI/AN 

populations including, among others, business and government impersonators, romance and

prize scams, and gift card scams. 

The FTC emails Consumer Alerts, in 

English and Spanish, to more than 413,000

subscribers, including individuals, community 

groups, advocates, national and local news 

media outlets, and other stakeholders. The FTC 

also publishes these Alerts on its consumer

websites, consumer.ftc.gov and 

consumidor.ftc.gov, as well as through social 

media platforms, so the public can read, link 

to, and easily share fraud prevention 

messages.61 In addition to discussing how to 

spot and avoid scams, the FTC uses its 

Consumer Alerts to highlight important events: for example, an Alert honoring American Indian 

and Alaska Native Heritage Month,

62 which highlighted the importance of sharing information to 

support communities and the people in them. 

Social Media Image Shared with FTC 

Consumer Alert Published November 2022

60 Consumer Alerts available at https://consumer.ftc.gov/consumer-alerts (English) and https://consumidor.

ftc.gov/alertas-para-consumidores (Spanish).

61 Information about subscribing to Consumer Alerts available at https://www.ftc.gov/ConsumerAlerts (English) 

and https://www.ftc.gov/AlertasDeConsumidor (Spanish).

62 See FTC Consumer Alert, Honoring American Indian and Alaska Native Heritage Month (Nov. 10, 2022), 

available at https://consumer.ftc.gov/consumer-alerts/2022/11/honoring-american-indian-and-alaska-nativeheritage-month.
22

The FTC encourages partners to sign up to receive Consumer Alerts and share them 

through their own communication channels. By doing so, partners stay informed about scams

and can amplify messages to the people they serve. Several organizations share FTC Consumer 

Alerts on social media. For example, in October 2022, the American Indian Higher Education 

Consortium shared a Consumer Alert about avoiding scams following the Administration’s 

announcement about student loan forgiveness.

63 And in September 2022, the NLC shared a 

Consumer Alert with information on the FTC’s redress program for former customers of Tate’s 

Auto dealerships.64

2. Pass It On Campaign

As previously mentioned, during listening sessions and in surveys, many people 

expressed concern about scammers targeting older adults in their communities. In fact, many 

said they personally knew older adults who had lost money to scammers. 

Pass It On65 is the FTC’s ongoing fraud prevention education campaign designed 

specifically for older adults. It is also one of the Agency’s most popular campaigns: since its 

launch in 2014, the FTC has distributed 17.2 million Pass It On items, including more than 1.6 

million items in fiscal year 2022. The free English and Spanish print materials are regularly 

requested by groups including banks, libraries, police departments, adult protective service 

offices, state attorneys general, military support groups, and educational and community groups 

nationwide — showing the value of having both print and digital options available for this 

demographic.

Campaign materials show respect for older adults’ life experiences and accumulated 

knowledge, supplying them with resources to read and pass on to family and friends, with the 

aim of starting conversations about fraud. The factsheets, bookmarks, videos, presentations, and 

other materials refresh and add to readers’ knowledge by briefly explaining how certain scams 

work and what the reader can do in response. The catalog of print and online material addresses 

13 common frauds,

66 several of which were identified by AI/AN partners as problematic in their 

communities — including romance scams, government impersonator scams, and unwanted calls 

63 See FTC Consumer Alert, Student loan scammers are circling. Keep them at bay (Oct. 3, 2022), available at

https://consumer.ftc.gov/consumer-alerts/2022/10/student-loan-scammers-are-circling-keep-them-bay.

64 See FTC Consumer Alert, FTC returns money to customers of deceptive auto dealerships (Sept. 15, 2022), 

available at https://consumer.ftc.gov/consumer-alerts/2022/09/ftc-returns-money-customers-deceptive-autodealerships. 

65 Pass It On campaign materials are available online at https://www.ftc.gov/PassItOn (English) and

https://www.ftc.gov/Pasalo (Spanish) and print versions are available for order at https://www.ftc.gov/bulkorder.

66 The full list of the topics featured in the Pass It On campaign include business impersonator scams, charity fraud, 

government impersonator scams, grandkid and family scams, health insurance scams, home repair scams, identity 

theft, investment scams, job, money-making scams. romance scams, tech support scams, unwanted calls and text 

messages, and “You’ve Won” scams, available at https://consumer.ftc.gov/features/pass-it-on. 
23

and text messages. Online resources include a presentation on each topic, including both slides 

and a script, to allow for easy sharing by partners. Pass It On campaign materials are available 

online and can be ordered in print for free.

67

3. Consumer.gov

The FTC’s consumer.gov website focuses on three topic areas: Managing Your Money; 

Credit, Loans and Debt; and Scams and Identity Theft. Consumer.gov (and consumidor.gov in 

Spanish) gives people consumer protection basics in straightforward language, easily navigated 

design, with increased accessibility through an audio read along of the content, and information 

in video for learners who benefit from a different style of information delivery. The site also 

includes related lesson plans for each topic area. Many of the AI/AN organizations that FTC staff

have partnered with (outlined in the following sections) offer financial literacy trainings and 

other forms of technical assistance to individuals on reservations and in urban areas. Several of 

these noted that the resources at consumer.gov are particularly useful.

