Federal Trade Commission

October 18, 2022

Protecting 

Older 

Consumers 

2021–2022

A Report of the

Federal Trade Commission 
Protecting

Older Consumers

2021–2022

A Report of the Federal Trade Commission

October 18, 2022

FEDERAL TRADE COMMISSION

Lina M. Khan, Chair

Noah Joshua Phillips, Commissioner

Rebecca Kelly Slaughter, Commissioner

Christine S. Wilson, Commissioner

Alvaro M. Bedoya, Commissioner
Contents

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

II. FTC Enforcement Activities Affecting Older Consumers...........................2

A. Enforcement Actions.......................................................................................................3

B. Case Resolutions .............................................................................................................6

C. Other Enforcement Highlights ........................................................................................9

1. Covid-19 Demand Letters...........................................................................................9

2. Consumer Monetary Relief.......................................................................................11

3. Criminal Liaison Unit ...............................................................................................15

4. Referrals to the FBI’s Recovery Asset Team ...........................................................16

D. FTC Strategies to Provide Additional Tools to Enhance FTC Enforcement Efforts....18

1. Advance Notice of Proposed Rulemaking on Impersonation of

Government and Business.........................................................................................18

2. Advance Notice of Proposed Rulemaking on Deceptive or

Unfair Earnings Claims.............................................................................................20

3. Advance Notice of Proposed Rulemaking on the Telemarketing Sales Rule...........21

III. Outreach and Education Activities ..............................................................22

A. Pass It On Education Campaign....................................................................................22

B. Outreach Relating to Older Adults................................................................................23

1. AARP members........................................................................................................24

2. Senior Medicare Patrol Volunteers...........................................................................24

3. Members of Congress...............................................................................................24

4. Consumer Financial Protection Bureau, SAGE, and others.....................................24

5. Older Adult Advocates and Allied Professionals .....................................................24

C. Pandemic Response.......................................................................................................25

IV. Developing Effective Strategies to Protect Older Consumers...................26

A. Research and Data Analysis..........................................................................................26

1. Consumer Sentinel Reports from Older Adults........................................................27
2. Analysis of Social Security Administration Scam Reports......................................43

3. Hearing Directly from Older Adults About FTC Impersonators..............................45

B. Coordinated Efforts to Protect Older Consumers..........................................................46

V. Conclusion.......................................................................................................48

Appendix A - Federal Trade Commission FY 2022 ...........................................49
FEDERAL TRADE COMMISSION FTC.GOV 1

I. Introduction 

The Federal Trade Commission (“FTC” or “Commission”) is the nation’s primary 

consumer protection agency and has a broad mandate to protect consumers from unfair and 

deceptive acts or practices in the marketplace. Protecting older consumers1 continues to be one 

of the FTC’s top priorities, which it pursues using a multi-pronged approach.

2 First, it files law 

enforcement actions to stop unlawful practices and, when possible, return money to consumers.3

Given the ongoing global health crisis, the FTC continues to focus on schemes that capitalize on 

the fears and economic uncertainty of the pandemic to deceptively peddle products related to the 

prevention and treatment of COVID-19. This year the FTC also initiated several important 

rulemakings on topics impacting older adults to bolster its ability to return money to consumers 

in light of the impact of the Supreme Court’s ruling in AMG Capital Management v. FTC.

4

Second, the FTC continues to employ innovative education and outreach campaigns that 

reach older adults throughout the country. These important efforts help consumers protect 

themselves against emerging frauds and alert them to prevalent consumer protection issues. As 

the population of older adults grows, the FTC’s outreach mission to help consumers protect 

themselves and their communities becomes increasingly important.5

 

1 This report refers to persons 60 and older when using the terms “older adults” or “older consumers” to be 

consistent with the requirements in Section 2(1) of the Elder Abuse Prevention and Prosecution Act, which 

references Section 2011 of the Social Security Act (42 U.S.C. 1397j(5)) (defining “elder” as an individual age 60 or 

older).

2 This report focuses on the Bureau of Consumer Protection’s work to protect older adults. The FTC’s Bureau of 

Competition also serves older adults through its work in various sectors of the economy, such as health care, 

consumer products and services, technology, manufacturing, and energy. The primary drafters of this staff report are 

Michelle Chua, Division of Marketing Practices; Emma Fletcher, Division of Consumer Response and Operations; 

and Bridget Small, Division of Consumer and Business Education. Additional acknowledgement goes to Kati 

Daffan, Patti Poss, and Patricia Hsue, Division of Marketing Practices; Karen Mandel and Christine DeLorme, 

Division of Advertising Practices; Jennifer Leach and Marlena Patterson, Division of Consumer and Business 

Education; Shiva Koohi and Michel Grosz, Bureau of Economics; and Summer Law Clerk Tyler Ritchie. This report 

reflects the work of staff throughout the Federal Trade Commission’s Bureau of Consumer Protection and its 

Regional Offices, with much of the work stemming from the FTC’s Every Community Initiative. Lois C. Greisman 

is the FTC’s Elder Justice Coordinator. 

3 The FTC has wide-ranging law enforcement responsibilities under the Federal Trade Commission Act, 15 U.S.C. § 

41 et seq. and enforces a variety of other laws ranging from the Telemarketing and Consumer Fraud and Abuse 

Prevention Act to the Fair Credit Reporting Act. In total, the Commission has enforcement or administrative 

responsibilities under more than 70 laws. See http://www.ftc.gov/ogc/stats.shtm. 

4 AMG Capital Mgmt., LLC v. FTC, 593 U. S. ___; 141 S. Ct. 1341 (2021) (holding that Section 13(b) of the FTC 

Act does not authorize federal courts to require defendants to refund monies to consumers or give up unjust gains).
FEDERAL TRADE COMMISSION FTC.GOV 2

Finally, the FTC conducts research and collaborates with a diverse array of partners, which

inform the strategies it employs to help ensure that its efforts achieve the maximum benefits for 

consumers, including older adults. For example, the FTC’s analysis of fraud and other reports 

filed by consumers nationwide helps the agency understand and respond to patterns and trends 

related to older adults, including the differences in how older adults in different demographic 

populations may experience fraud. 

The FTC submits this fifth annual report to the Committees on the Judiciary of the United 

States Senate and the United States House of Representatives to fulfill the reporting requirements 

of Section 101(c)(2) of the Elder Abuse Prevention and Prosecution Act of 2017.6 The report 

details the FTC’s recent comprehensive efforts to protect older consumers. The report also 

includes, pursuant to the law’s requirements, a list in Appendix A of every administrative and 

federal district court action filed in the last year that has impacted older adults.7

II. FTC Enforcement Activities Affecting Older 

Consumers 

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

consumers. Nearly all FTC enforcement actions involve numerous consumers of all ages, and 

while the actual ages of people affected in a given case are not typically known, in the 

Commission’s view, older adults are among those affected in every consumer protection case 

filed this past fiscal year. Therefore, Appendix A to this report lists all new enforcement actions 

brought by the FTC between October 1, 2021, and September 30, 2022. The cases listed in 

Appendix A involve a wide range of matters, including allegations regarding money transfer 

services, business opportunity and money-making schemes, unsubstantiated product claims, false 

claims about COVID-19 treatment or prevention, and more.8

5 The Census Bureau projects that by 2030 all baby boomers will be older than 65 and “one in every five Americans 

is projected to be [at] retirement age.” See Jonathan Vespa, Lauren Medina, and David M. Armstrong, U.S. Dep’t of 

Commerce, U.S. Census Bureau, Demographic Turning Points for the United States: Population Projections for 

2020 to 2060 (Mar. 2018, Rev. Feb. 2020), at 1, available at

https://www.census.gov/content/dam/Census/library/publications/2020/demo/p25-1144.pdf. 

6 Public Law 115–70, 115th Congress (enacted Oct. 18, 2017).

7 The law requires the FTC Chair to file a report listing the FTC’s enforcement actions “over the preceding fiscal 

year in each case in which not less than one victim was an elder or that involved a financial scheme or scam that was 

either targeted directly toward or largely affected elders.” Given the large number and broad range of consumers 

affected in FTC actions, this report includes, in Appendix A, a list of every administrative and federal district court 

action filed in the one-year period.

8 This list includes cases involving violations of children’s privacy laws. The perpetrators of such schemes may not 

typically target older adults, but the cases are listed because they involve large and diverse groups of consumers. 

The affected consumers may include an older parent or grandparent caring for children who go online and wish to 

protect their privacy.
FEDERAL TRADE COMMISSION FTC.GOV 3

This section highlights five enforcement actions filed within the last fiscal year where the 

Commission notes a significant impact on older adults. Also listed are additional agency actions 

that affected older consumers, including case resolutions, cease and desist demand letters, 

consumer refunds, and subsequent criminal action by other agencies relating to FTC matters. 

This section also describes the Commission’s issuance of three advance notices of proposed 

rulemakings (“ANPRs”), as part of its ongoing efforts and strategies to provide better tools to 

enhance its law enforcement efforts. It discusses how the three proposed rulemakings are 

relevant to certain critical areas that heavily impact older adults. 

A. Enforcement Actions

The Commission filed the following new enforcement actions in the last fiscal year that 

likely had a significant impact on older adults: 

In Walmart Inc., the FTC sued Walmart for alleged practices that allowed its money 

transfer services to be used for fraud.9

 The complaint asserted, among other things, that older 

consumers were financially exploited by telemarketing scams that made use of money transfers 

from Walmart stores. The FTC complaint alleged, 

In many cases, older consumers (ages 65 and older) have been financially exploited by 

sending money transfers in connection with common telemarketing scams, such as 

grandparent scams,10 Good Samaritan scams, lottery or prize scams, and romance scams, 

from Walmart locations. The average loss suffered by older consumers is usually greater 

than for younger consumers. In addition, perpetrators of the scams, or those acting on 

their behalf, including fraud rings and money mules, frequently collect the proceeds of 

the frauds from Walmart locations, and in some instances, those individuals have even 

been employees of Walmart. 

The complaint further stated that among all of MoneyGram’s complaints of fraud that involved

Walmart from 2013 to 2018, MoneyGram reported 19,035 complaints about person-in-need or 

grandparent scams, more than any other single category. The complaint also alleged that at one 

location in Teterboro, New Jersey, 72.6 percent of complaints about fraud-induced transfers 

involved the grandparent or emergency scam. 

Money transfers have long been a common vehicle for fraud targeting older consumers. 

According to the FTC’s complaint, Walmart has been a particularly popular processor for 

fraudulent money transfers, in large part because of Walmart’s ineffective, poorly enforced anti9 FTC v. Walmart Inc., No. 1:22-cv-3372 (N.D. Ill., filed June 28, 2022) (The Commission vote to file the civil 

penalty complaint was 3-2.), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3012-

walmart-ftc-v. 

10 In a “grandparent scam,” the caller pretends that a relative is in distress due to a legal or medical emergency and 

asks the victim to send money immediately.
FEDERAL TRADE COMMISSION FTC.GOV 4

fraud policy.11 The FTC alleged that many of the Walmart staff handling money transfers had 

insufficient training or no anti-fraud training at all; Walmart employees were told “If you suspect 

fraud, complete the transaction.” Walmart allegedly adopted this practice despite knowing that 

once the money transfers were paid out to suspected fraudsters, fraud victims usually could not 

get their money back. The FTC is seeking to obtain redress for consumers, as well as

civil penalties.

In Universal Guardian Acceptance, LLC (“UGA”), the FTC brought an action against 

defendants that had allegedly serviced and funded payment plans for expensive and often 

ineffective investment “trainings.”12 The case arose out of previously settled litigation against 

Online Trading Academy (“OTA”), a company that allegedly targeted older consumers with an 

investment trading strategy based on false or unfounded earnings claims.13 According to the 

FTC, OTA had secured payment through the use of short-term, high-interest retail installment 

contracts.14 The FTC alleged that UGA facilitated OTA’s deceptive scheme by underwriting, 

funding, and servicing OTA’s retail installment contracts. The FTC further alleged that UGA 

ignored red flags that OTA was engaged in deception, including consumer complaints, a high 

cancellation rate, and the fact that the vast majority of purchasers were not paying off their debt 

within the six month no-interest grace period included in the contracts. The terms of the 

settlement required the UGA defendants to offer debt forgiveness to OTA purchasers whose debt 

was held by UGA. The settlement also requires the defendants to screen prospective clients that 

claim consumers can make money using their products or services, and to monitor such clients’ 

transactions and business practices.

In Gravity Defyer, the FTC filed suit against a footwear company, claiming that the 

company made deceptive pain relief claims about its products.15 The FTC alleged that the 

defendants targeted older adults suffering from arthritis, joint pain, and other medical 

conditions.16 The company claimed in its marketing to offer “clinically proven pain defying 

11 Press Release, FTC, FTC Sues Walmart for Facilitating Money Transfer Fraud That Fleeced Customers Out of 

Hundreds of Millions (June 28, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/06/ftc-sues-walmart-facilitating-money-transfer-fraud-fleeced-customers-out-hundreds-millions. 

12 FTC v. Universal Guardian Acceptance, LLC, No. 21-8260 (C.D. Cal., filed Oct. 19, 2021), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/2123021-universal-guardian-acceptance-llc. 

13 FTC v. OTA Franchise Corporation, No. 8:20-cv-287 (C.D. Cal., filed Feb. 12, 2020), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3175-x200032-online-trading-academy. 

14 Press Release, FTC, Funder and Servicer of Online Trading Academy Payment Plans Will Forgive Debt in 

Settlement with FTC (Oct. 21, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/funder-servicer-online-trading-academy-payment-plans-will-forgive-debt-settlement-ftc. 

15 FTC v. Gravity Defyer Medical Technology Corporation, No. 1:22-cv-01464 (D.D.C., filed May 25, 2022), 

available at https://www.ftc.gov/legal-library/browse/cases-proceedings/1923117-gravity-defyer-ftc-v. 
FEDERAL TRADE COMMISSION FTC.GOV 5

footwear,” but the FTC asserted that it lacked competent and reliable scientific evidence to 

support such a claim. According to the FTC complaint, the defendants claimed that the unique 

technology in the soles of their shoes would relieve knee, back, and foot pain, as well as pain in 

people suffering from plantar fasciitis, arthritis, joint pain, and heel spurs. The owner of Gravity 

Defyer was previously barred from deceptive advertising by a 2001 FTC order, and the FTC

alleged that the Gravity Defyer advertisements were violations of that order.

Excerpt of Advertisement from Gravity Defyer17

False claims about COVID-19 treatment and prevention products continue to pose a 

threat to the health and finances of older adults.18 In two instances, the FTC has used its 

16 Press Release, FTC, Federal Trade Commission Sues Gravity Defyer and its Owner for Violating FTC Order and 

Making Baseless Pain-Relief Claims to Market Footwear (June 7, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/06/federal-trade-commission-sues-gravity-defyer-its-owner-violating-ftc-ordermaking-baseless-pain-relief-claims. 

17 FTC v. Gravity Defyer, supra n.15, Complaint ¶ 25, Exhibit B.

18 Not only are older adults more likely to get sick from COVID, they are also more likely to face drastic healthrelated consequences as a result. See Center for Disease Control and Prevention Guidance (Updated Aug. 2, 2021), 

available at https://www.cdc.gov/coronavirus/2019-ncov/need-extra-precautions/older-adults.html.
FEDERAL TRADE COMMISSION FTC.GOV 6

authority under the COVID-19 Consumer Protection Act to seek civil penalties in actions against 

entities for deceptively pitching products that purported to treat or cure COVID-19. 

In Xlear, Inc., the FTC asserted that the defendant falsely marketed its nasal sprays as 

effective ways to prevent and treat COVID-19.19 According to the FTC, Xlear promoted its 

sprays by falsely claiming they can provide four hours of protection against infection from the 

coronavirus and called them “a simple, safe, and cheap option that could be an effective solution 

to the pandemic,” among other claims.20 Another ad claimed that “Xlear nasal spray provides 

additional tested protection for up to four hours, helping keep you and others around you safe.” 

The FTC alleged that the defendants’ advertising grossly misrepresented the purported findings 

and relevance of several scientific studies. Even after a warning letter from the FTC in 2020 to 

stop its unlawful advertising, the defendants continued to make such statements on their website 

and social media pages, even modifying or removing the unlawful claims, only to reinstate them 

or add additional deceptive statements later, according to the complaint. The lawsuit was filed by 

the Department of Justice on the behalf of the FTC and asks for monetary penalties and an order 

barring the defendants from making false and unsupported claims. 

