UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

FILE NO. 202 3138 

In the Matter of 

CREDIT KARMA, LLC, a limited liability AGREEMENT CONTAINING 

company. CONSENT ORDER 

The Federal Trade Commission (“Commission”) has conducted an investigation of 

certain acts and practices of Credit Karma, LLC (“Proposed Respondent”). The Commission’s 

Bureau of Consumer Protection (“BCP”) has prepared a draft of an administrative Complaint 

(“draft Complaint”). BCP and Proposed Respondent, through its duly authorized officers, enter 

into this Agreement Containing Consent Order (“Consent Agreement”) to resolve the allegations 

in the attached draft Complaint through a proposed Decision and Order to present to the 

Commission, which is also attached and made a part of this Consent Agreement. 

IT IS HEREBY AGREED by and between Proposed Respondent and BCP, that: 

1. The Proposed Respondent is: 

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

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

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

2020. 

2. Proposed Respondent neither admits nor denies any of the allegations in the Complaint, 

except as specifically stated in the Decision and Order. Only for purposes of this action, 

Proposed Respondent admits the facts necessary to establish jurisdiction. 

3. Proposed Respondent waives: 

a. Any further procedural steps; 

b. The requirement that the Commission’s Decision contain a statement of findings 

of fact and conclusions of law; and 

c. All rights to seek judicial review or otherwise to challenge or contest the validity 

of the Decision and Order issued pursuant to this Consent Agreement. 

4. This Consent Agreement will not become part of the public record of the proceeding 

unless and until it is accepted by the Commission. If the Commission accepts this 

Consent Agreement, it, together with the draft Complaint, will be placed on the public 

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record for 30 days and information about them publicly released. Acceptance does not 

constitute final approval, but it serves as the basis for further actions leading to final 

disposition of the matter. Thereafter, the Commission may either withdraw its 

acceptance of this Consent Agreement and so notify Proposed Respondent, in which 

event the Commission will take such action as it may consider appropriate, or issue and 

serve its Complaint (in such form as the circumstances may require) and decision in 

disposition of the proceeding, which may include an Order. See Section 2.34 of the 

Commission’s Rules, 16 C.F.R. § 2.34 (“Rule 2.34”). 

5. If this agreement is accepted by the Commission, and if such acceptance is not 

subsequently withdrawn by the Commission pursuant to Rule 2.34, the Commission may, 

without further notice to Proposed Respondent: (1) issue its Complaint corresponding in 

form and substance with the attached draft Complaint and its Decision and Order; and (2) 

make information about them public. Proposed Respondent agrees that service of the 

Order may be effected by its publication on the Commission’s website (ftc.gov), at which 

time the Order will become final. See Rule 2.32(d). Proposed Respondent waives any 

rights it may have to any other manner of service. See Rule 4.4. 

6. When final, the Decision and Order will have the same force and effect and may be 

altered, modified, or set aside in the same manner and within the same time provided by 

statute for other Commission orders. 

7. The Complaint may be used in construing the terms of the Decision and Order. No 

agreement, understanding, representation, or interpretation not contained in the Decision 

and Order or in this Consent Agreement may be used to vary or contradict the terms of 

the Decision and Order. 

8. Proposed Respondent agrees to comply with the terms of the proposed Decision and 

Order from the date that Proposed Respondent signs this Consent Agreement. Proposed 

Respondent understands that it may be liable for civil penalties and other relief for each 

violation of the Decision and Order after it becomes final. 

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CREDIT KARMA, LLC FEDERAL TRADE COMMISSION 

_______________________ _______________________ 

By: EVAN ZULLOW 

LISA ROTHFARB 

Federal Trade Commission 

Date: Attorneys, Bureau of Consumer Protection 

KIRKLAND & ELLIS LLP APPROVED: 

_______________________ 

Rich Cunningham _______________________ 

Olivia Adendorff Sandhya P. Brown 

KIRKLAND & ELLIS LLP Assistant Director 

Division of Financial Practices 

________________________ 

Malini Mithal 

Associate Director 

Division of Financial Practices 

_______________________ 

Samuel Levine 

Director 

Bureau of Consumer Protection 

Date: 

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________________________________________________ 

202 3138 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Noah Joshua Phillips 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of DECISION AND ORDER 

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

________________________________________________ 

DECISION 

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

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

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

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

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

Trade Commission Act. 

Respondent and BCP thereafter executed an Agreement Containing Consent Order 

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

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

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

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

Rules. 

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

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

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

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

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

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

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

following Findings, and issues the following Order: 

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Findings 

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

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

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

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

Respondent, and the proceeding is in the public interest. 

ORDER 

Definitions 

For purposes of this Order: 

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

represented, expressly or by implication, to: 

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

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

secured by real property); or 

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

consumer in receiving, credit or stored value cards. 

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

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

assigns. 

Provisions 

I. Prohibited Misleading and Unsubstantiated Representations 

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

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

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

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

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

A. approval, including pre-approval; or 

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

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

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

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II. Monetary Relief 

IT IS FURTHER ORDERED that: 

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

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

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

the Commission. 

III. Additional Monetary Provisions 

IT IS FURTHER ORDERED that: 

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

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

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

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

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

bankruptcy case. 

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

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

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

such purposes. 

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

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

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

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

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

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

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

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

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

IV. Customer Information 

IT IS FURTHER ORDERED that Respondent must directly or indirectly provide 

sufficient customer information to enable the Commission to efficiently administer consumer 

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

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

within 14 days. 

V. Acknowledgments of the Order 

IT IS FURTHER ORDERED that Respondent obtain acknowledgments of receipt of 

this Order: 

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

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

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

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

managerial responsibilities for conduct related to the subject matter of this Order; and (3) 

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

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

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

before they assume their responsibilities. 

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

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

of this Order. 

VI. Compliance Report and Notices 

IT IS FURTHER ORDERED that Respondent make timely submissions to the 

Commission: 

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

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

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

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

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

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

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

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

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

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

Order, unless previously submitted to the Commission. 

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

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

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

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

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

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

practices subject to this Order. 

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

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

filing. 

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

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

concluding: “I declare under penalty of perjury under the laws of the United States of 

America that the foregoing is true and correct. Executed on: _____” and supplying the 

date, signatory’s full name, title (if applicable), and signature. 

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

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

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

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

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

Docket No. C-. 

VII. Recordkeeping 

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

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

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

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

and resulting net profit or loss; 

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

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

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

for termination; 

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

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

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

representation subject to this Order; 

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

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

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

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

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

communication relate to Respondent’s compliance with this Order; 

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

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

including all submissions to the Commission. 

VIII. Compliance Monitoring 

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

compliance with this Order: 

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

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

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

copying. 

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

communicate directly with Respondent. Respondent must permit representatives of the 

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

interview. The interviewee may have counsel present. 

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

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

any individual or entity affiliated with Respondent, without the necessity of identification 

or prior notice. Nothing in this Order limits the Commission’s lawful use of compulsory 

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

IX. Order Effective Dates 

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

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

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

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

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

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

such a complaint will not affect the duration of: 

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

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

complaint; and 

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

Provision. 

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

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

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

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

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

such dismissal or ruling is upheld on appeal. 

By the Commission. 

April J. Tabor 

Secretary 

SEAL: 

ISSUED: 

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