The FTC plans to expand the usefulness of consumer.gov by updating both content and 

navigation, with input from its target audience, including organizations serving AI/AN 

populations.

4. Protecting Small Businesses 

Small businesses are integral to all communities, including AI/AN communities: 

according to the U.S. Census’ Annual Business Survey, in 2020 there were close to 40,400 

AI/AN-owned businesses, with about 244,000 employees and $9.6 billion in annual payroll.

68

Protecting small businesses, including those that are AI/AN-owned, is a priority for the Agency. 

FTC outreach and education resources for small businesses on common scams69 and data 

security issues,70 available in English and Spanish, address the needs of AI/AN entrepreneurs. 

For example, Cybersecurity for Small Business materials provide information on a wide range of 

cybersecurity issues faced by small businesses, including what to do if your business has been 

67 Pass It On campaign materials are available online at https://www.ftc.gov/PassItOn (English), https://www.ftc.

gov/Pasalo (Spanish), and can be ordered in print at https://www.ftc.gov/bulkorder.

68 See Census Bureau Press Release, Census Bureau Releases New Data on Minority-Owned, Veteran-Owned and 

Women-Owned Businesses (Nov. 10, 2022), available at https://www.census.gov/newsroom/press-releases/2022/

annual-business-survey-characteristics.html.

69 See FTC Business Center, Scams and Your Small Business: A Guide for Business (May 2018), available at

https://www.ftc.gov/tips-advice/business-center/guidance/scams-your-small-business-guide-business (English) and 

https://www.ftc.gov/es/guia-para-negocios/las-estafas-y-su-pequeno-negocio-una-guia-para-los-negocios (Spanish).

70 See FTC Business Center, Cybersecurity for Small Business (October 2018), available at https://www.ftc.gov/

tips-advice/business-center/small-businesses/cybersecurity (English) and https://www.ftc.gov/es/guia-paranegocios/protegiendo-pequenos-negocios/ciberseguridad (Spanish).
24

targeted by ransomware, hackers, or scammers. As previously mentioned, these were cited as 

concerns by a number of organizations serving AI/AN-owned businesses. As a result of FTC 

staff outreach, the Dineh Chamber of Commerce, which represents businesses owned and 

operated on or near the Navajo Nation, invited FTC staff to present on cybersecurity issues to its 

Executive Committee.71

In addition to the above, the BCP’s Business Blog72 is a practical way for executives and 

entrepreneurs alike to get the latest word on topics that matter to them, including alerts about 

scams targeting small businesses. With more than 120,000 subscribers, the Business Blog 

explains what FTC cases mean for business and provides insights into FTC developments in data 

security and consumer privacy, credit and finance, advertising law, and other areas essential for 

businesses.

V. Law Enforcement Affecting AI/AN 

Populations

Aggressive law enforcement is a key component in the FTC’s efforts to protect 

consumers, including AI/AN consumers. Deliberate efforts are necessary to ensure the FTC’s 

law enforcement efforts are responsive to the needs of the diverse communities the Agency 

serves. To this end, the FTC has developed targeting and tracking tools to help identify potential 

case leads. For example, consumer reports about marketing practices, which are collected 

through the Sentinel database, provide an important source of information for law enforcement 

purposes. By analyzing these reports, the FTC can illuminate trends and disparities, identify 

problematic business practices and enforcement targets, and develop cases against targets under 

investigation. The FTC will work to increase reporting of fraud and other consumer issues by 

AI/AN individuals, including by engaging with community-based organizations to use 

ReportFraud.ftc.gov to access information on how to try to recover money lost.

A.Related Casework

The FTC has brought numerous cases — a few of which are summarized below —

relating to consumer abuses identified earlier in this report as impacting AI/AN communities.

1. Auto Buying and Financing Issues

For many, buying a car is one of the most expensive purchases they make. According to 

the USDA’s Economic Research Service, American Indians are the only minority group with a 

71 See Appendix C for event materials. 

72 The FTC’s Business Blog is available at https://www.ftc.gov/business-guidance/blog.
25

higher rural than urban share of the population,

73 so may be more reliant on cars for their 

transportation needs.74 AI/AN partners have also highlighted auto buying and financing, 

describing related consumer protection issues as problems impacting these communities. 

In Tate’s Auto, for example, the FTC charged a group of four auto dealers operating in 

Arizona and New Mexico, near the border of the Navajo Nation, with a range of illegal 

activities.75 These included falsifying consumers’ income and down payment information on 

financing applications and disseminating deceptive ads offering vehicles for sale, financing, and 

lease. Many of Tate’s Auto customers were members of the Navajo Nation, and the dealerships 

frequently ran radio and print ads in Navajo media. Tate’s Auto routinely assigned sales 

associates to visit the Navajo Reservation and solicit finance applications from consumers as 

they went about their daily activities. Indeed, a 2014 report by the Navajo Nation Human Rights 

Commission found that it received more complaints about Tate’s Auto than any other dealership.