In B4B Earth Tea LLC, the Department of Justice filed a complaint on behalf of the FTC 

and FDA alleging that the defendants had falsely claimed their product was clinically proven to 

treat, cure, and prevent COVID-19.21 According to the complaint, the defendants claimed that 

the defendants’ tea, which sells for $60 for a 16-ounce bottle, could cure COVID-19 in 24 to 48 

hours.22 Ads claimed that the tea was completely effective at preventing hospitalization (“100% 

effective with 0 side effects”) and specifically claimed that it was better than vaccination 

(“Vaccines trial shows preventing hospitalization is 85%-96% while so far Earth Tea Extra 

Strength is 100%...”). According to the complaint, those health claims were unsubstantiated 

because the single small study cited by the defendants did not meet the standard of competent 

and reliable scientific evidence. 

B. Case Resolutions 

The Commission reached resolution in four pending cases involving older adults in the 

last fiscal year.

19 U.S. v. Xlear, Inc., No. 2:21-cv-00640-RJS (D. Utah, filed Oct. 28, 2021), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/2123045-xlear-inc. 

20 Press Release, FTC, FTC Sues Utah-based Company for Falsely Claiming Its Nasal Sprays Can Prevent and 

Treat COVID-19 (Oct. 28, 2021), available at https://www.ftc.gov/news-events/news/press-releases/2021/10/ftcsues-utah-based-company-falsely-claiming-its-nasal-sprays-can-prevent-treat-covid-19. 

21 U.S. v. B4B Earth Tea LLC, no. 22-CV-1159 (E.D.N.Y., filed Mar. 3, 2022), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/2223007-b4b-corp. 

22 Press Release, FTC, FTC, DOJ, and FDA Take Action to Stop Marketer of Herbal Tea from Making False 

COVID-19 Treatment Claims (Mar. 3, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/03/ftc-doj-fda-take-action-stop-marketer-herbal-tea-making-false-covid-19-treatment-claims. 
FEDERAL TRADE COMMISSION FTC.GOV 7

In GDP Network LLC, the FTC and the Office of the Attorney General of Florida 

reached a settlement with the operators of an alleged credit card interest rate reduction scam.23

The complaint, filed in July 2020, alleged that the defendants made telemarketing calls in which 

they promised to permanently and substantially reduce the consumer’s credit card interest 

rates.24 After posing as representatives or affiliates of consumers’ credit card companies, the 

defendants allegedly claimed they could save consumers thousands of dollars in credit card 

interest, thereby allowing them to pay off their debt much faster. All these claims were false or 

unsubstantiated, according to the complaint. At most, the defendants sometimes opened new 

credit card accounts at low introductory rates and transferred consumers’ existing debt to the new 

cards. Instead of producing the savings that customers expected, the defendants’ service 

allegedly often left people even deeper in debt after they paid upfront fees of between $995 and 

$4,995, as well as substantial fees to transfer their existing debt to new cards. As part of the court 

order, the defendants will be permanently banned from the debt relief industry. According to the 

complaint, the defendants often targeted financially distressed consumers and older adults. 

In RagingBull.com, the FTC reached a settlement with an online stock trading site in a 

case filed in December 2020.

25 According to the complaint, the company falsely advised 

consumers that by joining its program they could make a substantial income without a lot of 

time, money, or experience.26 The complaint further alleged that the company made it difficult 

for consumers to cancel their subscriptions. According to the FTC, consumers lost more than 

$197 million in subscription fees for defendants’ services. Those consumers included retirees, 

older adults, and immigrants. As part of the stipulated final order, the Raging Bull defendants 

were required to pay over $2.4 million, end the earnings deception, get affirmative approval from 

customers for subscription sign-ups, and provide them with a simple method to cancel recurring 

charges. The FTC is planning to use funds collected in this matter to provide redress to

affected consumers.

23 Press Release, FTC, Operators of Credit Card Interest Rate Reduction Scam Permanently Banned from Debt 

Relief Business Under Settlement with the FTC and Florida Attorney General (Feb. 28, 2022), available at

https://www.ftc.gov/news-events/news/press-releases/2022/02/operators-credit-card-interest-rate-reduction-scampermanently-banned-debt-relief-business-under. 

24 FTC and Office of the Attorney General, State of Florida v. GDP Network LLC, no. 6:20-cv-1192-78DCI (M.D. 

Fla., filed July 6, 2020), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3137-gdpnetwork-llc-yf-solution. 

25 Press Release, FTC, Online Investment Site to Pay More Than $2.4 Million for Bogus Stock Earnings Claims and 

Hard-to-Cancel Subscription Charges (Mar. 8, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/03/online-investment-site-pay-more-24-million-bogus-stock-earnings-claims-hard-cancelsubscription. 

26 FTC v. RagingBull.com, No. 1:20-cv-3538 (Dec. 7, 2020), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/2023073-ragingbullcom. 
FEDERAL TRADE COMMISSION FTC.GOV 8

In Health Research Laboratories, LLC, the FTC settled an administrative complaint 

filed in 2020.27 The complaint alleged that the respondents marketed their supplements, the 

Ultimate Heart Formula, BG18, and Black Garlic Botanicals, as being able to prevent or treat 

cardiovascular disease, without appropriate substantiation.28 The FTC also alleged that

respondents made unsubstantiated claims that their supplement Neupathic could cure, mitigate, 

or treat diabetic neuropathy. The settlement banned the companies and their owner from 

advertising or selling dietary supplements and from making claims their products treat, cure, or 

reduce the risk of disease. In 2017, the owner of the companies and Health Research 

Laboratories had settled a previous complaint by the FTC and the State of Maine for deceptive 

marketing of health products. 

In Electronic Payment Systems (“EPS”), the FTC finalized an order against EPS for 

allegedly opening credit card processing merchant accounts for fictitious companies on behalf of 

Money Now Funding, a business opportunity scam that the FTC sued in 2013.29 In the Money 

Now Funding case, the FTC alleged that “many victims affected by this scam are seniors with 

limited income and savings.”30 In the FTC’s complaint against EPS, the FTC alleged that by

ignoring warning signs that the merchants were fake, EPS assisted and facilitated Money Now 

Funding in laundering more than $4.6 million of consumers’ credit card payments through 

different bank accounts for fictitious companies on behalf of the scammers from 2012 to 2013.31

Under the terms of the settlement order, the respondents are prohibited from providing payment 

processing services to any merchant that is, or is likely to be, engaged in deceptive or misleading 

conduct, and any merchant that credit card industry monitoring programs have flagged as highrisk for certain reasons. The respondents are also required to conduct detailed screening of 

potential merchants who conduct outgoing telemarketing or are engaged in certain activities that 

could harm consumers.32

27 In the Matter of Health Research Laboratories, LLC, No. 9397 (FTC filed Nov. 13, 2020), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/x180007-health-research-laboratories-llc-matter. 

28 Press Release, FTC, FTC Finalizes Order Banning Deceptive Marketing by Supplement Seller (June 30, 2022), 

available at https://www.ftc.gov/news-events/news/press-releases/2022/06/ftc-finalizes-order-banning-deceptivemarketing-supplement-seller?utm_source=govdelivery. 

29 Press Release, FTC, Federal Trade Commission Finalizes Order Against Electronic Payment Systems for 

Opening Credit Card Merchant Accounts for Fake Companies and Helping a Bogus Business Opportunity (May 24, 

2022), available at https://www.ftc.gov/news-events/news/press-releases/2022/05/federal-trade-commissionfinalizes-order-against-electronic-payment-systems-opening-credit-card. 

30 FTC v. Money Now Funding, LLC, No. CV-13-01583-PHX-ROS (D. Ariz., filed Aug. 5, 2013), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/122-3216-x130063-money-now-funding-llc. 

31 In the Matter of Electronic Payment Systems, LLC, No. C-4764 (FTC filed Mar. 15, 2022), available at 

https://www.ftc.gov/legal-library/browse/cases-proceedings/1523213-electronic-payment-systems-matter. 
FEDERAL TRADE COMMISSION FTC.GOV 9

C. Other Enforcement Highlights

Other FTC enforcement highlights during the past fiscal year include the issuance of 

cease and desist demand letters, providing consumer redress to consumers in cases previously 

brought by the FTC, and criminal action by other agencies that relate to prior FTC matters.

1. Covid-19 Demand Letters

Throughout the pandemic, the FTC has seen many potentially false and unsubstantiated 

claims about the treatment or prevention of COVID-19 that exploit consumers’ fear of the 

disease and its effects. As mentioned above, COVID-19 has had, and continues to have, a 

particularly devastating impact on the health and finances of older Americans. In some 

circumstances, to swiftly address troubling claims related to COVID-19, the FTC has sent cease 

and desist demand letters to companies and individuals. These letters warn recipients that their 

conduct is likely unlawful, and that they can face serious legal consequences, such as a federal 

lawsuit and civil penalties, if they do not immediately cease and desist from engaging in 

such conduct.33 

Since October 2021, the FTC has sent thirty one cease and desist demand letters to a 

range of companies and individuals about potentially false or deceptive advertising or marketing 

related to the coronavirus pandemic. Sixteen of these letters were sent jointly with the FDA. 

Almost all of the thirty one cease and desist demand letters went to companies allegedly 

violating the law by making deceptive or scientifically unsupported claims about their products’ 

ability to prevent, treat or cure the coronavirus. The unsubstantiated claims included patient 

testimonials and references to clinical trials or studies touting the products’ effectiveness against 

COVID-19, as described below. Although COVID-19 affects people of all ages, some of the 

letters highlighted examples of representations in the companies’ marketing that specifically 

related to older adults. For example: 

• In November 2021, the FTC sent a cease and desist demand letter to Austin 

Compounding Pharmacy based on its promotion of ivermectin and various supplements 

to prevent or treat COVID-19.34 The company made a Facebook post stating “Noone 

[sic] needs to die[.] Ivermectin does work.” Another Facebook post described a study of 

hospitalized “older patients” with COVID-19 that found that “patients aged 50 and 

32 Press Release, FTC, FTC Imposes Restrictions on Electronic Payment Systems for Opening Merchant Accounts 

for Fictitious Companies, Assisting a Business Opportunity Scam (Mar. 15, 2022), available at

https://www.ftc.gov/news-events/news/press-releases/2022/03/ftc-imposes-restrictions-electronic-payment-systemsopening-merchant-accounts-fictitious-companies. 

33 Information about the letters sent by the FTC can be found at https://www.ftc.gov/newsevents/features/coronavirus/enforcement/warning-letters. 

34 See FTC letter to Austin Compounding Pharmacy (Nov. 4, 2021), available at

https://www.ftc.gov/system/files/warning-letters/cease_and_desist_letter_to_austin_compounding_pharmacy_2021-

11-04_dap.pdf. 
FEDERAL TRADE COMMISSION FTC.GOV 10

above” who received vitamin supplements upon admission were less likely to require 

oxygen or be admitted to the intensive care unit. 

• Also in November 2021, the FTC sent a cease and desist demand letter to Sunshine 

Health Foods & Wellness Center challenging its social media claims about the efficacy 

of vitamins and supplements in preventing or curing COVID-19.35 For example, one 

Facebook post stated that “School is about to be back in session ... immune support is 

even more important this year with COVID-19,” and included the text of a previous post 

claiming their supplements would keep grandparents healthy. 

• In December 2021, the FTC sent a cease and desist demand letter to RhinoSystems Inc.

for its marketing of a nasal irrigation system to prevent and treat COVID-19.36 The

company sent an email to consumers claiming that a clinical trial had found “individuals 

age 55+” who were treated with nasal irrigation were 8.4 times less likely to be 

hospitalized or die. 

• Also in December 2021, the FTC sent a cease and desist demand letter to TerraMune 

Health, LLC, citing its claims about its ViralHalt Supplement, including calling it “A 

Natural Covid-19 Vaccine Alternative.” 37 Among other things, the company’s website 

provided a testimonial of two customers, identified as aged 76 and 78, reporting that they 

contracted COVID-19 and that their use of the company’s supplement “helped our bodies 

minimize our symptoms!”

• In February 2022, the FTC sent a cease and desist demand letter to Ohana 

Hyperbarics.

38 According to the FTC, the company’s website said that “Research 

around the US and Internationally is showing excellent results for those suffering with 

COVID-19 being treated with hyperbaric therapy.” One Instagram post shared an article 

reporting that a study found that hyperbaric treatment produced relief of COVID-19 

symptoms in a group of “predominantly men age 30 to 79.” 

35 See FTC letter to Sunshine Health Foods & Wellness Center (Nov. 4, 2021), available at

https://www.ftc.gov/system/files/warning-letters/cease_and_desist_letter_to_sunshine_health_food_2021-11-

04_dap.pdf. 

36 See FTC letter to RhinoSystems Inc. (Dec. 14, 2021), available at https://www.ftc.gov/system/files/warningletters/cease_and_desist_letter_to_rhinosystems_2021-12-14_dap.pdf. 

37 See FTC letter to TerraMune Health, LLC (Dec. 20, 2021), available at https://www.ftc.gov/system/files/warningletters/warning_letter-dap-terramune.pdf. 

38 See FTC letter to Ohana Hyperbarics (Feb. 22, 2022), available at 

https://www.ftc.gov/system/files/ftc_gov/pdf/2022-02-22%20DAP%20Ohana%20Hyperbarics.pdf. 
FEDERAL TRADE COMMISSION FTC.GOV 11

2. Consumer Monetary Relief

In the last fiscal year, FTC enforcement actions have resulted in relief of more than $462 

million to consumers of all ages.39 Although the FTC’s ability to seek monetary relief for harmed 

consumers is now substantially limited following the Supreme Court’s decision in AMG Capital 

Mgmt.,

40 the FTC continues to deliver refunds to consumers when possible. These payments 

provide people some recompense for the losses that occurred due to illegal conduct. 

In October 2021, the FTC began sending payments totaling $1.1 million to consumers 

who had paid for a business opportunity scheme called 8 Figure Dream Lifestyle.

41 According 

to the FTC, the company used a combination of illegal robocalls, live telephone calls, text 

messaging, internet ads, emails, social media, and live events to market and sell consumers 

fraudulent money-making opportunities. The FTC alleged that the defendants made false or 

unsubstantiated claims in their marketing about how much consumers could earn using their 

programs. According to the FTC complaint, the defendants “directly targeted older consumers 

who may need extra money for living expenses or retirement.”42 During one webinar, defendants 

targeted retirees with the tagline “Make sure those golden years are actually ‘Golden’!”

Later in October 2021, the FTC began sending checks totaling nearly $300,000 to people 

who paid Elite IT Partners Inc. for unnecessary computer repair services.43 According to the 

FTC, the company’s telemarketers claimed consumers’ computers and personal information 

were in imminent danger, and convinced many consumers to pay large sums for immediate 

cleaning of their computers, antivirus software, and ongoing technical support services. The 

complaint asserted that “the vast majority of consumers Elite contacts are elderly and/or 

unfamiliar with the workings of computers or the internet. Defendants use intimidation and scare 

tactics to take advantage of these consumers’ limited knowledge about such technology.”44 

39 The FTC provides updated statistics about where refunds were sent, the dollar amounts refunded, and the number 

of people who benefited from FTC refund programs at www.ftc.gov/refunds. 

40 AMG Capital Mgmt., 141 S. Ct. at 1341. See also discussion in Section II(D) below.

41 Press Release, FTC, FTC Returns $1.1 Million to Consumers Who Lost Money to Alleged Scammers Selling 

Bogus Income Opportunities (Oct. 4, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/ftc-returns-11-million-consumers-who-lost-money-alleged-scammers-selling-bogus-incomeopportunities. 

42 FTC v. 8 Figure Dream Lifestyle LLC, No. 8:19-cv-01165-AG-KES (C.D. Cal., filed June 12, 2019), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3117-8-figure-dream-lifestyle-llc. 

43 Press Release, FTC, 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/ftc-sendsrefunds-totaling-nearly-300000-people-who-lost-money-tech-support-scheme. 