The FTC’s complaint identified a variety of practices that prevented consumers from 

understanding and reviewing income and down payment information in connection with 

financing a vehicle. In numerous instances, Tate’s Auto employees filled out the contract 

documents and then presented them to the consumer while distracting, pressuring, and rushing 

them into signing papers. Approximately 57% of Tate’s Auto consumers who funded their 

purchase through Tate’s primary finance company defaulted on their loans, and they were about 

10% more likely to default than consumers at other similarly situated dealerships.

The allegedly deceptive advertising employed by Tate’s Auto took various forms. For 

example, one YouTube ad claimed the featured car “can be in your driveway for only $169 per 

month.”76 In fact, though the ad offered the car for purchase or lease, consumers could not buy 

that car for the advertised monthly payment — that amount applied only to a lease. In addition, 

the ad did not adequately disclose that, to get that monthly payment, consumers had to pay 

$2,899 plus other fees at lease signing. Another online ad listed an “incentive” discount of 

$5,250. However, buried behind multiple hyperlinks was the fact that the discount was available 

only to consumers who traded in a vehicle or terminated a lease from another car company 30 

days before or 90 days after delivery. Tate’s Auto’s social media posts also failed to disclose 

73 See John Cromartie and Dennis Vilorio, Rural Population Trends (Feb. 15, 2019), available at https://www.ers.

usda.gov/amber-waves/2019/february/rural-population-trends/.

74 See Jeremy Mattson and Dilip Mistry, Rural Transit Factbook 2022 (Apr. 2022), available at https://www.ugpti.

org/resources/reports/details.php?id=1058.

75 FTC v. Tate’s Auto Ctr., No. 3:18-cv-08176 (D. Ariz. filed July 31, 2018), available at https://www.ftc.gov/

enforcement/cases-proceedings/162-3207/tates-auto-center.

76 See id., Complaint ¶ 38, available at https://www.ftc.gov/system/files/documents/cases/tates_automotive_

complaint.pdf.
26

terms required under the Truth in Lending Act and the Consumer Leasing Act, according to the 

complaint. 

The FTC settled with and obtained a monetary judgment of $7.2 million against the 

dealerships, which were liquidated in Chapter 7 bankruptcy. The Agency subsequently settled 

with the individual defendant in the case, who was the owner and manager of the auto group, for 

$450,000. On September 15, 2022, the FTC distributed close to 3,500 redress checks to Tate’s 

Auto consumers who obtained financing and subsequently had their cars repossessed. During the 

redress process the FTC provided phone support and had live agents available to answer 

questions in Navajo related to the case and the refund program. This was accomplished in great 

part thanks to the collaboration of the Navajo Nation Human Rights Commission. The FTC 

wishes to acknowledge their valuable assistance during the investigation of this case, the redress 

process, and beyond. The FTC continues to work with the Navajo Nation Human Rights 

Commission to resolve individual consumer challenges related to getting or cashing payments.

In Napleton, a case brought jointly with the Illinois Attorney General, the FTC alleged 

that Napleton’s parent company, Ed Napleton Automotive Group, and eight of its dealerships

engaged in discrimination by charging Black consumers disproportionately more for markups 

and add-ons — like payment insurance or paint protection.77 The FTC alleged these differences 

could not be explained by factors related to underwriting risk or credit characteristics of the 

applicants.

According to the joint complaint, the dealerships also used tactics like waiting until the 

end of the hours-long car-buying process to illegally tack on junk fees for unwanted add-ons into 

consumers’ contracts, even after consumers specifically declined the products or confirmed 

prices that did not include them. In other instances, consumers were lied to about the add-ons 

being free or required to purchase or finance the vehicle. A survey of Napleton's consumers cited 

in the complaint showed that the vast majority of buyers — over 80 percent — were charged for 

add-ons without authorization or as a result of deception.

Napleton will pay a $10 million judgment to settle the lawsuit brought by the FTC and 

the State of Illinois, a record-setting monetary judgment for an FTC auto lending case. Almost 

all of that amount will be used to redress consumers.

In Passport Auto Group, the FTC alleged that the defendant charged Black and Latino 

consumers more in fees and interest rate markups than White consumers.

78 This practice violated 

77 See FTC Press Release, FTC Takes Action Against Multistate Auto Dealer Napleton for Sneaking Illegal Junk 

Fees onto Bills and Discriminating Against Black Consumers (Apr. 1, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/04/ftc-takes-action-against-multistate-auto-dealer-napleton-sneaking-illegal-junkfees-bills.