44 FTC v. Elite IT Partners, Inc., No. 2:19-cv-00125-RJS (D. Utah, filed Feb. 25, 2019), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3114-elite-it-partners-inc. 
FEDERAL TRADE COMMISSION FTC.GOV 12

Also in October 2021, the FTC sent checks worth more than $1.1 million to consumers 

who purchased the supplements Neurocet, Regenify, and Resetigen-D from five related 

companies including Mile High Madison Group, Inc.45 The FTC alleged that the companies 

who marketed those supplements deceptively promoted their products using false or 

unsubstantiated claims that the supplements could stop pain and treat age-related ailments. For 

example, the complaint asserted that the defendants made false or unsubstantiated claims that 

their supplements could “repair or reverse age-related damage in human cells” and “repair or 

reverse all age-related health conditions,” including improving memory and brain function, and 

eliminate or significantly reduce arthritis and bone, joint, and muscle pain.46

In November 2021, consumers who purchased certain publications from Agora 

Financial LLC received full refunds totaling more than $2 million as the result of a stipulated 

final order.47 According to the FTC, the defendants convinced consumers to buy pamphlets, 

newsletters, and other publications through false promises and deceptive marketing. The refunds 

provided full compensation for consumers who bought certain publications. The FTC alleged 

that the defendants falsely marketed one publication as providing a clinically proven protocol 

that can permanently cure type 2 diabetes and falsely promised that another book would show 

consumers how to claim hundreds of thousands of dollars from the government. According to the 

FTC, the defendants primarily targeted their publications at older consumers nationwide. The 

defendants’ marketing included testimonials purporting to be from an 88-year-old retiree and a 

73-year-old retiree who had each made thousands of dollars.48 

In December 2021, the FTC sent checks totaling more than $1.8 million to people who 

were charged by Lifewatch Inc. for products that were advertised as free.49 The FTC joined with 

the Florida Attorney General’s Office to assert that the defendants had made at least one billion 

robocalls to pitch medical alert systems available to senior citizens “at no cost whatsoever.” The 

45 Press Release, FTC, FTC Sends Refunds to Consumers Who Bought Deceptively Marketed Supplements to Treat 

Pain and Age-related Health Conditions (Oct. 20, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/ftc-sends-refunds-consumers-who-bought-deceptively-marketed-supplements-treat-pain-agerelated. 

46 FTC v. Mile High Madison Group, Inc., No. 1:20-cv-21622-FAM (S.D. Fla., filed Apr. 17, 2020), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/172-3132-172-3143-nordic-clinical-inc-encore-plussolutions-inc. 

47 Press Release, FTC, FTC Sends Full Refunds Totaling Over $2 Million to Consumers who Lost Money Through 

Deceptive Direct Mail Publications Scheme (Nov. 2, 2021), available at https://www.ftc.gov/newsevents/news/press-releases/2021/11/ftc-sends-full-refunds-totaling-over-2-million-consumers-who-lost-moneythrough-deceptive-direct. 

48 FTC v. Agora Financial, LLC, No. 1:19-cv-03100-JMC (D. Md., filed Oct. 24, 2019), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/182-3116-agora-financial-llc. 

49 Press Release, FTC, FTC Issues Refunds Totaling More Than $1.8 Million to Consumers Defrauded by Lifewatch, 

Inc.’s Deceptive Medical Alert Telemarketing Scheme (Dec. 1, 2021), available at https://www.ftc.gov/newsevents/news/press-releases/2021/12/ftc-issues-refunds-totaling-more-18-million-consumers-defrauded-lifewatchincs-deceptive-medical. 
FEDERAL TRADE COMMISSION FTC.GOV 13

messages allegedly claimed that the system was endorsed or recommended by reputable 

organizations like the American Heart Association. According to the FTC, consumers eventually 

learned that they were responsible for monthly fees and that it was difficult to cancel without 

paying a penalty. The complaint alleged that “Many of the consumers who receive these 

unsolicited calls are elderly, live alone, and have limited or fixed incomes. They often are in poor 

health, suffer from memory loss or dementia, and rely on family members, friends, or health 

professionals to manage their finances and to make financial or health related decisions for 

them.”50

Also in December 2021, the FTC sent a second round of checks totaling more than $6.5 

million to people who lost money to an alleged debt relief scam orchestrated by Helping 

America Group.

51 The FTC first sent payments to affected consumers in July 2020. In total, the 

agency has mailed more than $20 million to consumers in this matter. According to a complaint 

by the FTC and the State of Florida, the defendants tricked consumers into paying hundreds of 

thousands of dollars per month under the false pretense that defendants would pay, settle, or 

obtain dismissals of customers’ debts and improve their credit.52 The complaint alleged that the 

affected consumers carried significant debt and included the elderly and disabled. 

In February 2022, the FTC began sending checks to consumers who had purchased 

indoor TV antennas or signal amplifiers from Wellco, Inc.53 The refunds total more than 

$580,000. The FTC alleged that the defendants had made deceptive performance claims and used 

deceptive consumer endorsements and web pages that looked like objective news reports to 

market their products. According to the complaint, the defendants claimed that their antennas 

would enable some consumers to receive one hundred or more premium channels in HD and that 

users of the antennas and related amplifiers would receive cable or subscription channels like 

HBO and AMC.54 One of their advertisements was titled “New York: Seniors Are Taking 

Advantage of New 2018 Rule That Allows Americans To Get FREE TV In HD, Causing 

Millions To Cancel Cable.”

50 FTC and State of Florida, Office of the Attorney General v. Lifewatch Inc., No. 1:15-cv-05781 (N.D. Ill., filed 

June 30, 2015), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/152-3216-x160047-lifemanagement-services-inc. 

51 Press Release, FTC, Helping America Group Refunds (Dec. 2021), available at

https://www.ftc.gov/enforcement/refunds/helping-america-group-refunds. 

52 FTC and State of Florida v. Jeremy Lee Marcus, No. 0:17-cv-60907-CMA (S.D. Fla., filed May 8, 2017), 

available at https://www.ftc.gov/legal-library/browse/cases-proceedings/162-3125-x170037-jeremy-lee-marcus-etal. 

53 Press Release, FTC, FTC Sending Refunds to Consumers who Bought Deceptively Marketed Indoor TV Antennas 

and Signal Amplifiers from Wellco, Inc. (Feb. 18, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/02/ftc-sending-refunds-consumers-who-bought-deceptively-marketed-indoor-tv-antennas-signalamplifiers. 

54 FTC v. Wellco, Inc., No. 1:21-cv-02081 (S.D.N.Y., filed Mar. 10, 2021), available at https://www.ftc.gov/legallibrary/browse/cases-proceedings/192-3004-wellco-inc-ftc-v. 
FEDERAL TRADE COMMISSION FTC.GOV 14

In April 2022, the FTC returned more than $23 million in redress to consumers who were 

allegedly defrauded by a business coaching scheme based out of Malaysia called My Online 

Business Education, or MOBE Ltd.55 The defendants made allegedly false claims that MOBE

would enable its members to start their own online businesses and earn substantial income 

quickly and easily using a “proven” 21-step system. The FTC asserted that the defendants’

international operation targeted U.S. consumers—including service members, veterans, and older 

adults—through online ads, social media, direct mailers, and live events held throughout the 

country. According to the complaint, the defendants created and promoted a system called the 

“Ultimate Retirement Breakthrough,” a re-branded version of the 21-step system aimed at older 

adults and retirees.56 A banner advertisement touted it as “The Surefire Way To Create A SixFigure Retirement Income In Less Than 12 Months.” 

Later in April 2022, the FTC sent checks totaling $423,000 to consumers who had 

purchased the purported anti-aging pill ReJuvenation from Quantum Wellness Botanical 

Institute, LLC and filed a valid claim with the FTC.

57 The FTC first sent refunds to consumers 

in June 2020. In total, the agency has mailed more than $556,000 to consumers in this matter. 

According to the FTC, the defendants marketed the pill as a cure-all for a range of age-related 

ailments, including cell damage, heart attack damage, brain damage, and deafness.58 For 

example, one challenged advertisement for ReJuvenation stated: “Flood your body with youth 

hormones ... NATURALLY! Increase your HGH up to 682% ... Stunning age reversal study: 

Stem cells boost life span three-fold ... Repair every aging cell in your body—damaged tissues 

and organs, too! Visibly fade wrinkles overnight.”59 Another challenged advertisement stated 

ReJuvenation would: “Rejuvenate every tissue, organ and gland of the body to levels you 

enjoyed when you were young ... Improve your skin’s elasticity and tone, thereby reducing 

wrinkles, furrows and lines ... Dramatically boost memory and mental clarity ... Slow down or 

even halt aspects of the normal aging process.” 

55 Press Release, FTC, Federal Trade Commission Returns More Than $23 Million To Consumers Deceived by 

Online Business Coaching Scheme MOBE (Apr. 5, 2022), available at https://www.ftc.gov/news-events/news/pressreleases/2022/04/federal-trade-commission-returns-more-23-million-consumers-deceived-online-business-coachingscheme. 

56 FTC v. MOBE Ltd., No. 6:18-cv-862-Orl-37DCI (M.D. Fla., filed June 4, 2018), available at

https://www.ftc.gov/legal-library/browse/cases-proceedings/172-3072-mobe-ltd-et-al. 

57 Press, Release, FTC, ReJuvenation Refunds (April 2022), available at

https://www.ftc.gov/enforcement/refunds/rejuvenation-refunds. 

58 Press Release, FTC, FTC Sending Refund Checks Totaling Almost $149,000 to Consumers Who Bought 

ReJuvenation “Anti-Aging” Pill (June 1, 2020), available at https://www.ftc.gov/news-events/news/pressreleases/2020/06/ftc-sending-refund-checks-totaling-almost-149000-consumers-who-bought-rejuvenation-antiaging-pill. 

59 FTC v. Quantum Wellness Botanical Institute, LLC, No. 2:20-cv-00244-SMB (D. Ariz., filed Feb. 3, 2020), 

available at https://www.ftc.gov/legal-library/browse/cases-proceedings/172-3131-quantum-wellness-botanicalinstitute-llc. 
FEDERAL TRADE COMMISSION FTC.GOV 15

In July 2022, the FTC began sending refunds to consumers who were allegedly defrauded 

by the Next-Gen sweepstakes scam.60 The FTC is sending almost $25 million to affected 

consumers in dozens of countries, including more than $18 million to U.S. consumers. 

According to the complaint filed jointly by the FTC and the State of Missouri, the defendants 

sent tens of millions of deceptive personalized mailers to consumers around the world since 

2013. The defendants’ mailers allegedly falsely told recipients they had won or were likely to 

win a substantial cash prize, as much as $2 million, in exchange for a fee ranging from $9.00 to 

$139.99. The FTC alleged that many consumers paid the defendants several times before 

realizing they had been scammed. According to the complaint, many of the victims were 

elderly consumers.61

3. Criminal Liaison Unit

The FTC’s Criminal Liaison Unit works with federal and state criminal prosecutors to 

better address consumer fraud.62 Notably, in November 2021, the Commission issued a policy 

statement to enhance its efforts to combat the criminal misconduct it uncovers in its consumer 

protection and antitrust investigations.63 Through this work, prosecutors have brought criminal 

cases built on facts the FTC exposed in bringing its civil law enforcement actions. 

For example, in March 2022, former FTC defendant Travis Peterson was sentenced to 

nearly three and a half years (41 months) in prison for a fraudulent charity scheme that targeted 

older adults.64 Peterson’s operation made millions of robocalls asking for donations and falsely 

claiming those donations were tax-deductible and would benefit veterans’ charities.65 The FTC’s 

60 Press Release, U.S. Federal Trade Commission Returning Almost $25 Million to Consumers Worldwide Who 

Were Defrauded by Next-Gen Sweepstakes Scheme (July 19, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/07/us-federal-trade-commission-returning-almost-25-million-consumersworldwide-who-were-defrauded-next?utm_source=govdelivery. 

61 FTC and State of Missouri ex rel. Hawley v. Next-Gen, Inc., No. 4:18-CV-00128-DGK (W.D. Mo., filed Sept. 24, 

2018), available at https://www.ftc.gov/legal-library/browse/cases-proceedings/172-3133-x180023-next-gen-inc.

62 Information about the FTC’s Criminal Liaison Unit is available at https://www.ftc.gov/enforcement/criminalliaison-unit. 

63 Commission Statement Regarding Criminal Referral and Partnership Process (Nov. 18, 2021), available at 

https://www.ftc.gov/system/files/documents/public_statements/1598439/commission_statement_regarding_criminal

_referrals_and_partnership_process_updated_p094207.pdf. 

64 Press Release, U.S. Department of Justice, Utah Man who Operated Fraudulent Veteran Charities Sentenced to 

Federal Prison (Mar. 29, 2022), available at https://www.justice.gov/usao-ndga/pr/utah-man-who-operatedfraudulent-veteran-charities-sentenced-federal-prison. 

65 Press Release, FTC, FTC Crackdown Stops Operations Responsible for Billions of Illegal Robocalls (March 26, 

2019), available at https://www.ftc.gov/news-events/news/press-releases/2019/03/ftc-crackdown-stops-operationsresponsible-billions-illegal-robocalls. 
FEDERAL TRADE COMMISSION FTC.GOV 16

action against Peterson was part of Operation Donate with Honor, a state-and-federal sweep 

combating fraudulent charities that claimed to help veterans and servicemembers.66

In 2022, Maricopa County Attorney’s Office in Arizona obtained guilty pleas against 

David Johnson and Brandon Randis, and sentenced Johnson to five years in prison, for their roles 

in a telemarketing scheme that targeted older adults, among others.67 The FTC previously sued 

the ringleaders of this operation, which tricked consumers into purchasing ecommerce websites 

through false promises of substantial income and a money-back guarantee.68 The FTC obtained 

more than $7 million in redress for consumers through the civil case.69 Maricopa County has 

obtained a total of 13 pleas in this criminal case to date, and the case is ongoing against the 

remaining defendants, including the former-FTC-defendant ringleaders.

Following extradition from Costa Rica, Jamaican nationals Derrick Levy and Maurice 

Levy pled guilty in January and June of 2022, respectively, for running a telemarketing scam 

targeting older adults in the United States.70 The scammers contacted their elderly victims by 

telephone and falsely claimed the individuals had won sweepstakes prizes, sometimes even 

impersonating FTC officials, to induce the victims to send “fees” in order to claim their prizes.71

The FTC provided assistance to DOJ in this case. 

4. Referrals to the FBI’s Recovery Asset Team

Since 2019, the FTC has referred reports involving high dollar losses to the Federal 

Bureau of Investigations (“FBI”) Internet Crime Complaint Center (IC3) Recovery Asset Team. 

This team’s goal is to “streamline communication with financial institutions and assist FBI field 

offices with the freezing of funds for victims who made transfers to domestic accounts under 

66 Press Release, FTC, FTC and States Combat Fraudulent Charities That Falsely Claim to Help Veterans and 

Servicemembers (July 19, 2018), available at https://www.ftc.gov/news-events/news/press-releases/2018/07/ftcstates-combat-fraudulent-charities-falsely-claim-help-veterans-servicemembers. 

67 Maricopa County Criminal Court Case Information (accessed July 5, 2022), available at

http://www.superiorcourt.maricopa.gov/docket/CriminalCourtCases/caseInfo.asp?caseNumber=CR2019-006125. 

68 Press Release, FTC, Business Opportunity Scheme Operators Banned from Telemarketing and Selling Investment 

Opportunities; Will Return Millions to Consumers (Mar. 13, 2017), available at https://www.ftc.gov/newsevents/press-releases/2017/03/business-opportunity-scheme-operators-banned-telemarketing. 

69 Press Release, FTC, FTC to Send Refund Checks to Consumers who Lost Money in Business Opportunity 

Telemarketing Scam (Mar. 5, 2019), available at https://www.ftc.gov/news-events/press-releases/2019/03/ftc-sendrefund-checks-consumers-who-lost-money-business. 

70 Press Release, U.S. Department of Justice, Two Men Plead Guilty to International Telemarketing Sweepstakes 

Fraud Scheme (June 30, 2022), available at https://www.justice.gov/opa/pr/two-men-plead-guilty-internationaltelemarketing-sweepstakes-fraud-scheme. 

71 Indictment, United States v. Levy, et al., Case No. 3:14-cr-143 (W.D.N.C. Aug. 5, 2014), available at

https://www.justice.gov/criminal-fraud/file/1395791/download. 
FEDERAL TRADE COMMISSION FTC.GOV 17

fraudulent pretenses.”72 The FTC refers reports received through its website and call center that 

meet certain criteria (typically larger dollar losses) to the FBI IC3 Recovery Asset Team when 

the consumer agrees to the referral. In the past year, the FTC has referred over 700 reports

through its Consumer Sentinel Network to the FBI IC3’s Recovery Asset Team for review and 

potential action. 

 In 2021, the FBI IC3 Recovery Asset Team responded to 1,726 incidents and froze an 

impressive $328.32 million of the $443.48 million reported losses, making recovery possible for 

many victims.73 Here are some recent success stories shared by the FBI IC3 Recovery

Asset Team: 

• In June 2022, an elder victim reported to the FTC that the victim had been contacted by 

an individual claiming to be from customer support at the victim’s bank. The subject then 

instructed the victim to complete a wire transfer to a fraudulent domestic account in order 

to “save their money.” Since the victim reported the incident quickly, the FBI IC3 

Recovery Asset Team was able to contact the recipient bank and freeze the full wired 

amount of almost $100,000 for possible recovery. 

• In May 2022, an elder victim reported to the FTC that the victim had been contacted by 

an individual claiming to be from McAfee Anti-Virus, claiming that their protection plan 

was due to update. The victim called the number contained in the spoofed email and gave 

the victim’s bank account access to the subject, where the subject then initiated a wire 

transfer for almost $50,000. Again, since the victim reported the incident quickly, the FBI 

IC3 Recovery Asset Team was able to contact the recipient bank and freeze the full wired 

amount for possible recovery. 

• Also in May 2022, an elder victim reported to the FTC that the victim had been contacted 

by an individual claiming to be from Amazon Support. The subject claimed that the 

victim had a fraudulent purchase on their account and threated they would be arrested if 

they did not complete a wire transfer in order to “protect their money.” The victim 

completed a wire to a fraudulent domestic account of almost $100,000. The FBI IC3 

Recovery Asset Team was able to contact the recipient bank and freeze a majority of the 

funds for possible recovery. 

The FTC is proud to partner with the FBI IC3’s Recovery Asset Team to help consumers, 

particularly those experiencing large dollar losses, recover funds when possible. 

72 Federal Bureau of Investigation Internet Crime Report 2021, Dept of Justice Federal Bureau of Investigation 

(2021) at 10 available at https://www.ic3.gov/Media/PDF/AnnualReport/2021_IC3Report.pdf. 

73 Id. at 11.
FEDERAL TRADE COMMISSION FTC.GOV 18

D. FTC Strategies to Provide Additional Tools to Enhance 

FTC Enforcement Efforts

In the past fiscal year, the FTC focused on developing additional tools to enhance its law 

enforcement efforts. These efforts were made in part as a result of a 2021 United States Supreme 

Court ruling in AMG Capital Mgmt., which 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 FTC 

Act.74 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 older adults.75 Following the AMG decision, the Commission is constrained in its 

ability to obtain redress for consumers and has sought to increase the tools at its disposal to do 

so. While additional tools to enhance the FTC’s enforcement efforts would affect all 

consumers,76 the particular initiatives described below apply to deceptive or unfair practices that

often disproportionately impact older adults, among other population segments. 

1. Advance Notice of Proposed Rulemaking on Impersonation of 

Government and Business

In December 2021, the FTC issued an Advance Notice of Proposed Rulemaking to 

address deceptive or unfair acts or practices relating to impersonation fraud (“Impersonation 

ANPR”).

77 The proposed rulemaking is aimed at combatting government and business 

impersonation fraud, a pernicious problem that has grown worse during the pandemic.78

74 AMG Capital Mgmt., LLC v. FTC, 141 S. Ct. 1341 (2021).

75 15 U.S.C. § 53(b). From FY 2017 to 2021, the Commission returned $11.4 billion to consumers across all FTC 

cases, including those brought solely under the FTC’s Section 13(b) authority.

76 In addition to the Commission’s rulemaking efforts, the FTC has also revitalized its authority to put bad actors on 

notice that their conduct violates the FTC Act by sending them a Notice of Penalty Offenses. These notices outline 

a number of practices that the Commission has previously found to be unfair or deceptive and highlight that 

engaging in this conduct could lead to civil penalties. See, e.g., Press Release, FTC, FTC Targets False Claims by 

For-Profit Colleges (Oct. 6, 2021), available at https://www.ftc.gov/news-events/news/press-releases/2021/10/ftctargets-false-claims-profit-colleges. 

77 Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901 (Dec. 23, 2021), 

available at https://www.federalregister.gov/documents/2021/12/23/2021-27731/trade-regulation-rule-onimpersonation-of-government-and-businesses. The FTC unanimously approved the ANPR earlier in December 

2021. See Press Release, FTC, FTC Launches Rulemaking to Combat Sharp Spike in Impersonation Fraud (Dec. 16, 

2021), available at https://www.ftc.gov/news-events/news/press-releases/2021/12/ftc-launches-rulemaking-combatsharp-spike-impersonation-fraud. 

78 Press Release, FTC, FTC Launches Rulemaking to Combat Sharp Spike in Impersonation Fraud. “The COVID-19 

pandemic has spurred a sharp spike in impersonation fraud, as scammers capitalize on confusion and concerns 

around shifts in the economy stemming from the pandemic. Incorporating new data from the Social Security

Administration, reported costs have increased an alarming 85 percent year-over year, with $2 billion in total losses 

between October 2020 and September 2021. Notably, since the pandemic began, COVID-specific scam reports have 

included 12,491 complaints of government impersonation and 8,794 complaints of business impersonation.” 
FEDERAL TRADE COMMISSION FTC.GOV 19

Government and business impersonators can take many forms, posing as government officials or 

representatives from well-known businesses or charities, for example. The perpetrators of 

impersonation fraud commonly seek monetary payment or information that they can use to 

commit identity theft. 

Government impersonators often pretend to represent institutions such as the Social 

Security Administration, Medicare/Health and Human Services, IRS, or law enforcement, and 

may threaten their targets with a discontinuation of government benefits, enforcement of tax 

liability, and even arrest or prosecution. Business impersonators may claim there is suspicious 

activity on a customer’s account or offer a refund or prize if the victim will provide some 

personal information. According to the FTC, the most common type of government 

impersonation fraud involved the Social Security Administration, with more than 308,000 

complaints between 2017 and 2021, more than twice the number of the next type.79 As discussed 

in Section IV, analysis of the FTC reports shows older adults reported tremendous losses to

impersonation scams, topping $151 million for business impersonation scams and $122 million 

for government impersonation scams in 2021.

With the Impersonation ANPR, the FTC seeks to determine if a Trade Regulation Rule 

targeting deceptive or unfair impersonation practices is warranted. The ANPR noted that while

the FTC in the past has brought many cases relating to impersonation under different authorities, 

it is currently limited in its remedial authority,

80 and solicited comment on whether the FTC 

should propose a rule that could more comprehensively outlaw government and business 

impersonation.81 The ANPR also sought comment on the prevalence of impersonation schemes, 

the costs and benefits of a rule to address them, and alternative or additional actions, such as 

publication of educational materials and hosting of public workshops. On September 15, 2022, 

79 Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901, 72902. “From 

January 1, 2017 through September 30, 2021, consumers reported 1,362,996 instances of government impersonation 

and associated total losses of roughly $922,739,109. The most common such schemes involved Social Security 

Administration (SSA) impersonators, with more than 308,000 complaints alleging SSA impersonation, followed by 

the IRS (124,000) and Health and Human Services/Medicare programs (125,000).”

80 See, e.g., Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901, 72902 

(“Although the Commission has brought many cases involving impersonator scams under Section 5 of the FTC 

ACT, 15 U.S.C. 45, its current remedial authority is limited. The U.S. Supreme Court recently held that equitable 

monetary relief, including consumer redress, is not available under Section 13(b) of the FTC Act.”).

81 Trade Regulation Rule on Impersonation of Government and Businesses, 86 Fed. Reg. 72901, 72903. “Both the 

Mortgage Assistance Relief Services (MARS) Rule and the Telemarketing Sales Rule (TSR) already proscribe 

impersonation involving false government and business (including nonprofit) affiliation and endorsement claims .... 

An impersonator rule that builds on the existing sector- and method-specific rules could more comprehensively 

outlaw government and business impersonation. By focusing on practices that are the subject of its law enforcement 

experience and the subject of consumer fraud reports, the Commission anticipates streamlining this proposed 

rulemaking for the benefit of consumers.”
FEDERAL TRADE COMMISSION FTC.GOV 20

the Commission approved a Notice of Proposed Rulemaking addressing impersonation of 

government and businesses.82

2. Advance Notice of Proposed Rulemaking on Deceptive or Unfair 

Earnings Claims

In March 2022, the FTC issued an Advance Notice of Proposed Rulemaking to address 

deceptive or unfair earnings claims (“Earnings Claims ANPR”).

83 This ANPR is aimed at 

misleading earnings claims, which both deprive consumers of the ability to make informed 

decisions and unfairly advantage bad actors in the marketplace at the expense of

honest businesses.84 

As prior FTC cases demonstrate, sales pitches containing deceptive earnings claims can 

appeal to retirees and older adults living on fixed incomes who are looking to supplement their 

income.85 The FTC has taken aggressive law enforcement action related to earnings claims made 

by targets engaged in coaching or mentoring schemes, multi-level marketing companies, workfrom-home, e-commerce, or other business opportunity scams, chain referral schemes, gig 

companies and employers, job scams, and businesses purporting to offer educational 

opportunities. However, despite the FTC’s aggressive enforcement program, deceptive earning 

claims continue to proliferate in the marketplace.86 

The FTC anticipates that a rule prohibiting the use of misleading earnings claims would 

enhance deterrence and help the FTC move quickly to stop illegal conduct. Such a rule may also 

further clarify for businesses what constitutes a deceptive earnings claim. In addition, a rule 

would enable the FTC to seek monetary relief for consumers harmed by deceptive earnings 

82 Press Release, FTC, 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. 

83 Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951 (Mar. 11, 2022), available at

https://www.federalregister.gov/documents/2022/03/11/2022-04679/deceptive-or-unfair-earnings-claims#. The FTC

unanimously approved the ANPR in February 2022. Press Release, FTC, FTC Takes Action to Combat Bogus 

Money-Making Claims Used to Lure People into Dead-end Debt Traps (Feb. 17, 2022), available at 

https://www.ftc.gov/news-events/news/press-releases/2022/02/ftc-takes-action-combat-bogus-money-makingclaims-used-lure-people-dead-end-debt-traps. 

84 The Earnings Claims ANPR follows the Commission’s announcement of a new Notice of Penalty Offenses 

Concerning Money-Making Opportunities in October 2021. The Commission served this notice on more than 1,100 

businesses, putting them on notice that if they deceive or mislead consumers about potential earnings, they could be 

subject to civil penalties. Press Release, FTC, FTC Puts Business on Notice that False Money-Making Claims Could 

Lead to Big Penalties (Oct. 26, 2021), available at https://www.ftc.gov/news-events/news/pressreleases/2021/10/ftc-puts-businesses-notice-false-money-making-claims-could-lead-big-penalties. 

85 Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951, 13952–53 n.23–33 (citing FTC v. OTA Franchise 

Corp., FTC v. Ragingbull.com, FTC v. Mobe Ltd., FTC v. 8 Figure Dream Lifestyle LLC, among others).

86 Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951, 13952. 
FEDERAL TRADE COMMISSION FTC.GOV 21

claims, as well as civil penalties against those who make the deceptive claims. The FTC has 

previously promulgated rules regulating the use of earnings claims in certain instances, 

including: The Franchise Rule, the Business Opportunity Rule, and the Telemarketing Sales 

Rule. However, the scope of coverage of these rules is limited.87

The FTC’s Earnings Claims ANPR requests input on whether and how it can most 

effectively use its authority to address the use of false, unsubstantiated, or otherwise misleading 

earnings claims. If promulgated, a rule in this area would allow the FTC to recover redress for 

defrauded consumers and seek significant penalties against those who make these claims. The 

FTC will determine whether to issue a notice of proposed rulemaking after it reviews the public 

comments it receives in response to the ANPR. 

3. Advance Notice of Proposed Rulemaking on the Telemarketing 

Sales Rule

In June 2022, the FTC issued an Advance Notice of Proposed Rulemaking seeking public 

comment on a number of possible amendments to the Telemarketing Sales Rule (“TSR”) (“ TSR 

ANPR”).

88 One of the major issues the TSR ANPR highlights is the rise of computer technical 

support scams (or “tech support services”) and the disproportionate impact on older adults.89 In 

many instances, these scams commence with an inbound call from a consumer to a telemarketer

who proceeds to deceive the consumer into purchasing unnecessary computer technology 

services to fix phantom problems. Such calls, however, are typically exempt from the TSR’s 

protections.90 

The TSR ANPR describes the Commission’s law enforcement experience addressing 

such scams and explains how they have been a rising trend that particularly impacts 

87 Deceptive or Unfair Earnings Claims, 87 Fed. Reg. 13951, 13952. “Numerous different types of enterprises that 

do not clearly fall under the scope of these existing rules continue to use misleading earnings claims to deceive 

consumers in violation of section 5.”

88 Telemarketing Sales Rule, 87 Fed. Reg. 33662 (June 3, 2022), available at

https://www.federalregister.gov/documents/2022/06/03/2022-10922/telemarketing-sales-rule. The FTC unanimously 

approved the ANPR in April 2022. Press Release, FTC, Federal Trade Commission Proposes Small Business 

Protections Against Telemarketing Tricks and Traps (April 28, 2022), available at https://www.ftc.gov/newsevents/news/press-releases/2022/04/federal-trade-commission-proposes-small-business-protections-againsttelemarketing-tricks-traps. The FTC also issued a concurrent Notice of Proposed Rulemaking (“TSR NPRM”) 

proposing additional amendments to the TSR. Telemarketing Sales Rule, 87 Fed. Reg. 33677 (June 3, 2022), 

available at https://www.federalregister.gov/documents/2022/06/03/2022-09914/telemarketing-sales-rule. 

89 The FTC’s last fraud survey found a higher prevalence for this type of fraud for older adults. FTC Bureau of 

Economics Staff Report, Mass-Market Consumer Fraud in the United States: A 2017 Update 76–79 (Oct. 2019), 

available at https://www.ftc.gov/system/files/documents/reports/mass-market-consumer-fraud-united-states-2017-

update/p105502massmarketconsumerfraud2017report.pdf. 

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

Tricks and Traps. 
FEDERAL TRADE COMMISSION FTC.GOV 22

older adults.91 It highlights the Commission’s analysis of consumer complaints about tech 

support scams showing they increased dramatically over the last few years, ranging from 

approximately 40,000 complaints in 2017 to approximately 100,000 complaints in 2020. Indeed, 

tech support scams disproportionately harm older consumers; in 2021, consumers age 60 and 

over were nearly five times more likely to report a financial loss to tech support scams compared 

to younger consumers.92 From 2015 to 2018, older adults filed more reports on tech support 

scams than on any other category.93

The TSR ANPR thus seeks comment on whether the Commission should amend the TSR 

to cover all deceptive telemarketing of tech support services. The FTC will determine whether to 

proceed with a notice of proposed rulemaking once it reviews the public comments submitted in 

response to the ANPR.

III. Outreach and Education Activities

A. Pass It On Education Campaign

Pass It On is the FTC’s ongoing fraud prevention education campaign for older adults. 

Campaign materials show respect for the readers’ life experience and accumulated knowledge, 

and supply them with resources to read and “pass on” to family and friends to start 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 a reader can 

do in response. Since the Pass It On campaign began in 2014, the number of topics it covers in 

print and online has expanded, based on community partners’ requests and changes in fraud 

trends. In 2022, the entire catalog of print and online material was reviewed and updated and 

now addresses these 13 common frauds.