78 See FTC Press Release, Federal Trade Commission Takes Action Against Passport Automotive Group for 

Illegally Charging Junk Fees and Discriminating Against Black and Latino Customers (Oct. 18, 2022), available at

https://www.ftc.gov/news-events/news/press-releases/2022/10/federal-trade-commission-takes-action-againstpassport-automotive-group-illegally-charging-junk-fees.
27

the Equal Credit Opportunity Act, which makes it illegal to discriminate in any aspect of a credit 

transaction based on things like race, national origin, and age, among others, and also was unfair. 

In addition, the FTC alleged that Passport misrepresented the prices it advertised for 

particular used vehicles. The company frequently charged consumers hundreds or thousands of 

dollars in additional fees, making the total price of the car substantially higher than advertised. 

The FTC also alleged that Passport lied to consumers about certain fees being required, such as 

certification, reconditioning, and inspection fees, when, in reality, they were just bogus fees that 

Passport had already included in its advertised price. 

The order requires Passport to pay $3.38 million dollars to refund consumers and requires 

each Passport dealership location to either charge no financing markup or charge the same 

markup rate to all consumers.

2. Predatory Lending and Other Financial Issues 

In LendingClub, the FTC alleged that the online lender falsely promised loan applicants 

they would receive a specific loan amount with “no hidden fees,” when in reality the company 

deducted hundreds or even thousands of dollars in hidden upfront fees from consumers’ loans.79

The FTC also alleged that LendingClub told consumers they were approved for loans when they 

were not and took money from their bank accounts without authorization. LendingClub was

required to pay $18 million, almost all of which was returned to consumers.80 The final order 

settling the case also bars the company from making misrepresentations to loan applicants and

requires that the company clearly and conspicuously disclose the amount of any prepaid, upfront, 

or origination fee and the total amount of funds that borrowers will receive.

Most recently, in Credit Karma, the FTC issued a final order resolving allegations that 

the company deployed dark patterns in offers that misrepresented consumers’ pre-approval status 

for third-party financial products, such as credit cards.81 The complaint alleged that the financial 

product companies had not pre-approved these consumers, and that, in many instances, almost a 

third of people who applied for these offers were denied. The complaint further alleged that 

Credit Karma knew — based on the results of experiments known as A/B testing — that its 

prominent pre-approval claims conveyed false “certainty” to consumers. However, it continued 

to use these claims deliberately to influence consumers’ behavior. The FTC also alleged that in 

cases in which the company revealed that the consumers’ approval was not certain, it still 

79 See FTC Press Release, FTC Charges Lending Club with Deceiving Consumers (Apr. 25, 2018), available at 

https://www.ftc.gov/news-events/press-releases/2018/04/ftc-charges-lending-club-deceiving-consumers-0.

80 See FTC Legal Library, LendingClub Corporation (last updated Jan. 18. 2022), available at https://www.ftc.gov/

legal-library/browse/cases-proceedings/162-3088-lendingclub-corporation.

81 See FTC Press Release, FTC Takes Action to Stop Credit Karma From Tricking Consumers With Allegedly False 

“Pre-Approved” Credit Offers (Sep. 1, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/09/ftc-takes-action-stop-credit-karma-tricking-consumers-allegedly-false-pre-approved-credit-offers.
28

misrepresented that consumers’ likelihood of approval was 90% or buried the information in 

disclaimers.

Credit Karma is paying $3 million in monetary relief for consumers who wasted time 

applying for the offers, and the company is prohibited from making deceptive approval-related 

claims. In addition, to help prevent future use of deceptive dark patterns, Credit Karma must 

preserve records of any market, behavioral, or psychological research, or user, customer, or 

usability testing, including any A/B testing.

The FTC has also brought multiple law enforcement actions against companies that make 

false promises of debt relief to consumers dealing with financial insecurity. For example, in 

ACRO, the FTC alleged that the defendants falsely promised to eliminate or substantially reduce 

credit card debts in 12-18 months and charged illegal fees.82 In another recent case, Home 

Matters, the FTC’s complaint alleges the scammers charged consumers thousands of dollars for 

the false promise of negotiating better mortgage terms.83 The FTC has also successfully sued 

companies that have preyed on consumers with student loan debt. In Elegant Solutions, for 

example, the agency prevailed in a $27 million case against an operation that falsely promised to 

obtain low student loan payment terms and pretended to be federal loan servicers in order to 

collect and divert consumers’ student loan payments into their own coffers.84 

3. Tech Support

The FTC also files actions to shutter types of outright fraud, such as tech support scams.