• Business Impersonator Scams

• Charity Fraud

• Government Impersonator Scams

• Grandkid and Family Scams

• Health Insurance Scams

• Home Repair Scams

• Identity Theft

• Investment Scams

• Job and Money-Making Scams

• Romance Scams

91 Telemarketing Sales Rule, 87 Fed. Reg. 33662, 33669.

92 See Section IV(A)(1)(c).

93 Telemarketing Sales Rule, 87 Fed. Reg. 33662, 33670.
FEDERAL TRADE COMMISSION FTC.GOV 23

• Tech Support Scams 

• Unwanted Calls and Text Messages

• “You’ve Won” Scams

 The FTC has distributed 17.2 million Pass It On items since the campaign began, 

including more than 1.6 million items in fiscal year 2022. The free English and Spanish print 

material is requested by groups including banks, libraries, police departments, adult protective 

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

groups nationwide. Campaign materials are available at www.ftc.gov/PassItOn, 

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

 The FTC emails Consumer Alerts about many of the topics covered by Pass It On and 

other topics of interest to older adults, including business and government impersonators;

COVID-19 vaccine scams; romance, investment, and prize or lottery scams; and scammers’ 

demands for payment by gift card and cryptocurrency. The FTC emails the Alerts in English and 

Spanish to more than 413,000 subscribers, who include individuals, community groups, 

advocates, national and local news media outlets, and other stakeholders. The FTC also posts 

these Alerts and materials on its consumer website, www.consumer.ftc.gov, so the public can 

read, link to, and share the prevention messages.94

B. Outreach Relating to Older Adults

The FTC collaborates with many organizations across the country to share its consumer 

education messages and inform the public about its work. In this reporting period, FTC staff in 

Washington, DC and eight regional offices have presented, exhibited, or participated in more 

than 210 outreach events with the public, other law enforcement agencies, and stakeholders 

focused on protecting members of a wide range of communities from scams. More than 70, or 

one-third of all outreach events, served older adults and the people who work with them, or 

engaged partner organizations in discussions about issues that affect older adults. The FTC’s 

outreach and education work also focused on issues related to consumers’ financial resilience 

and recovery from effects of the COVID-19 pandemic; more information about that work is set 

forth in Section C. Pandemic Response. 

 FTC staff participated in events for older adults together with local, state, and federal 

organizations, including the Better Business Bureau (BBB), public libraries, consumer 

organizations, legal services providers, as well as state attorneys general and consumer affairs 

offices, and federal agencies including the Federal Emergency Management Agency, the FBI, 

the Internal Revenue Service, the Social Security Administration Office of Inspector General, 

and the US Postal Inspection Service. The FTC also joined in multiple activities with

groups including: 

94 Information about subscribing to Consumer Alerts is available at www.ftc.gov/ConsumerAlerts. 
FEDERAL TRADE COMMISSION FTC.GOV 24

1. AARP members

 Staff educated older adults through more than 30 events with AARP members, including 

nationwide and statewide Facebook Live conversations, webinars, and tele-town halls about 

topics including impersonators, identity theft, and romance, telephone, and cyberscams. During a 

nationwide tele-town hall in December 2021, FTC shared information about holiday scams with 

15,600 older adults. During a similar event the next month, staff talked about top scams with 

32,000 older adults. 

2. Senior Medicare Patrol Volunteers

The FTC made seven presentations to older adult Senior Medicare Patrol (SMP) 

volunteers in six states to share updated advice about fraud, identity theft, and impersonator 

scams among other topics. The FTC also met virtually with SMP volunteers, along with staff in 

State Health Insurance Programs (SHIP) and Medicare Improvement for Patients and Providers 

Act (MIPPA)-funded programs, to explain the Commission’s efforts to address fraud and 

consumer issues affecting communities of color and older adults. To recognize Older Americans 

Month, staff from the FTC and Senior Medicare Patrol Resource Center presented a virtual 

interactive discussion about various scams that affect older adults and responded to participants’ 

questions. Current SMP volunteers and members of the public attended the discussion. 

3. Members of Congress

 The FTC joined members of Congress and shared FTC resources at a Senior Scam 

Workshop for New Jersey residents, an online safety tele-townhall for Californians, and an 

in-person identity theft and fraud prevention workshop for more than 200 older 

Wisconsin residents. 

4. Consumer Financial Protection Bureau, SAGE, and others

The FTC and the Consumer Financial Protection Bureau’s Office for Older Americans 

co-hosted the LGBTQ+ Elder Fraud Prevention and Response Network Summit in collaboration 

with SAGE, the advocacy and services organization for LGBTQ+ elders; the National Center on 

Elder Abuse; and the Keck School of Medicine of the University of Southern California. The 

summit was the first federal-led convening on consumer protection issues affecting LGBTQ+ 

elders. Together with CFPB staff, FTC staff facilitated conversations about addressing consumer 

protection issues. More than 70 representatives from advocacy, government, and industry 

groups participated. 

5. Older Adult Advocates and Allied Professionals

 Commission staff shared educational material about scams, fraud, identity theft and other 

issues that affect older adults at several conferences with advocates and professionals. These 

included events organized by the American Association of Service Coordinators, whose 

members assist older adults, people with disabilities, and families who live in affordable housing 

communities; ADvancing States, which represents state and territorial agencies on aging, 

disability and long term services; the National Legal Aid & Defender Association, a national 
FEDERAL TRADE COMMISSION FTC.GOV 25

organization devoted to advocating equal justice for all Americans; National Extension 

Association of Family & Consumer Sciences, which educates and recognizes Cooperative 

Extension professionals who impact the quality of life for individuals, families and communities; 

USAging, a membership organization for Area Agency on Aging personnel; and UnidosUS, a 

Latino civil rights and advocacy organization. 

In 2021, the FTC launched the Community Advocate Center95 to support legal services 

organizations’ fraud reporting and strengthen the FTC’s connections with historically 

underserved communities. In October 2021, the FTC released and promoted The Community 

Advocate Center in a ReportFraud.ftc.gov96 video to introduce the Center and explain the 

benefits of becoming a Report Fraud Community Advocate. In this reporting period, FTC staff 

had 24 meetings with legal service providers to introduce the Community Advocate Center and 

give an overview of FTC education resources the providers could use to assist their clients. Six

of the legal service providers operate programs dedicated to serving older adults. Staff also 

deepened their connections with front line professionals, older adults, and lower income 

residents of Alaska, Arizona, Oklahoma, and Tennessee through virtual state Consumer 

Protection Conversations. Each conversation, co-hosted by FTC staff and local BBB, legal aid, 

and state attorney general representatives, gave viewers information about identity theft, 

consumer protection, and current local fraud. 

The FTC’s outreach partnerships with groups and communities throughout the country 

provide opportunities to share the agency’s important prevention messages and foster more direct 

communication lines so the FTC learns in real-time about ongoing scams and other consumer 

protection problems affecting the public. This, in turn, can generate ideas for policy and 

education initiatives, as well as new case leads.

C. Pandemic Response 

 As the effects of the pandemic have continued, the agency is increasing its outreach on 

issues related to financial resiliency. This includes advice and resources to learn — and teach 

others — how to tackle financial issues resulting from or worsened by the pandemic. Shortly 

after the coronavirus pandemic began, the FTC developed a multi-media campaign and dedicated 

website to alert people to scams associated with the COVID-19 pandemic 

(www.ftc.gov/coronavirus and www.ftc.gov/coronavirus/scams). This webpage, available in 

English and Spanish, serves as a one-stop directory of the FTC’s coronavirus education resources 

for consumers and businesses. The site’s consumer page contains advice on how to stay safe in 

the face of the health and pandemic-related financial crisis and links to Consumer Alerts. Local 

media and community partners that subscribe to these Alerts, including libraries, educators, 

banks, and local law enforcement, share and forward the information to their members, which 

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

96 The video can be viewed, shared, or downloaded at https://www.youtube.com/watch?v=xLGq3EcG6hA. 
FEDERAL TRADE COMMISSION FTC.GOV 26

exponentially expands the FTC’s audience and impact. As of July 31, the FTC’s coronavirusrelated material has had 9.6 million views. 

Since February 2020, the FTC has issued more than 180 Consumer Alerts about topics 

related to the pandemic including COVID-19 test kits, vaccines, stimulus payments, health and 

treatment claims, and government impersonators. In fact, one post on free COVID-19 tests was 

one of the most popular posts of the year, driving 66 percent of readers to the official links to 

order tests.

In the last fiscal year, FTC staff worked with varied partners and channels to deliver 

information to older adults, especially to those in historically underserved communities targeted 

by COVID-19 scams and issues. Staff appeared on national television to warn about fake athome COVID-19 tests and talked with more than 500 AARP members in California about the 

financial impact of the pandemic on the Latino community, including the emergence of job and 

mortgage scams. In Georgia, FTC staff joined AARP and the BBB to explain how listeners could 

avoid scams when looking for work-from-home positions. Staff sent FTC educational material to 

outreach partners in civic groups and local, state, and federal government in a six-state region to

distribute to their members and constituents, and educated 100 legal service providers about how 

to help clients recover from scams that follow the pandemic. In December 2021, the FTC sent 

folders with Pass It On and Pásalo material to 40,000 library, law enforcement, veterans’, and 

older adult support group presenters and trainers to share with the older adults they contact, to 

help them better manage the financial impact of the pandemic and avoid scams.

IV. Developing Effective Strategies to Protect 

Older Consumers

A. Research and Data Analysis 

The FTC collects and analyzes consumer report information through its Consumer 

Sentinel Network (“Sentinel”). Sentinel is a secure online database that provides federal, state, 

and local law enforcement agencies with access to reports from consumers about fraud and other 

consumer problems. Law enforcement agencies and other organizations contribute consumer 

reports,97 and the FTC collects reports directly from the public through its call center and online 

reporting system, ReportFraud.ftc.gov. The Sentinel database is searchable by criteria such as the 

type of fraud or problem and the name, address, and telephone number of the reported entity. 

The FTC has worked to increase the number of data contributors providing reports to Sentinel, 

and was pleased to welcome the Social Security Administration Office of the Inspector General 

and the Australian Competition and Consumer Commission last year, adding hundreds of 

thousands of reports. Using Sentinel, the FTC and its law enforcement partners can analyze 

97 Data contributors are listed at https://www.ftc.gov/enforcement/consumer-sentinel-network/data-contributors. 
FEDERAL TRADE COMMISSION FTC.GOV 27

reports filed by older adults to look for patterns and trends, identify problematic business 

practices and enforcement targets, and develop cases against targets under investigation.

1. Consumer Sentinel Reports from Older Adults

During calendar year 2021, Sentinel took in more than 5.9 million reports from 

consumers, both directly and through its data contributors, about problems they experienced in 

the market. Of that number, nearly 2.9 million reports were about fraud, more than 1.4 million 

were about identity theft, and nearly 1.6 million were about other consumer problems.98

Consumers reported losing $6.1 billion to fraud in 2021. About 46% of fraud reports filed in 

2021 included consumer age information.99 Consumers who said they were 60 and older (older 

adults) filed 467,340 fraud reports with reported losses of more than $1 billion. Because the vast 

majority of frauds are not reported, these numbers include only a fraction of older adults harmed 

by fraud.100 

Key findings from the 2021 Sentinel data: 

• Older adults (ages 60 and over) were still less likely than younger adults (ages 18-59) to 

report losing money to fraud. 

• Older adults continued to report higher individual median dollar losses than younger 

adults. The disparity remained particularly large among people 80 and over compared to 

younger adults. 

• Older adults continued to be much more likely than younger adults to report losing 

money on tech support scams, prize, sweepstakes and lottery scams, and family and 

friend impersonation. 

98 See generally FTC, FTC Consumer Sentinel Network (Last Updated July 29, 2021), available at

https://public.tableau.com/profile/federal.trade.commission. Figures are based on reports directly to the FTC and 

reports provided by all Sentinel data contributors. These figures do not include reports about unwanted calls. 

Sentinel data is self-reported and not a survey. As such, individuals decide whether to file a report and decide what 

information, if any, to provide. As noted below, not all consumers who file a report provide their age, payment 

method, amount of dollar loss, and other data. As referenced in the text above, “other consumer problems” include 

various categories of reports not classified as fraud, such as auto-related reports and reports about cable and satellite 

TV.

99 Data provided by the Internet Crimes Complaint Center (IC3) are excluded here and throughout this report, except 

where otherwise noted, due to differences in the age ranges collected from consumers and differences in report 

categorization. 

100 See Anderson, K. B., 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 (study showed that only 4.8 percent of 

victims of mass-market consumer fraud complained to a Better Business Bureau or a government entity).
FEDERAL TRADE COMMISSION FTC.GOV 28

• Online shopping fraud remained the most commonly reported category of fraud in which 

people of all ages indicated they lost money; however, older adults were much less likely 

to report losing money to online shopping fraud than younger adults. 

• Romance scams, business impersonation scams, and investment scams caused the highest 

aggregate reported losses for older adults as a whole, but prize, sweepstakes and lottery 

scams remained the costliest for people 80 and over. 

• Aggregated reported losses and the number of reports indicating money was lost by older 

adults were highest for online frauds, but reported median individual losses were highest 

for frauds that started with a phone call. 

• Gift cards and reload cards were the most frequently reported fraud payment methods by 

older adults, followed by credit cards. Aggregate losses reported by older adults were 

highest on bank transfers or payments. 

• New analysis points to differences in how older adults in different demographic 

populations may experience fraud. 

These findings, explored more fully below, help inform the FTC’s efforts to protect consumers 

through consumer education, law enforcement, and policy work. 

a. Most Older Adults Who Filed Fraud Reports Avoided Losing Any Money

As in previous years, the overwhelming majority of Sentinel fraud reports filed in 2021 

by people 60 or over did not indicate any monetary loss. Figure 1, which controls for population 

size,101 shows that older adults were 68% more likely to file these no-loss reports about fraud 

they had spotted or encountered—but avoided losing money on—than people ages 18-59.102

Moreover, consistent with previous years, older adults were 26% less likely to report losing 

money to fraud than people ages 18-59. This suggests that older adults may be more likely to 

avoid losing money when exposed to fraud, more inclined to report fraud when no loss has 

occurred, or a combination of these or other factors. The FTC’s most recent fraud survey, 

published in October 2019, also found that what it called the “rate of victimization” for the 

101 The comparison of older adults and younger consumers is normalized against the population size of each age 

group. The analysis is based on U.S. Census Bureau data for population by age. See U.S. Census Bureau, Annual 

Estimates of the Resident Population for Selected Age Groups by Sex for the United States (June 2020), available at

https://www.census.gov/data/tables/time-series/demo/popest/2010s-national-detail.html. 

102 The largest share of 2021 no-loss reports by older adults were about phone scams, and these were most often 

calls from scammers impersonating businesses and government agencies.
FEDERAL TRADE COMMISSION FTC.GOV 29

various categories of frauds included in the survey was generally lower for those 65 and older 

than for younger consumers.103 

b. Older Adults Reported Higher Median Individual Dollar Losses than 

Younger Consumers

In 2021, as in previous years, younger consumers were more likely to report losing 

money to fraud than older adults, but older adults who did report losing money reported higher 

median individual losses (see Figure 2). People 80 and over reported median individual losses of 

$1,500, far higher than any other age group. The reported median individual dollar loss increased

for all age groups in 2021 as compared to 2020, but the increases were most striking for younger 

adults. These increases can be explained, in part, by a surge in reports of money lost to romance 

scams and investment scams, both of which have much higher reported median individual dollar 

losses than most other frauds.104

103 FTC Bureau of Economics Staff Report, Mass-Market Consumer Fraud in the United States: A 2017 Update 76–

79 (Oct. 2019), available at https://www.ftc.gov/system/files/documents/reports/mass-market-consumer-fraudunited-states-2017-update/p105502massmarketconsumerfraud2017report.pdf. 

104 In 2021, the reported median individual dollar loss by adults 60 and over for reports categorized as romance 

scams and investment related fraud was $5,100 and $6,800 respectively, compared to $685 for all fraud reports by 

this age group. Here and throughout this report, investment scams refer to fraud reports classified as investment 

seminars and advice, stocks and commodity futures trading, art, gems and rare coin investments, and miscellaneous 

investments. 
FEDERAL TRADE COMMISSION FTC.GOV 30

Some Sentinel reports are filed on behalf of consumers by adult children, spouses, 

caretakers, or others. As in prior years, 2021 Sentinel data show that adults ages 80 and over 

were more likely than other age groups to have a Sentinel report filed on their behalf. About 17% 

of reports for people 80 and over indicated they were submitted by a person on behalf of the 

consumer, a far higher rate than any other age group.