In Elite IT Partners, the FTC alleged that the company used Internet ads to target those looking 

for help recovering their email passwords.85 People who responded to Elite’s ads were 

encouraged to provide their names, email addresses, and phone numbers. Elite’s telemarketers 

then reached out to people — often pretending to be associated with well-known companies —

and pressured them to provide access to their computers. The telemarketers ran bogus 

“diagnostic” tests, claimed the computers and personal information were in danger, and 

convinced many people to pay large sums for immediate cleaning of their computers, antivirus 

software, and ongoing technical support services. The FTC alleged that the scheme affected tens 

82 See FTC Press Release, FTC Halts Debt Relief Scheme that Bilked Millions from Consumers While Leaving Many 

Deeper in Debt (Nov. 30, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/11/ftchalts-debt-relief-scheme-bilked-millions-consumers-while-leaving-many-deeper-debt.

83 See FTC Press Release, Federal Trade Commission, California Take Action To Shut Down Mortgage Relief 

Operation that Preyed on Struggling Homeowners (Sept. 19, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/09/federal-trade-commission-california-take-action-shut-down-mortgage-reliefoperation-preyed.

84 See FTC Legal Library, Elegant Solutions, Inc. (Mission Hills Federal) (last updated Jul. 14, 2022), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3105-elegant-solutions-inc-mission-hills-federal.

85 See FTC Press release, FTC Halts Tech Support Scam as Part of Major Initiative Focused on Older Adults Hit 

Hardest by These Scams (Mar. 7, 2019), available at https://www.ftc.gov/news-events/news/pressreleases/2019/03/ftc-halts-tech-support-scam-part-major-initiative-focused-older-adults-hit-hardest-these-scams.
29

of thousands of individuals. Since settling the case, the FTC has distributed hundreds of 

thousands of dollars in redress payments to consumers.

86

4. Internet Services

In Frontier Communications, the FTC alleged that the company — which provides 

internet service in many rural areas, including some tribal lands,87 over copper telephone wires 

— in many cases misrepresented its Internet speeds to customers. As part of Frontier’s joint 

settlement with the FTC and California it is required to, among other things, substantiate its 

Internet speed claims to new and existing customers and notify them when it is unable to do so; 

notify customers who are currently receiving copper Internet service at speeds slower than 

advertised; and allow those customers to change or cancel their service at no charge.

B.Relevant Rulemakings

The FTC has issued four notices of proposed rulemaking related to issues identified as 

impacting AI/AN communities and which would provide the Agency with better tools to

enhance its law enforcement work in these areas. 

1. Impersonation

As previously mentioned, according to FTC data, government impersonators are the top 

fraud type reported to the agency by people living in majority AI/AN communities. It’s also a 

top fraud reported to the FTC by all other communities year after year. This particular fraud has 

cost consumers more than $1.4 billion in the past five years.88 The FTC issued a Notice of 

Proposed Rulemaking89 to address deceptive or unfair acts or practices relating to impersonation 

fraud (“Impersonation NPRM”). The proposed rulemaking is aimed at combating government 

and business impersonation fraud. Government and business impersonators can take many 

forms, posing as government officials or representatives from well-known businesses or 

charities, for example. These fraudsters take people’s money, but also sometimes personal 

86 See FTC Press release, FTC Sends Refunds Totaling Nearly $300,000 to People who Lost Money to a Tech 

Support Scheme (Oct. 12, 2021), available at https://www.ftc.gov/news-events/news/press-releases/2021/10/ftcsends-refunds-totaling-nearly-300000-people-who-lost-money-tech-support-scheme.

87 See Frontier, Rural Broadband Deployment: Connecting the Navajo Nation (Aug. 23, 2019), available at

https://frontier.com/corporate/responsibility/policy-blog/navajo-nation.

88 See Federal Trade Commission, Explore Government Imposter Scams, Tableau Public (last visited Mar. 6, 2023), 

available at https://public.tableau.com/app/profile/federal.trade.commission/viz/GovernmentImposter/Infographic.

89 See FTC Press release, FTC Proposes New Rule to Combat Government and Business Impersonation Scams

(Sept. 15, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/09/ftc-proposes-new-rulecombat-government-business-impersonation-scams. 
30

information that they can use to commit identity theft. The FTC is reviewing and analyzing 

comments from the public to determine whether to issue a rule. The proposed rule, if adopted,

would give the FTC additional tools to fight scammers and return money to consumers harmed 

by impersonators, including people in AI/AN communities.

2. Junk Fees 

The FTC has also issued an Advanced Notice of Proposed Rulemaking90 to address “junk 

fees,” which are unnecessary, unavoidable, or surprise charges that inflate costs while adding 

little to no value for consumers (“Junk Fees ANPR”). Such fees are frequently bundled as 

ancillary products in conjunction with large or complicated purchases and loans, including auto 

financing — an issue that advocates highlighted as having a particular impact on AI/AN 

populations. The FTC will review comments to the Junk Fees ANPR to determine whether and 

how a rule on junk fees could address widespread unfair or deceptive practices affecting 

consumers, including AI/AN populations.

3. Telemarketing of Tech Support Services

As noted above, one type of scam affecting tribal communities is tech support fraud, 

where scammers convince consumers that there are problems with their computers, and they 

should buy tech support services or software that they do not need. In April 2022, the FTC issued 

an Advance Notice of Proposed Rulemaking91 seeking comment on whether the Telemarketing 

Sales Rule should be expanded to apply explicitly to inbound telemarketing of tech support 

services. The FTC will review comments to the ANPR to determine whether and how 

rulemaking under the Telemarketing Sales Rule could explicitly address tech support fraud 

caused by inbound telemarketing.

4. Auto 

The FTC also issued a Notice of Proposed Rulemaking to protect consumers in the motor 

vehicle buying and leasing process.92 As discussed above, the FTC has brought many 

enforcement actions against dealers engaged in deceptive or unfair practices, including bait and 

90 See FTC Press Release, Federal Trade Commission Explores Rule Cracking Down on Junk Fees (Oct. 20, 2022), 

available at https://www.ftc.gov/news-events/news/press-releases/2022/10/federal-trade-commission-explores-rulecracking-down-junk-fees.

91 See FTC Press release, Federal Trade Commission Proposes Small Business Protections Against Telemarketing 

Tricks and Traps (Apr. 28, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/04/

federal-trade-commission-proposes-small-business-protections-against-telemarketing-tricks-traps.

92 See FTC Press Release, FTC Proposes Rule to Ban Junk Fees, Bait-and-Switch Tactics Plaguing Car Buyers

(June 23, 2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/06/ftc-proposes-rule-banjunk-fees-bait-switch-tactics-plaguing-car-buyers.
31

switch advertising, and cramming hidden charges.93 In spite of these actions, complaints from 

consumers related to automobiles remain in the top ten complaint types received by the FTC, 

with more than 100,000 complaints from consumers annually over the past three years. The FTC 

is reviewing and analyzing comments from the public to determine whether to issue a rule. The 

proposed rule, if adopted, would prohibit dealers from making a number of false promises to lure 

in prospective buyers and would ban dealers from charging fees for add-on products and services 

that provide no benefits to consumers. 

VI. Recommendations

The FTC is committed to protecting AI/AN individuals, and all people, from scams, 

frauds, and bad business practices. As outlined in previous sections, the FTC found that people 

living in AI/AN communities experience many of the same scams that people in other 

communities face. The FTC will continue to fight these scams by using all the tools at its 

disposal: law enforcement actions, outreach and education efforts, and research. The FTC is also 

committed to continue improving its targeting abilities to find appropriate cases for law 

enforcement actions to stop scams, frauds, and bad business practices impacting AI/AN 

communities. To accomplish this, the FTC will not only study and analyze the reports that come 

in from AI/AN communities, but also continue meaningful community engagement and dialog as 

well as conduct and encourage research to deepen its understanding of disparities in AI/AN 

communities. This will also include strengthening existing relationships, and forming new 

partnerships, with agencies at the federal, state, and local levels to further encourage information 

sharing, case referrals, and the opportunity to collaborate on matters whenever possible and 

logical.

A.Continue to Fight Lawbreaking through Enforcement

The FTC will continue to fight against the frauds and scams facing AI/AN populations, 

and return money to those affected, when possible. However, the FTC’s ability to seek monetary 

relief for harmed consumers is now substantially limited following the 2021 United States 

Supreme Court ruling in AMG Capital Mgmt. This held, among other things, that the FTC did 

not have authority to seek equitable monetary relief in cases brought under Section 13(b) of the 

93 See also, e.g., Complaint, FTC v. Liberty Chevrolet, Inc., No. 1:20-cv-03945 (S.D.N.Y. May 21, 2020) (alleging 

deceptive and unauthorized add-on charges in consumers’ transactions); Complaint, FTC v. Universal City Nissan, 

Inc., No. 2:16-cv-07239 (C.D. Cal. Sept. 29, 2016) (alleging dealerships claimed consumers could finance the 

purchase of vehicles with attractive terms and buried disclosures indicating such terms were applicable to leases 

only, and alleging deceptive and unauthorized add-on charges in consumers’ transactions); Complaint, In re 

Progressive Chevrolet Co., No. C-4578 (F.T.C. June 13, 2016) (alleging deceptive failure to disclose material 

conditions of obtaining the lease monthly payment in their online and print advertising); Complaint, In re Timonium 

Chrysler, Inc., No. C-4429 (F.T.C. Jan. 28, 2014) (alleging dealership advertised internet prices and dealer discounts 

but failed to disclose consumer would have to qualify for multiple rebates not generally available to them); 

Complaint, In re Ganley Ford West, Inc., No. C-4428 (F.T.C. Jan. 28, 2014) (alleging dealership advertised 

discounts on vehicle prices, but failed to disclose discounts were only available on the most expensive models).
32

FTC Act. Prior to this ruling, the FTC had used its Section 13(b) authority to provide billions of 

dollars in monetary restitution to consumers affected by unfair or deceptive acts or practices, 

including people in historically underserved communities. Following the AMG decision, the 

Agency is constrained in its ability to obtain redress for consumers and has sought to increase the 

tools at its disposal to do so.