105 Reports submitted by third parties had 

higher median individual reported losses as compared to those that were self-reported for all age 

groups, but this disparity was particularly striking for older adults.106

105 The percentage of reports submitted by another person on behalf of a consumer in 2021 were as follows: 17.1%

(80 and over), 5.0% (70-79), 2.9% (60-69), 2.4% (50-59), 2.0% (40-49), 1.8% (30-39), 2.2% (20-29), and 3.8% (18-

19). These figures exclude reports collected by Sentinel data contributors because of differences in identifying 

reports submitted by third parties.

106 The 2021 reported median individual dollar losses by age for this subset of reports were as follows: $4,000 (80 

and over), $3,000 (70-79), $1,500 (60-69), $1,000 (50-59), $1,000 (40-49), $982 (30-39), $877 (20-29), and $600 

(18-19). These figures exclude reports collected by Sentinel data contributors because of differences in identifying 

reports submitted by third parties.
FEDERAL TRADE COMMISSION FTC.GOV 31

c. Some Types of Fraud Affected Older Adults Differently from Younger 

Adults

To identify the top scams that had a financial effect on older adults, Figure 3 displays the 

top fraud categories ranked by the number of reports by older adults indicating that money was 

lost (loss reports). The dark teal bars show loss reports submitted by older adults (age 60 and 

over), and the light green lines show loss reports filed by younger people (ages 18-59) for each 

category of fraud. As shown in Figure 3, controlling for population size, older adults were more 

likely than younger people to report financial losses to certain types of frauds. Three categories 

of fraud continued to stand out in 2021. Older adults were: 1) nearly five times, or 398%, more 

likely than younger people to report losing money on a tech support scam; 2) more than twice as

likely to report a loss on a prize, sweepstakes or lottery scam; and 3) 45% more likely to report a 

loss on a family or friend impersonation scam.
FEDERAL TRADE COMMISSION FTC.GOV 32

 Reports of losses to online shopping fraud increased sharply starting in the second 

quarter of 2020,107 and the numbers remained far higher than pre-pandemic levels in 2021 even 

as reports of COVID-19 related online shopping fraud declined.108 Although older adults 

continued to be less likely than younger people to report losing money to online shopping fraud, 

the number of loss reports submitted by older adults on this fraud type continued to far exceed 

any other category of fraud reported by older adults. Ads on social media were frequently 

identified as the starting point for these frauds, particularly when the items purchased were 

simply not received.109 

Analysis of total dollars reported lost by older adults by fraud type, shown in Figure 4, 

highlights the tremendous financial harm caused by romance scams, business impersonation 

scams, and investment scams in 2021. The highest aggregate dollar losses reported in 2021 by 

older adults were again in the romance scam category. Reported losses to romance scams have 

increased significantly in recent years,

110 and this trend accelerated with the start of the COVID19 pandemic.111 For older adults, reported romance scam losses increased from $139 million in 

2020 to $213 million in 2021. Among older adults, hardest hit were the 60-69 and 70-79 age 

groups, which reported $198 million of the 2021 reported losses. Reported losses by older adults 

on business impersonation scams topped $151 million in 2021, more than double the 2020 

number. This increase was due, in part, to a surge in reports of losses to scammers posing as 

Amazon.112 The most striking increase was on investment scams, with reported losses by older 

adults more than tripling in 2021. This increase was driven in large part by a surge in reports of 

losses to cryptocurrency investment scams.113 Reported losses by older adults to scam

107 See FTC Consumer Protection 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. 

108 Adults 60 and over reported 1,567 COVID-19 related online shopping frauds in 2021 compared to 3,190 such 

reports in 2020.

109 About one in four older adults who reported losing money on undelivered online shopping purchases in 2021 

identified social media as the contact method.

110 See FTC Consumer Protection Data Spotlight, Reports of romance scams hit record highs in 2021 (Feb. 10, 

2022), available at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2022/02/reports-romancescams-hit-record-highs-2021. 

111 See FTC Consumer Protection Data Spotlight, Romance scams take record dollars in 2020 (Feb. 10, 2021), 

available at https://www.ftc.gov/news-events/blogs/data-spotlight/2021/02/romance-scams-take-record-dollars2020. 

112 Amazon imposters reportedly contact consumers with false claims about compromised accounts or unauthorized 

purchases. See FTC Consumer Protection 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. 

113 See FTC Consumer Protection Data Spotlight, Reports show scammers cashing in on crypto craze (June 3, 

2022), available at https://www.ftc.gov/news-events/data-visualizations/data-spotlight/2022/06/reports-showscammers-cashing-crypto-craze. 
FEDERAL TRADE COMMISSION FTC.GOV 33

investment opportunities where the payment method is in cryptocurrency increased more than 

ninefold in 2021.

114

For adults 80 and over the highest aggregate reported losses were again on prize, 

sweepstakes and lottery scams, with $47 million reported taken in 2021. This figure represents 

an astonishing 31% of all reported fraud losses by people 80 and over in 2021. The median 

individual reported loss on these scams for the 80 and over age group was $6,000 in 2021, far 

higher than for other age groups.115

114 Older adults reported $41.5 million lost on fraud categorized as investment related with cryptocurrency as the 

payment method in 2021 compared to $4.5 million in 2020.

115 In 2021, the median individual reported loss on prize, sweepstakes and lottery scams was $1,450 for adults 60-79 

and $400 for ages 18-59.
FEDERAL TRADE COMMISSION FTC.GOV 34

d. Older Adults Most Frequently Reported Losses to Online Fraud, But 

Reported the Highest Median Individual Loss Amounts to Fraud that 

Started with a Phone Call

In 2020, loss reports about online frauds by older adults surpassed phone fraud loss 

reports for the first time.116 This trend accelerated in 2021, with online fraud loss reports by older 

adults increasing by more than 60% to nearly double the phone fraud number (see Figure 5). 

Aggregate reported losses to online fraud by older adults increased 90%, surpassing phone fraud 

for the first time in 2021. However, 2021 reported median individual losses remained far higher 

for phone fraud at $1,500 compared to $300 for online fraud.

116 Online frauds are defined here as those in which the consumer reported first learning about the fraud on a website 

or app, on social media, or via an online ad or pop-up. Phone frauds are those in which the consumer reported first 

learning about the fraud via a phone call. Text frauds belong to a category separate from phone frauds. 
FEDERAL TRADE COMMISSION FTC.GOV 35

People 80 and over were again an exception in that this age group continued to report 

losses to phone fraud at higher rates than online fraud,

117 and their aggregate reported losses to 

phone fraud were more than twice that of online fraud.

118 About 46% of aggregate reported 

losses by this age group were on phone fraud compared to 24% of aggregate reported losses by 

people ages 60-79. Moreover, the median individual reported loss to phone fraud was $3,000 for 

people 80 and over compared to $1,340 for people ages 69-79. 

Figure 6 shows the yearly trend in loss reports for each of the contact methods collected 

in Sentinel.119 Reports indicating a loss to fraud that reached older adults via social media once 

117 In 2021, 38% of reports indicating a dollar loss by adults 80 and over were about phone fraud and 27% were 

about online fraud. By comparison, 20% of reports indicating a dollar loss by adults 60-79 were about phone fraud 

and 43% were about online fraud. 

118 The aggregate reported loss on phone fraud by adults 80 and over in 2021 was $70 million, compared to $26 

million on online fraud. 

119 Figure 6 excludes the online ad or pop-up contact method because this was not an available option prior to 

October 22, 2020.
FEDERAL TRADE COMMISSION FTC.GOV 36

again more than doubled.120 A 40% increase in reports of losses to text scams was also notable, 

although the numbers relative to other contact methods remained low. The data suggest that 

attempted phone fraud continued to be a concern for older adults. More than a third of fraud 

reports by adults 60 and over in 2021 were about phone contacts with no reported dollar loss, 

compared to just 17% of reports by younger adults.121

Figure 7 shows 2021 aggregate reported losses and median individual reported losses for 

each of the contact methods collected in Sentinel. The social media contact method again stands 

out, with total reported losses more than doubling from $63 million in 2020 to $164 million in 

2021. Median individual reported losses on social media scams by older adults increased from 

$204 in 2020 to $460 in 2021. Also notable were text scams, which showed higher median 

individual reported losses than any other contact method with the exception of phone calls. The 

total loss amount reported by older adults on text scams increased from $22 million in 2020 to 

$41 million in 2021. 

The types of frauds older adults most frequently reported losing money to varied by 

contact method. As in 2020, when the contact method was a phone call, older adults most often 

120 See FTC Consumer Protection 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-minescammers-2021. 

121 Older adults submitted 406,955 reports indicating a contact method in 2021, while younger adults submitted 

752,022 reports indicating a contact method. Of these, 148,204 reports by older adults indicated a phone call was the 

contact method and no money was lost, compared to 131,153 such reports by younger adults.
FEDERAL TRADE COMMISSION FTC.GOV 37

reported dollar losses on business impersonation scams followed by government impersonation

scams and tech support scams. However, for the 80 and over age group, loss reports indicating a 

phone call as the method of contact were again most often about prize, sweepstakes and lottery 

scams. When text was the contact method, the largest share of loss reports by older adults were 

business impersonation scams, particularly those impersonating Amazon. When the contact 

method was online, most of the loss reports by older adults were about online shopping frauds, 

with business impersonation scams and romance scams a distant second and third.122 While 

online shopping was the most commonly reported fraud, the amount of losses were highest for 

romance and then investment scams. About 60% of all dollars reported lost to online fraud by 

older adults were lost to romance scams and investment scams.123 

e. Gift Cards Were the Most Frequently Reported Payment Method, but Bank 

Transfers Took the Top Spot for Total Dollars Lost

People reporting fraud frequently indicate the payment method they used, and this 

information helps the FTC identify opportunities for enforcement and consumer education. The 

first column in Figure 8 shows that, in 2021, older adults most often reported paying scammers 

with gift cards or reload cards followed by credit cards and debit cards. The second column in 

Figure 8 shows the aggregate dollar losses that older adults reported for the payment methods 

shown. Aggregate losses reported by older adults were highest on bank transfers and payments.

122 Of 37,178 online fraud reports by older adults indicating a dollar loss in 2021, 20,130 were about online 

shopping fraud, followed by 3,863 business impersonation scam reports and 3,269 romance scam reports.

123 Of $341 million dollars reported lost to online fraud by older adults in 2021, $137 million was reported lost to 

romance scams and $72 million was reported lost to investment scams. 
FEDERAL TRADE COMMISSION FTC.GOV 38

 Several notable shifts occurred in the payment methods reported by older adults in 2021 

as compared to 2020. The number of older adults who said they paid with a gift card or reload 

card increased by about 67%.124 These reports were largely about impersonation scams, with the 

growth related to a sharp increase in reports of scammers posing as well-known businesses.125

Reported losses by older adults using bank transfers and payments more than doubled,126 with 

the largest share of these losses going to romance scams, investment related fraud, and business 

impersonation scams.127 Most striking was the more than fivefold increase in reported losses 

124 In 2021, 21,436 fraud loss reports by older adults indicated gift card or reload card as the method of payment 

compared to 12,813 in 2020. Reported losses by older adults using this payment method increased from $59 million 

in 2020 to $110 million in 2021. See FTC Consumer Protection 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/dataspotlight/2021/12/scammers-prefer-gift-cards-not-just-any-card-will-do. 

125 In 2021, about 66% of reports by older adults indicating gift card or reload card as the payment method were 

categorized as imposter scams. Reports by older adults classified as business imposter scams with gift card or reload 

card as the payment method increased 83% in 2021 as compared to 2020.

126 Adults 60 and over reported $209 million (5,904 loss reports) lost to fraud with bank transfers and payments as 

the payment method in 2021 compared to $99 million (2,948 loss reports) in 2020.

127 In 2021, adults 60 and over reported losing $43 million to romance scams using bank transfers and payments as 

the payment method, followed by investment related fraud at $39 million and business imposter scams at $37 

million.
FEDERAL TRADE COMMISSION FTC.GOV 39

using cryptocurrency as the payment method.128 The largest share of reported cryptocurrency 

losses by older adults were on investment scams, with romance scams a close second.129

f. Identifying Differences in Fraud and Consumer Issues Affecting Older 

Adults of Color

FTC research and analysis has demonstrated that different demographic communities 

report different types of fraud at different rates.130 This section seeks to identify trends for older 

adults in Black, Latino, and Asian American and Pacific Islander (“AAPI”) populations. 

Although the FTC does not collect race and ethnicity information directly from consumers, a 

method to impute race and ethnicity using name and zip code information has been applied for 

the purpose of identifying any trends in reporting.131 Using this method, over 138,000 fraud 

reports filed from 2019 to 2021 from older adults most likely to be Black, Latino, and AAPI 

were identified for analysis.132 The results show differences in the reported fraud types and 

128 Adults 60 and over reported $119 million (2,796 loss reports) lost to fraud with cryptocurrency as the payment 

method in 2021 compared to $22 million (784 loss reports) in 2020.

129 In 2021, adults 60 and over reported losing $42 million to investment scams using cryptocurrency as the payment 

method, followed by romance scams at $40 million.

130 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-tradecommissions-efforts-address-fraud-consumer/ftc-communities-color-report_oct_2021-508-v2.pdf. 

131 The procedure used to impute race and ethnicity for this report combines information from a consumer’s first 

name, surname, and home zip code, with a method known as Bayesian Improved First Name Surname Geocoding 

(BIFSG). Where BIFSG could not be applied, race/ethnicity probabilities were determined using surname and zip 

code (BISG) and using zip code alone where surname could not be used. Consumers were then classified according 

to their largest single race/ethnicity probability, an approach called max a posteriori (MAP) classification. To check 

for robustness, statistics were also computed using race probabilities as weights and threshold classification methods 

to ensure that the findings broadly held across methodologies. BISG is a standard technique in fair lending analysis 

for banking supervision, originally explored in Mark N. Elliott et al, Using the Census Bureau’s surname list to 

improve estimates of race/ethnicity and associated disparities, Health Services and Outcomes Research 

Methodology 9, no. 2. (2009). For more information on BIFSG, See Ioan Voicu, Using First Name Information to 

Improve Race and Ethnicity Classification, Statistics and Public Policy, Volume 5, Issue 1 (2018) at 1-13. available 

at https://www.tandfonline.com/doi/full/10.1080/2330443X.2018.1427012. 

132 Three years of reporting data were used to increase the sample size. The number of 2019-2021 reports identified 

for analysis for each group were as follows: 72,235 Black, 50,435 Latino, and 15,453 AAPI. Note that this 

information only includes a fraction of the older adults in these populations who experienced fraud. One study has 

shown that only about 4.8 percent of the victims of mass-marketing consumer fraud complained to the Better 

Business Bureau or a government agency. 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

(study showed that only 4.8 percent of victims of mass-market consumer fraud complained to a Better Business 

Bureau or a government entity). Further, research involving nine consumer protection matters found that heavily 

Black and Latino areas complained substantially less relative to their rate of victimization after controlling for other 

demographic characteristics. See Devesh Raval, Whose Voice Do We Hear in the Marketplace? Evidence from 

Consumer Complaining Behavior, Marketing Science (2020), 39 (1), 168-187, available at

https://deveshraval.github.io/complaintBehavior.pdf. 
FEDERAL TRADE COMMISSION FTC.GOV 40

payment methods for each community, as well as larger reported median dollar losses for older 

adults most likely to be AAPI.
FEDERAL TRADE COMMISSION FTC.GOV 41

Figure 9 shows top fraud types by the share of total reported losses by older adults most 

likely to be Black, Latino, and AAPI. The gray bar represents all reports by older adults.133 Each 

colored bar shows the share of total losses from each demographic group about various types of 

fraud. The data suggest that the fraud types with the highest reported dollar losses for older 

adults as a whole are also among the most costly for Black, Latino and AAPI older adults. 

However, differences are also evident. For example, 24% of total reported losses by older adults 

most likely to be AAPI were on government impersonation scams, compared to just 13% of all 

reports.134 Older adults most likely to be AAPI also had a much higher share of reported losses 

on investment-related fraud. These reports have continued to climb, and in the first six months of 

2022, 57% of all reported losses by the AAPI group were on investment scams, and nearly half 

of these losses were in cryptocurrency. For reports from older adults most likely to be Black, 

prize, sweepstakes and lottery scams stand out at 19% of the total reported losses for this group 

compared to 13% for older adults generally. The largest share of these losses was on phone 

scams in which consumers reported that the scammers claimed a connection with

well-known businesses. 

133 Because the method used to impute race requires a U.S. zip code of residence, reports from consumers residing 

outside the U.S. have been excluded here and throughout this section of the report.

134 Reports about scammers impersonating immigration and customs officers contributed to the higher share of 

reported losses on government imposter scams among older adults most likely to be AAPI. See Consumer Alert, 

FTC, Scammers impersonate U.S. immigration officers, available at https://consumer.ftc.gov/consumeralerts/2022/07/scammers-impersonate-us-immigration-officers. This group also reported scams impersonating the 

Chinese Consulate. See Consumer Alert, FTC, Scammers impersonate the Chinese Consulate (April 18, 2018), 

available at https://consumer.ftc.gov/consumer-alerts/2018/04/scammers-impersonate-chinese-consulate. 
FEDERAL TRADE COMMISSION FTC.GOV 42

Figure 10 shows the differences in the top fraud payment methods reported by older 

adults for each of the three demographic groups. Older adults most likely to be Black and Latino 

filed a larger share of their reports about payments made with debit cards compared to all older 

adults, and a lower share about payments made with credit cards. Because the law provides 

additional fraud protection in credit card transactions, these disparities are especially noteworthy

for consumer reports of fraud.

135 Figure 10 also shows that older adults most likely to be Latino 

reported using wire transfers as the payment method in 11% of their reports compared to just 6% 

135 See FTC Consumer Advice, Lost or Stolen Credit, ATM, and Debit Cards, available at

https://consumer.ftc.gov/articles/lost-or-stolen-credit-atm-debit-cards. 
FEDERAL TRADE COMMISSION FTC.GOV 43

for all older adults. About 22% of these reports were about scammers impersonating friends and 

family members, compared to 8% of all wire transfer reports by older adults. 

 Fraud reports from older adults in each demographic group also showed differences in 

individual loss amounts and the share of reports that indicated any money was lost. The median 

reported loss from 2019 to 2021 was $600 for the older adults most likely to be Black, $720 for 

older adults most likely to be Latino, and $1,000 for older adults most likely to be AAPI, 

compared to $650 for all older adults. These differences were seen across many different fraud 

types, with the older adults most likely to be AAPI reporting higher median losses than those 

most likely to be Black and Latino as well as all older adults on most frequently reported 

frauds.136 As with older adults generally, most fraud reports from the three demographic groups 

were no-loss reports. However, for all three groups the share of fraud reports that did indicate a 

monetary loss was higher than for all older adults.137 

2. Analysis of Social Security Administration Scam Reports

 Government impersonators have been plaguing U.S. consumers for many years now. In 

2021, the FTC received almost 400,000 reports about government impersonators.138 Scammers 

impersonating the Social Security Administration (“SSA”) topped the list in 2021 with more than 

217,000 reports and almost $150 million dollars in reported losses. 

136 Of the top fraud types identified in Figure 9, the AAPI group reported higher median individual losses than all 

older adults on all but the family and friend imposters fraud type. Compared to the Black and Latino groups, the 

AAPI group reported higher median individual losses for all but the online shopping and family and friend imposters 

fraud type. 

137 From 2019-2021, the share of fraud reports indicating a monetary loss was 17% for all older adults, 20% for both 

the Black and Latino groups, and 26% for the AAPI group.

138 Explore Government Imposter Scams, FTC Tableau Public Infographic, available at

https://public.tableau.com/app/profile/federal.trade.commission/viz/GovernmentImposter/Infographic. 
FEDERAL TRADE COMMISSION FTC.GOV 44

2021 Data from FTC’s Explore

Government Imposters Dashboard139

The SSA Scam typically starts with an automated phone call from scammer claiming 

there is a problem with the consumer’s Social Security number, often claiming it has been 

suspended because of criminal activity. The scammer tells consumers to avoid arrest and secure 

their money, they must purchase gift cards or cryptocurrency, or wire money. The scammer then 

takes the consumer’s funds. 

Two researchers took a closer look at the reports received by the FTC about the SSA 

Scam, using a variety of methods to learn more about the scam.140 Among other things, the 

researchers confirmed that SSA scam reports followed some of the trends for all government 

impersonator scams, that is, that older adults file fewer reports about losing money to these 

scams than younger people, but older adults lose significantly more money per incident 

on average.

141

139 FTC, Explore Government Imposter Scams (last updated July 20, 2022), available at 

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

140 DeLiema, Marguerite, and Paul Witt. Mixed Methods Analysis of Consumer Fraud Reports of the Social Security 

Administration Impostor Scam. Ann Arbor, MI. University of Michigan Retirement and Disability Research Center 

(MRDRC) Working Paper; MRDRC WP 2021-434 (2021) available at 

https://mrdrc.isr.umich.edu/publications/papers/pdf/wp434.pdf. 

141 Id. at 35, 40, 45, 46.
FEDERAL TRADE COMMISSION FTC.GOV 45

In looking at the narratives in the consumer reports, the researchers found evidence of 

high intensity emotional arousal in nearly every consumer narrative.142 The researchers noted 

that “[o]f the 600 cases in the sample, 312 included threats of arrest, 220 mentioned drug-related 

charges, and 165 mentioned money laundering charges.”143 They further found that 

“[c]onsumers who complied with the scam described how these threats instilled fear, anxiety, 

and panic.”144 The most common emotion word in the consumers’ narratives was “scared,” along 

with derivatives such as “afraid,” “worried,” “terrified,” “paralyzed,” “panicked,” “shaking,”

“nervous,” “fearful,” and others.145

The researchers also matched the zip code information for all consumer reports to U.S. 

Census Bureau information and looked to the demographic information for those zip code areas. 

They found that consumers from majority Black, Asian, and Hispanic communities are more 

likely to report that they lost money than people in non-Hispanic White communities.146 People 

from non-Hispanic White communities reported higher average losses.

147 Researchers also noted 

that reports about the SSA scam often mentioned successful interventions by third parties in the 

narrative, such as: “(1) retail store employees, including cashiers, store managers, and bank 

tellers; (2) law enforcement officers; (3) friends and family members; (4) SSA employees; and 

(5) financial institutions.”148

3. Hearing Directly from Older Adults About FTC Impersonators

The FTC continued its program this year to engage with and gather information from

older adults who reported losing money to scammers pretending to work at or be affiliated with 

the FTC. FTC staff reached out to the majority of people who filed these reports to explain that 

the FTC does not distribute prizes, money, or grants, and provided additional information as 

needed. During these calls, staff learned more about the means by which scammers continued to 

call older adults and ultimately steal their money. 

Information from this program indicates that as the isolation of the pandemic continues, 

scammers continue to call older adults and use the FTC’s name to gain their trust. At the outset, 

when the scammer states that they are part of a government agency, they gain an aura of 

142 Id. at 43.

143 Id. at 21-22.

144 Id.

145 Id.

146 Id. at 47-48.

147 Id. at 36, 47-48.

148 Id. at 23.
FEDERAL TRADE COMMISSION FTC.GOV 46

legitimacy, which seems to increase the likelihood that consumers will respond. Once this aura is 

established, they move on to finding ways to convince people to send them money. 

The most common approach scammers employ is to talk about prizes the consumer 

supposedly won, such as cash, cars, or overseas vacations. The required payments are presented 

as taxes, import and customs fees, and delivery charges that must be paid before the prize can be 

delivered. Individually these payments are seldom large, but over time as the scam is 

perpetuated, they can accumulate into an enormous loss. To lower consumers’ suspicions and 

keep the money coming in, the scammers develop “relationships” with the consumers, calling 

several times a week to check up on them and to give updates on their prize. Sometimes a 

consumer is passed on to another caller working the scam, which helps convince them that each 

payment brings their jackpot closer. Secrecy is also emphasized, supposedly to make the huge 

payout a surprise to the consumer’s family when it comes. But in reality, secrecy prevents other 

family members or friends from learning how much the consumer has paid. 

Many of the older adults contacting the FTC have grown suspicious and want to confirm 

that the callers they have been interacting with are indeed FTC employees. Yet, FTC staff may 

also spend significant time convincing the consumer that the scammers are not in any way 

employed by or affiliated with the FTC. In other instances, some of the older adults already have 

consulted with family members about what has been happening and contact the FTC in order to 

report the scam. In such circumstances, they are contacting the FTC to ensure that others are not 

similarly deceived and will not suffer difficult and often devasting monetary losses. 

B. Coordinated Efforts to Protect Older Consumers

The FTC’s Every Community Initiative leads the agency’s strategic planning for the 

protection of older consumers. As highlighted in last year’s Serving Communities of Color 

Report, different types of consumer protection issues affect different groups of people, and this 

Initiative examines the impact of various schemes on distinct groups, including older adults, 

military service members and veterans, Black Americans, Latinos, Asian Americans, Native 

Americans, communities who speak languages other than English, and other groups.149 The 

Initiative uses research and input from stakeholders in communities to develop strategies to 

prevent fraud, inform the agency’s law enforcement program, and expand outreach. These 

partnerships across the country have been extremely valuable as the FTC identifies potential 

cases and further develops strategies to protect older adults in a wide range of communities from 

financial loss.

In pursuing law enforcement actions to have the largest possible impact, the FTC also 

coordinates with federal, state, local, and international agencies, including those with criminal 

authority, leveraging resources to track down fraudsters and build cases to stop them. In 

149 FTC Staff Report, Serving Communities of Color: A Staff Report on the Federal Trade Commission’s Efforts to 

Address Fraud and Consumer Issues Affecting Communities of Color (Oct. 2021), available at

https://www.ftc.gov/system/files/documents/reports/serving-communities-color-staff-report-federal-tradecommissions-efforts-address-fraud-consumer/ftc-communities-color-report_oct_2021-508-v2.pdf. 
FEDERAL TRADE COMMISSION FTC.GOV 47

particular, the FTC participates in the Global Anti-fraud Enforcement Network, a multilateral 

network of agencies that enforces laws prohibiting mass marketing fraud. The Network has been 

pivotal in enforcement actions against entities that have defrauded millions of older consumers. 

 Further, the FTC has continued to be an active member of the Elder Justice Coordinating 

Council, a multi-agency federal entity that coordinates activities across the federal government 

related to elder abuse, neglect, and exploitation. Led by the Assistant Secretary for Aging within 

the Department of Health and Human Services (“HHS”), the EJCC meets at least twice a year 

with the goal of better coordinating the federal response to elder abuse.150 At the December 2021 

meeting, the FTC’s Elder Justice Coordinator presented information about the FTC’s efforts to 

protect older adults from fraud and bad business practices, highlighting the FTC’s work to better 

serve people living in communities of color.151 At the June 2022 meeting, six researchers 

summarized their recent projects, including Dr. Marti DeLiema who discussed her paper 

analyzing consumer reports received in the FTC’s Consumer Sentinel Network about the SSA 

impersonation scam.152 The EJCC and its staff-level working group have strengthened the FTC’s 

connections with other federal government offices that are also working to combat elder abuse 

and has facilitated valuable information sharing and coordination. 

 Finally, pursuant to the Stop Senior Scams Act,153 the FTC recently established an 

Advisory Group comprised of stakeholders from government, industry, and consumer advocacy 

groups154 to create new initiatives that address fraud impacting older adults. The Advisory Group 

held its first public meeting on September 29, 2022, and introduced several committees that will

150 HHS convened the Elder Justice Coordinating Council in accordance with the Elder Justice Act passed in 2010. 

The Council consists of heads of federal departments and other government entities, including the FTC, identified as 

having responsibilities, or administering programs, relating to elder abuse, neglect, and exploitation. See HHS, What 

is the Elder Justice Coordinating Council? (last modified July 8, 2022), available at

https://www.acl.gov/programs/elder-justice/elder-justice-coordinating-council-ejcc. 

151 A recording of the December 2021 EJCC meeting is available at https://acl.gov/programs/protecting-rights-andpreventing-abuse/fall-2021-ejcc-meeting. 

152 A recording of the June 2022 EJCC meeting, along with a copy of Dr. DeLiema’s remarks is available at 

https://acl.gov/programs/june-21-2022-ejcc-meeting. Dr. DeLiema’s analysis of the Consumer Sentinel reports 

about the SSA scam is discussed in Section IV(A)(2) of this report.

153 Congress enacted the Fraud and Scam Reduction Act, Section 101, Division Q of the Consolidated 

Appropriations Act, 2022, Pub. L. No. 117-103 on March 15, 2022. See

https://www.congress.gov/117/plaws/publ103/PLAW-117publ103.pdf. Subtitle A of the Act, referred to as the “Stop 

Senior Scams Act,” requires the FTC to create an Advisory Group comprised of various members, including those 

identified in the Act.

154 The Advisory Group is comprised of representatives of the following entities: AARP; AmeriCorps Senior; 

Chamber of Digital Commerce; Commodity Futures Trading Commission; Consumer Financial Protection Bureau; 

Federal Deposit Insurance Corporation; Federal Reserve Board; Federal Trade Commission; Financial Crimes 

Enforcement Network; Financial Industry Regulatory Authority; Innovative Payments Association; National Retail 

Federation; Office of the Attorney General for the State of Vermont; Retail Gift Card Association; Securities and 

Exchange Commission; The Money Services Round Table; U.S. Department of Health and Human Services; U.S. 

Department of Justice; U.S. Department of Treasury; U.S. Postal Inspection Service; and USTelecom.
FEDERAL TRADE COMMISSION FTC.GOV 48

tackle four topics in the upcoming year: 1) expanding consumer education efforts; 2) improving 

industry training on scam prevention; 3) identifying innovative or high-tech methods to detect 

and stop scams; and 4) developing research on consumer or employee engagement to reduce 

fraud. The FTC also created a Senior Fraud Advisory Office pursuant to the Seniors Fraud 

Prevention Act of 2022.155 This Office will advise the Commission on fraud prevention 

strategies, monitor the market for emerging fraud trends impacting older adults, and coordinate 

with our law enforcement partners to disseminate consumer education regarding these

new trends.

V. Conclusion

The FTC remains firmly committed to protecting older adults through aggressive law 

enforcement and effective consumer education and outreach. Research, law enforcement 

experience, and input from stakeholders will continue to be critical as the Commission innovates 

in using its resources to protect older adults in the years ahead.

155 See Fraud and Scam Reduction Act, Section 101, Division Q of the Consolidated Appropriations Act, 2022, Pub. 

L. No. 117-103, available at https://www.congress.gov/117/plaws/publ103/PLAW-117publ103.pdf. Subtitle B of 

the Act, referred to as the “Seniors Fraud Prevention Act of 2022,” requires the FTC to establish an Advisory Office 

to, among other responsibilities, advise the Commission on the prevention of fraud targeting seniors, monitor the 

market for fraud trends impacting older adults, and disseminate consumer education about those trends in 

coordination with the U.S. Department of Health and Human Services; U.S. Department of Justice; U.S. Postal 

Inspection Service; and U.S. Postal Service.
FEDERAL TRADE COMMISSION FTC.GOV 49

Appendix A - Federal Trade Commission FY 2022

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Resident Home 

LLC et al.

FTC Matter No. 

C-4767

FTC 

Administrative 

Matter

10/1/2021 Made in the 

USA 

Deception

Alleged the 

respondents made false

or misleading 

advertising claims that 

their imported 

mattresses were made 

from 100% USA-made 

materials.

Consent Order
FEDERAL TRADE COMMISSION FTC.GOV 50

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Universal Guardian 

Acceptance, LLC et 

al.

2:21-cv-08260 Central District 

of California

10/19/2021 Deceptive 

Earning 

Claims 

Alleged the defendants 

facilitated a deceptive 

investment training 

scheme by 

underwriting, funding, 

and servicing financing 

contracts the scheme 

issued to purchasers.

Settlement

United States of 

America v. Xlear, 

Inc. et al.

2:21-cv-00640 District of 

Utah

10/28/2021 COVID-19 

Consumer 

Protection Act

Alleged the defendants 

made unsubstantiated 

claims that their

product could prevent 

or treat COVID-19.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 51

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Automatic Funds 

Transfer Services, 

Inc. et al.

1:21-cv-02932 District of 

Columbia

11/8/2021 Payment 

Processing 

Alleged the 

defendants assisted and 

facilitated a fraudulent 

student loan debt relief 

scheme by processing 

victims’ payments to 

the scheme.

Settlement

United States of 

America v. OpenX 

Technologies, Inc.