B.Continue Education and Outreach Efforts 

The Agency will continue to disseminate messaging and create education campaigns to 

alert the public, including AI/AN communities, about spotting, avoiding, and reporting scams, 

frauds, and bad business practices. Through the FTC’s ftc.gov/NativeAmerican landing page, 

Consumer Alerts, and other outreach tools, the agency will continue to spread consumer 

protection messages on government impersonator scams; prize, sweepstakes, and lottery scams;

romance scams; and the many other scams and practices identified by AI/AN communities. The 

Agency will also continue sharing relevant consumer education messaging directly and through 

community media. These efforts will increase the visibility not only of scams but of the Agency 

and the importance of reporting, which could lead to further law enforcement cases.

The FTC will also continue collaborations and dialogue with trusted partners to reach 

AI/AN communities in meaningful and informative ways. While there are limitations on the 

FTC’s ability to provide in-language consumer education resources, the FTC will continue to

collaborate with partners to identify opportunities in which we can work together to disseminate

information in a way that is welcomed and well-received by these communities.

C.Conduct and Encourage Further Research 

Further research on the impacts of deception, fraud, and bad business practices on AI/AN 

populations would help the FTC identify effective methods for combating these practices. The 

FTC is committed to review and analysis of consumer reports in the Sentinel database, as well as 

case and refund data, with a focus on identifying trends and disparities related to fraud and other 

issues impacting AI/AN communities. The FTC encourages related research by industry, experts, 

advocates, and other stakeholders to improve understanding about the impacts of consumer fraud 

on AI/AN populations and guide strategies to fight these impacts.
33

VII. Appendix

A.Selected Recent Listening Sessions with AI/AN 

Advocates, Organizations, Tribal Government 

Representatives, and U.S. Government Agencies

FTC Office Organization Date

Division of Consumer and 

Business Education (DCBE) National Indian Child Care Association (NICCA) June 7, 2022

DCBE Association for American Indian Affairs (AAIA) June 23, 2022

Northwest Region (NWR) Yakama Nation Member and Tribal Liaison, 

Washington State Office of the Attorney General July 13, 2022

DCBE National Center for American Indian Enterprise 

Development (NCAIED) Jul 19, 2022

Western Region Los Angeles

(WRLA)

Redding Rancheria Tribe (Chief Executive Officer) July 27, 2022

DCBE Native American Financial Officers Association 

(NAFOA) Aug 12, 2022

DCBE National Council of Urban Indian Health (NCUIH) Aug 16, 2022

Midwest Region (MWR) Prairie Band Potawatomi Nation, Kansas (Member) Aug 26, 2022

MWR Mni Sota Fund Aug 30, 2022

Southeast Region (SER) North Carolina Commission of Indian Affairs Aug 30, 2022

MWR Kentucky Indigenous Peoples Sept 1, 2022

DCBE American Indian Higher Education Consortium (AIHEC) Sept 4, 2022

WRLA ASU Indian Legal Clinic (Director) Sept 6, 2022

Western Region San Francisco 

(WRSF) First Nations Development Institute Sept 9, 2022

MWR The Christensen Fund/Tribal Judicial Support Clinic, KU 

Law Sept 9, 2022

MWR Native Governance Center Sept 9, 2022

WRLA/WRSF American Indian Chamber of Commerce of California Sept 14, 2022

WRSF California Department of Consumer Affairs Tribal 

Liaison Sept 20, 2022

NWR Northwest Justice Project Oct 5, 2022

East Central Region (ECR) Michigan Indian Legal Services Dec 1, 2022

DCBE Division of Economic Development, Bureau of Indian 

Affairs, U.S. Department of the Interior Dec 14, 2022

WRLA/WRSF California Indian Legal Services Multiple contacts

WRLA DNA People’s Legal Services Multiple contacts

MWR Native CDFI Network/Native360 Loan Fund Multiple contacts

DCBE Native Learning Center (NLC) Multiple contacts

WRLA/Southwest Region 

(SWR) Navajo Nation Human Rights Commission Multiple contacts
34

SWR/ DCBE Oklahoma Native Assets Coalition (ONAC) Multiple contacts

DCBE Office of Native American Programs, U.S. Department 

of Housing and Urban Development Multiple contacts

WRLA Southern California American Indian Resource Center Multiple contacts

B.Selected Recent Outreach Events by FTC Staff 

FTC Office Name of 

Event/Organization Location Date Description

DCBE Dineh Chamber of 

Commerce Virtual Aug 8, 2022

FTC staff presented on scams targeting 

small businesses, cybersecurity 

resources, and how to report fraud 

during Chamber of Commerce meeting.