2:21-cv-09693 Central District 

of California

12/15/2021 Data Privacy / 

Children’s 

Online Privacy 

Protection Act 

(COPPA)

Alleged the defendants

deceived consumers by 

accessing location data 

even when consumers 

denied consent and

collected personal 

information from 

children under 13 

without parental 

consent.

Settlement

Federal Trade 

Commission v. 

ITMedia Solutions 

LLC et al.

2:22-cv-00073 Central District 

of California

1/5/2022 Lead 

Generation

Alleged the defendants 

solicited sensitive 

information from 

consumers through

deceptive loan 

applications and then 

indiscriminately sold 

that information to 

marketing companies 

and others.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 52

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Dun & Bradstreet, 

Inc. 

FTC Matter No. 

C-4761

FTC 

Administrative 

Matter

1/10/2022 Deceptive 

Marketing

Alleged the respondent 

made false or 

misleading claims that 

its products would 

improve business credit 

scores and ratings.

Consent Order

In the Matter of 

Fashion Nova LLC

FTC Matter No. 

C-4759

FTC 

Administrative 

Matter

1/24/2022 Deceptive 

Reviews

Alleged the respondent 

blocked negative 

reviews of its products 

from being posted to its 

website.

Consent Order

United States of 

America v. Vision 

Path, Inc. 

1:22-cv-00176 District of 

Columbia

1/25/2022 Contact Lens 

Rule 

Alleged the defendants 

failed to obtain or 

properly verify 

prescriptions for 

contact lenses and 

substituted their own 

brand for the ones 

prescribed.

Settlement

United States of 

America v. 

Burgerim Group 

USA, Inc. et al.

2:22-cv-00825 Central District 

of California

2/7/2022 Franchise Rule Alleged the defendants 

withheld required 

information to 

encourage consumers 

to purchase fast-food 

franchises.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 53

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

American Vehicle 

Protection 

Corporation et al.

0:22-cv-60298 Southern 

District of 

Florida

2/8/2022 Telemarketing 

Sales Rule

Alleged the defendants 

used deceptive 

telemarketing tactics to 

encourage consumers 

to buy extended 

automobile warranties.

Litigation 

Ongoing

United States of 

America v. Kurbo, 

Inc. et al.

3:22-cv-00946 Northern 

District of 

California

2/16/2022 Children’s 

Online Privacy 

Protection Act 

(COPPA)

Alleged the defendants 

marketed a weight loss 

app for use by children 

as young as eight and 

then collected their 

personal information 

without parental 

permission.

Settlement

United States of 

America v. Turbo 

Solutions Inc. et al.

4:22-mc-00369 Southern 

District of 

Texas

3/1/2022 Credit Repair Alleged the defendants 

falsely claimed they 

would remove negative 

information from credit 

reports and filed fake 

identity theft reports to 

explain negative items 

on customers’ credit 

reports.

Permanent 

Injunction 
FEDERAL TRADE COMMISSION FTC.GOV 54

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. B4B 

Earth Tea LLC et 

al.

1:22-cv-01159 Eastern 

District of New 

York

3/3/2022 COVID-19 

Consumer 

Protection Act

and FTC Act

Alleged the defendants 

made unsubstantiated 

claims that their

product could prevent 

or treat COVID-19.

Litigation 

Ongoing

In the Matter of 

Residual Pumpkin 

Entity, LLC and 

Planetart, LLC 

(CafePress)

FTC Matter 

Nos. C-4768 & 

C-4769

FTC 

Administrative 

Matter

3/11/2022 Data Security Alleged the 

respondents failed to 

implement reasonable 

security measures to 

protect sensitive 

information stored on 

its network.

Consent Order

In the Matter of 

Electronic Payment 

Systems, LLC et al.

FTC Matter No. 

C-4764

FTC 

Administrative 

Matter

3/11/2022 Credit Card 

Laundering

Alleged the 

respondents opened 

credit card processing 

merchant accounts for 

fictitious companies on 

behalf of a business 

opportunity scam

previously sued by the 

FTC.

Consent Order
FEDERAL TRADE COMMISSION FTC.GOV 55

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

HomeAdvisor, Inc. 

FTC Matter No. 

D-9407 

FTC 

Administrative 

Matter

3/11/2022 Lead 

Generation

Alleged the respondent 

used deceptive and 

misleading tactics in 

selling home 

improvement project 

leads to service 

providers.

Pending 

Administrative

Complaint

In the Matter of 

Intuit Inc. 

(TurboTax)

FTC Matter No. 

D-9408

FTC 

Administrative 

Matter

3/28/2022 Deceptive 

Marketing

Alleged the respondent 

deceived consumers 

with advertisements 

pitching “free” tax 

filing that most tax 

filers could not use for 

free. 

Pending 

Administrative

Complaint

Federal Trade 

Commission and 

People of the State 

of Illinois v. North 

American 

Automotive 

Services, Inc. et al.

1:22-cv-01690 Northern 

District of 

Illinois 

3/31/2022 Add-on 

Products / 

Equal Credit 

Opportunity 

Act (ECOA)

Alleged the defendants 

included illegal fees for 

unwanted “add-ons” 

for consumers 

purchasing vehicles 

and discriminated 

against Black 

consumers by charging 

them more for 

financing. 

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 56

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. 

Walmart Inc.

1:22-cv-00965 District of 

Columbia

4/8/2022 Deceptive 

Marketing

Alleged the defendant 

falsely marketed rayon 

textile products as 

bamboo and made 

deceptive 

environmental claims 

about the processing of 

those products. 

Settlement

United States of 

America v. Kohl’s 

Inc.

1:22-cv-00964 District of 

Columbia

4/8/2022 Deceptive 

Marketing

Alleged the defendant 

falsely marketed rayon 

textile products as 

bamboo and made 

deceptive 

environmental claims 

about the processing of 

those products.

Settlement

United States of 

America v. 

Lithionics Battery, 

LLC et al.

8:22-cv-00868 Middle District 

of Florida

4/12/2022 Made in the 

USA 

Deception 

Alleged the defendants 

made false or 

unsubstantiated claims 

that battery systems 

containing significant 

imported content were 

made in the USA.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 57

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Human Resource 

Development 

Services, Inc. et al.

1:22-cv-01919 Northern 

District of 

Illinois 

4/14/2022 Telemarketing 

Sales Rule / 

Holder Rule / 

Credit 

Practices Rule

Alleged the defendants 

deceptively marketed 

medical school license 

exam test pass rate and 

residency matches to 

prospective students 

and violated the Holder 

Rule and the Credit 

Practices Rule.

Settlement

Federal Trade 

Commission v. 

Warrior Trading, 

Inc. et al.

3:22-cv-30048 District of 

Massachusetts

4/19/2022 Restore Online 

Shoppers’ 

Confidence 

Act (ROSCA) / 

Telemarketing 

Sales Rule / 

Misleading 

Earnings 

Claims

Alleged the defendants 

made misleading and 

unfounded claims that 

their purported trading 

system would lead to 

investment gains for 

consumers. 

Settlement

United States of 

America v. Funeral 

& Cremation Group 

of North America,

LLC et al. 

0:22-cv-60779 Southern 

District of 

Florida

4/22/2022 Funeral Rule Alleged the defendants 

misrepresented their 

location and prices, 

illegally threatened and 

failed to return 

cremated remains to 

consumers and failed to 

provide required 

disclosures.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 58

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

United States of 

America v. VOIP 

Terminator, Inc. et 

al.

6:22-cv-00798 Middle District 

of Florida

4/26/2022 Telemarketing 

Sales Rule

Alleged the defendants 

assisted and facilitated 

the transmission of 

illegal prerecorded 

telemarketing calls.

Litigation 

Ongoing

Federal Trade 

Commission v. 

Michael Rando et 

al. (The Credit 

Game)

3:22-cv-00487 Middle District 

of Florida 

5/2/2022 Credit Repair 

Organizations 

Act (CROA) / 

Business 

Opportunities 

Rule / 

Telemarketing 

Sales Rule / 

COVID-19 

Consumer 

Protection Act

Alleged the defendants 

illegally charged 

consumers for credit 

repair services of little 

to no value, filed false 

identity theft reports 

with the FTC, and 

encouraged consumers 

to take unlawful 

actions. 

Litigation 

Ongoing

In the Matter of 

Lions Not Sheep 

Apparel, LLC et al.

FTC Matter No. 

C-4772

FTC 

Administrative 

Matter

5/10/2022 Made in the 

USA 

Deception 

Alleged the 

respondents added false 

labels to its products to 

claim that its imported 

apparel is Made in the 

USA. 

Consent Order
FEDERAL TRADE COMMISSION FTC.GOV 59

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

R360 LLC et al.

0:22-cv-60924 Southern 

District of 

Florida 

5/16/2022 Opioid 

Addiction 

Recovery 

Fraud 

Prevention Act

Alleged the defendants 

deceived people 

seeking help for 

addiction about the 

evaluation and 

selection criteria for the 

treatment centers in 

their network.

Settlement

Federal Trade 

Commission v. 

Financial Education 

Services, Inc. et al. 

2:22-cv-11120 Eastern 

District of 

Michigan

5/23/2022 Credit Repair 

Organizations 

Act (CROA) / 

Telemarketing 

Sales Rule

Alleged the defendants 

made false marketing 

claims about their 

credit repair services 

and encouraged 

consumers to 

participate in an illegal 

pyramid scheme.

Litigation 

Ongoing

United States of 

America v. Twitter, 

Inc.

3:22-cv-03070 Northern 

District of 

California

5/25/2022 Data Privacy / 

Violated a 

2011 FTC 

Order

Alleged the defendant 

misrepresented to users 

the security and privacy 

of nonpublic contact 

information and 

violated a previous 

FTC order prohibiting 

such 

misrepresentations.

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 60

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission v. 

Gravity Defyer 

Medical 

Technology 

Corporation et al.

1:22-cv-01157 District of 

Columbia

5/25/2022 Deceptive 

Marketing / 

Violated a 

2001 FTC 

Order

Alleged the defendants 

made false and 

unsubstantiated claims 

that their shoes could 

relieve pain and 

violated a previous 

FTC order prohibiting 

such 

misrepresentations.

Litigation 

Ongoing

Federal Trade 

Commission and 

Office of the 

Attorney General, 

State of Florida v. 

Treashonna P. 

Graham et al.

(Grant Bae)

3:22-cv-00655 Middle District 

of Florida

6/13/2022 Covid-19 

Consumer 

Protection Act

Alleged the defendants 

made false promises of 

easy access to 

guaranteed grant 

funding and COVID-19 

economic benefits.

Litigation 

Ongoing

In the Matter of 

Harley-Davidson 

Motor Company 

Group, LLC

FTC Matter No. 

2123140

FTC 

Administrative 

Matter

6/22/2022 Right to Repair Alleged the respondent 

illegally restricted 

customers’ right to 

repair their purchased 

products by including 

terms that voided the 

warranties if customers 

used unauthorized

parts. 

Pending 

Consent Order
FEDERAL TRADE COMMISSION FTC.GOV 61

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

MWE Investments, 

LLC 

FTC Matter No. 

2223012

FTC 

Administrative 

Matter

6/22/2022 Right to Repair Alleged the respondent 

illegally restricted 

customers’ right to 

repair their purchased 

products by including 

terms that voided the 

warranties if customers 

used unauthorized

parts.

Pending 

Consent Order

Federal Trade 

Commission v. 

Walmart, Inc.

1:22-cv-03372 Northern 

District of 

Illinois

6/28/2022 Telemarketing 

Sales Rule

Alleged the defendants 

allowed scammers to 

use their money 

transfer services by 

failing to implement 

effective anti-fraud 

policies or trainings.

Litigation 

Ongoing

In the Matter of 

Weber-Stephen 

Products LLC

FTC Matter No. 

2123139

FTC 

Administrative 

Matter

7/1/2022 Right to Repair Alleged the respondent 

illegally restricted 

customers’ right to 

repair their purchased 

products by including 

terms that voided the 

warranties if customers 

used or installed thirdparty parts on their grill 

products.

Pending 

Consent Order
FEDERAL TRADE COMMISSION FTC.GOV 62

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

Federal Trade 

Commission, 

Attorney General of 

the State of 

Connecticut et al. v. 

Harris Originals of 

NY, Inc. et al.

2:22-cv-04260 Eastern 

District of New 

York

7/20/2022 Truth in 

Lending Act /

Military 

Lending Act

Alleged the defendants 

made deceptive claims 

that financing jewelry 

purchases would raise 

customers’ credit 

scores, misrepresented 

that its protection plans 

were required, added 

plans to purchases 

without consumers’ 

consent, and violated 

the Military Lending 

Act.

Settlement

Federal Trade 

Commission v. First 

American Payment 

Systems, LP et al. 

4:22-cv-00654 Eastern 

District of 

Texas

7/29/2022 Deceptive 

Marketing / 

Restore Online 

Shoppers’ 

Confidence 

Act (ROSCA)

Alleged the defendants 

made false claims 

about the costs of their 

services, debited 

consumers’ accounts 

without consent, and 

made it difficult and 

expensive for them to 

cancel the service. 

Settlement
FEDERAL TRADE COMMISSION FTC.GOV 63

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Opendoor Labs Inc.

FTC Matter No. 

1923191

FTC 

Administrative 

Matter

8/1/2022 Deceptive 

Marketing

Alleged the respondent 

falsely represented that 

its home-buying 

service would save 

consumers money 

compared to traditional 

home sales.

Pending

Consent Order

United States of 

America v. Axis 

LED Group, LLC et 

al.

3:22-cv-01389 Northern 

District of 

Ohio

8/5/2022 Made in the 

USA

Deception

Alleged the defendants 

made false and 

misleading claims that 

their PPE products

containing significant 

imported materials

were made in the 

USA.

Litigation 

Ongoing

Federal Trade 

Commission v. 

Benefytt 

Technologies, Inc. 

et al.

8:22-cv-01794 Middle District 

of Florida

8/8/2022 Deceptive 

Marketing / 

Telemarketing 

Sales Rule 

(TSR) / 

Restore Online 

Shoppers’ 

Confidence 

Act (ROSCA)

Alleged the defendants 

misrepresented 

products that provided 

little or no coverage as 

comprehensive health 

insurance plans 

qualified under the 

Affordable Care Act.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 64

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Electrowarmth 

Products, LLC.

FTC Matter No. 

2223096

FTC 

Administrative 

Matter

8/19/2022 Made in the 

USA 

Deception

Alleged the respondent 

falsely represented that 

the textiles used in their 

heated mattress pads 

were made in the 

United States when 

they were wholly 

imported.

Pending 

Consent Order

Federal Trade 

Commission v. 

Kochava, Inc.

2:22-cv-377 District of 

Idaho

8/29/22 Unfair 

Practices

Alleged the defendant 

engaged in unfair 

practices for selling

sensitive geolocation 

data associated with 

consumers’ unique 

persistent identifiers.

Litigation 

Ongoing

Federal Trade 

Commission, 

People of the State 

of California et al. 

v. Roomster Corp. 

et al.

1:22-cv-7389 Southern 

District of New 

York

8/30/22 Deceptive 

Marketing

Alleged the defendants 

used fake reviews to 

bolster their deceptive 

advertisements that 

their housing listings 

were verified and 

authentic.

Litigation 

Ongoing
FEDERAL TRADE COMMISSION FTC.GOV 65

Case Name Case Number Court Name Date of 

Complaint

Case Type Description Outcome

In the Matter of 

Credit Karma, LLC.

FTC Matter No. 

2023138

FTC 

Administrative 

Matter

9/1/22 Deceptive 

Marketing

Alleged the respondent 

made false or 

misleading claims 

regarding consumers’ 

approval or odds of 

receiving approval for 

credit cards or other 

financial products.

Pending 

Consent Order

Federal Trade 

Commission, 

California

Department of 

Financial Protection 

and Innovation v. 

Green Equitable 

Solutions et al.

2:22-cv-06499 Central District 

of California

9/12/22 Deceptive 

Marketing / 

Telemarketing 

Sales Rule / 

COVID-19 

Consumer 

Protection 

Act/Mortgage 

Assistance 

Relief Services 

Rule

Alleged the defendants 

made unsolicited calls 

to consumers pitching 

mortgage relief 

services for an upfront 

fee and falsely claimed 

an affiliation with 

government programs, 

including COVID-19 

government relief 

programs.

Litigation 

Ongoing
Federal Trade Commission

ftc.gov