SWR/

Division of 

Privacy and 

Identity 

Protection 

(DPIP)

Southwestern 

Association of 

American Indian Art’s 

(SWAIA) 100th Annual 

Indian Market

Santa Fe, NM

Aug

20-21, 

2022

As they have in previous years, FTC staff 

attended and distributed consumer 

education materials on identity theft, 

laptop security, money matters, and 

purchasing authentic Native American 

arts and crafts.

SER

Eastern and 

Midwestern 

Conference on the 

Workforce Innovation 

and Opportunities Act

Myrtle Beach, 

SC

Sept 12, 

2022

FTC staff presented during a training 

session for Native American jobseekers 

and members of tribal government 

employment offices.

DCBE Native Learning 

Center (NLC) Virtual Oct 1, 2022

FTC staff recorded four episodes of 

NLC's podcast and presented one 

webinar. Podcast episodes focused on 1) 

spotting, avoiding, and reporting scams; 

2) spotting and avoiding phone scams; 

and 3) avoiding bogus money-making 

schemes and business opportunities. 

The webinar focused on red flags when 

buying and financing cars.

DCBE

Native American 

Financial Officers 

Association (NAFOA)

Mashantucket, 

CT

Oct 2-3, 

2022

FTC staff attended NAFOA's annual 

conference and distributed FTC 

consumer education resources to 

attendees.

DPIP Indian Country Today 

(ICT) Virtual Oct 17, 2022

FTC staff were interviewed about 

avoiding identity theft and holiday 

shopping scams.
35

DPIP/SWR

Oklahoma Native 

Assets Coalition 

(ONAC)

Virtual Oct 19, 

2022

FTC staff co-hosted and presented a 

webinar on identity theft.

NWR

Alaska Federation of 

Natives Annual 

Convention

Anchorage, AK

Oct

20-21, 

2022

FTC staff distributed resources at a 

consumer information booth with the 

Indian Arts and Crafts Board.

WRSF

National Congress of 

American Indian's 

79th Annual 

Convention and 

Marketplace

Sacramento, 

CA

Nov 2, 

2022

Staff attended and made connections 

for outreach with the American Indian 

Chamber of Commerce, among others. 

This included plans for further outreach 

in 2023 with the Chamber's Education 

Fund.

WRLA/SWR DNA People’s Legal 

Services Virtual Nov 10, 2022

FTC staff invited a representative from 

DNA People’s Legal Services and a client 

from Navajo Nation to speak during the

FTC’s briefing for Native American 

media.

DCBE

Native American 

Media Outlets 

(multiple)

Virtual Nov 10, 

2022

FTC staff held a media briefing on scams 

and reporting fraud with Native 

American media.

MWR Native CDFI Network 

(NCN) Virtual Nov 10, 2022

FTC staff presented to NCN members on 

common scams and FTC resources.

MWR Minnesota Indian 

Affairs Council Virtual Nov 16, 2022

FTC staff presented at quarterly 

meeting.
36

C.Sampling of FTC Events Shared by Partners:

FTC Presentation to Dineh Chamber of Commerce

(Aug 2022) 
37

D.Sampling of FTC Events Shared by Partners: ONAC 

Webinar on Identity Theft and FTC Resources (Oct 

2022)
38

E. News Briefing for Native American Media: Invitation
39

F. Scripts for Live Announcer and Radio Spots Placed 

on AI/AN Media Outlets

Autos

15 seconds: You’ve probably seen those car ads — low price! low payments! But when you get 

to the dealer, there could be a catch. If a dealer isn’t honest when it comes to its car ads, tell the 

Federal Trade Commission at Report Fraud-dot-FTC-dot-gov. A message from the Federal Trade 

Commission.

30 seconds: You see the car ads — low price, low payments. Sounds good, but when you get to 

the dealer, there could be a catch. The dealer may try to add things like extra products or services 

— at extra cost. And to get that low monthly payment, you might have to make a big down 

payment. The bottom line is this: If you can’t get the advertised deal, or one you feel good about, 

walk away. If a dealer isn’t honest when it comes to its car ads, tell the Federal Trade 

Commission, the nation’s consumer protection agency, at Report Fraud-dot-FTC-dot-gov. A 

message from the Federal Trade Commission. 

Gift Card Scams 

15 seconds: What if someone said you owe money to the IRS and have to pay with a gift card? 

Or, they ask for a gift card so you can avoid going to jail. Stop! It’s a scam. Gift cards are for 

gifts, not payments. Report scams at Report Fraud-dot-FTC-dot-gov. A message from the 

Federal Trade Commission. 

30 seconds: What if someone said you owe money to the IRS and have to pay with a gift card? 

What if they ask for a gift card so you can avoid arrest, help a family member, or keep your 

Social Security benefits? No real business or government agency will ever tell you to pay with a 

gift card. Anyone who does is a scammer. Gift cards are for gifts, not for paying someone. If 

anyone tells you to pay with a gift card, tell the Federal Trade Commission, the nation’s 

consumer protection agency, at Report Fraud-dot-FTC-dot-gov. A message from the Federal 

Trade Commission.