UNITED ST A TES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF NEW YORK 

FEDERAL TRADE COMMISSION, 

Case No. CV-10-3551 (ILG)(RLM) Plaintiff, 

STIPULATED ORDER FOR 

v. PERMANENT INJUNCTION AND 

MONETARY JUDGMENT AS TO CONSUMER HEAL TH BENEFITS DEFENDANT WENDI TOW ASSOCIATION, organized as a Missouri 

not-for-profit, also doing business as CHBA, 

NATIONAL ASSOCIATION FOR AMERICANS, 

organized as a Missouri not-for-profit, also doing 

business as NAF A, 

NATIONAL BENEFITS CONSULTANTS, LLC, a 

Florida limited liability company, also doing 

business as NBC, 

NATIONAL BENEFITS SOLUTIONS, LLC, a 

Florida limited liability company, also doing 

business as NBS, 

LOUIS LEO, individually, as a Managing Member 

ofNATIONAL BENEFITS CONSULTANTS, 

LCC, as a Managing Member of NATIONAL 

BENEFITS SOLUTIONS, LLC, and as the Vice 

President and Treasurer of CONSUMER HEAL TH 

BENEFITS ASSOCIATION, 

RON WERNER, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULT ANTS, LLC, as a Managing Member of 

NATIONAL BENEFITS SOLUTIONS, LLC, and 

as President and Managing Partner of CONSUMER 

HEALTH BENEFITS ASSOCIATION, 

RITA WERNER, individually, and as Senior Vice 

President and Director of Operations of 

CONSUMER HEAL TH BENEFITS 

AS SOCIA TI ON, 

Case 1:10-cv-03551-ILG-RLM Document 500 Filed 12/09/21 Page 1 of 18 PageID #: 30044 
WENDI TOW, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULT ANTS, LLC, and as a Managing 

Member of NATIONAL BENEFITS SOLUTIONS, 

LLC, 

JOHN SCHWARTZ, individually, as a Managing 

Member of NATIONAL BENEFITS 

CONSULTANTS, LLC, and as a Managing 

Member of NATIONAL BENEFITS SOLUTIONS, 

LLC, 

GUARANTEE TRUST LIFE INSURANCE 

COMPANY, an Illinois corporation, 

VANTAGE AMERICA SOLUTIONS, INC., an 

Illinois corporation, 

CENTURY SENIOR SERVICES, a Florida 

corporation, 

JEFFREY BURMAN, individually, as President of 

VANTAGE AMERICA SOLUTIONS, INC., and as 

Vice President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, 

BARBARA TAUBE, individually, and as Vice 

President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, and 

RICHARD HOLSON, III, individually, and as 

President of GUARANTEE TRUST LIFE 

INSURANCE COMPANY, 

Defendants. 

Plaintiff, the Federal Trade Commission ("Commission" or "FTC"), filed its Complaint 

for Permanent Injunction and Other Relief, subsequently amended as First Amended Complaint 

for Permanent Injunction and Other Relief ("First Amended Complaint"), pursuant to Sections 

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13(b) and 19 of the Federal Trade Commission Act ("FTC Act"), 15U.S;C. §§ 53(b) and 57b. 

The Commission and Defendant Wendi Tow ("Defendant Tow") stipulate to the entry of this 

Stipulated Order for Permanent Injunction and Monetary Judgment as to Defendant Wendi Tow 

("Order") to resolve all matters in dispute in this action between them. 

THEREFORE, IT IS ORDERED as follows: 

FINDINGS 

1. This Court has jurisdiction over this matter. 

2. The First Amended Complaint charges that Defendant Tow participated in deceptive acts 

or practices in violation of Section 5 of the FTC Act, 15 U.S.C. § 45, and the FTC's 

Telemarketing Sales Rule ("TSR"), 16 C.F .R. Part 310, in connection with the marketing and sale 

of medical discount plans. 

3. Defendant Tow neither admits nor denies any of the allegations in the First Amended 

Complaint, except as specifically stated in this Order. Only for purposes of this action, 

Defendant Tow admits the facts necessary to establish jurisdiction. 

4. Defendant Tow waives any claim that she may have under the Equal Access to Justice 

Act, 28 U.S.C. § 2412, concerning the prosecution of this action through the date of this Order, 

and agrees to bear her own costs and attorney fees. 

5. Defendant Tow waives all rights to appeal or otherwise challenge or contest the validity of 

this Order. 

DEFINITIONS 

For the purpose of this Order, the following definitions apply: 

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A. "Clear(ly) and Conspicuous(ly)" means that a required disclosure is difficult to miss 

(i.e., easily noticeable) and easily understandable by ordinary consumers, including in all of the 

following ways: 

1. In any communication that is solely visual or solely audible, the disclosure must be 

made through the same means through which the communication is presented. In any 

communication made through both visual and audible means, such as a television 

advertisement, the disclosure must be presented simultaneously in both the visual and 

audible portions of the communication even if the representation requiring the disclosure 

is made in only one means. 

2. A visual disclosure, by its size, contrast, location, the length of time it appears, and 

other characteristics, must stand out from any accompanying text or other visual elements 

so that it is easily noticed, read, and understood. 

3. An audible disclosure, including by telephone or streaming video, must be 

delivered in a volume, speed, and cadence sufficient for ordinary consumers to easily hear 

and understand it. 

4. In any communication using an interactive electronic medium, such as the Internet 

or software, the disclosure must be unavoidable. 

5. The disclosure must use diction and syntax understandable to ordinary consumers 

and must appear in each language in which the representation that requires the disclosure 

appears. 

6. The disclosure must comply with these requirements in each medium through 

which it is received, including all electronic devices and face-to-face communications. 

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7. The disclosure must not be contradicted or mitigated by, or inconsistent with, 

anything else in the communication. 

8. When the representation or sales practice targets a specific audience, such as 

children, the elderly, or the terminally ill, "ordinary consumers" includes reasonable 

members of that group. 

B. "Defendants" means Consumer Health Benefits Association; National Association for 

Americans; National Benefits Consultants, LLC; National Benefits Solutions, LLC; Guarantee 

Trust Life Insurance Company; Vantage America Solutions, Inc.; Century Senior Services; their 

successors and assigns; Louis Leo; Ron Werner; Rita Werner; Wendi Tow; John Schwartz; 

Jeffrey Burman; Barbara Taube; and Richard Holson, III, individually, collectively, or in any 

combination. 

C. "Escrow Agent" means Steven E. Ostrow, the Court-appointed successor escrow agent in 

this case. 

D. "Healthcare-Related Benefits or Discount Programs" includes any program, 

membership, card, product, or other good or service, which is not insurance, that purports to offer 

discounts, savings, or benefits on healthcare, or access to such discounts, savings, or benefits. 

E. "Insurance" means any good or service that (a) has the effect of transferring or spreading 

risk; (b) is an integral part of the policy relationship between the insurer and the insured; and 

( c) is limited to entities within the insurance industry. 

F. "Seller" means any person who, in connection with a Telemarketing transaction, provides, 

offers to provide, or arranges for others to provide goods or services to the customer in exchange 

for consideration, whether or not such person is under the jurisdiction of the Commission. 

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G. "Telemarketer" means any person who, in connection with Telemarketing, initiates or 

receives telephone calls to or from a customer or donor, whether or not such person is under the 

jurisdiction of the Commission. 

H. "Telemarketing" means any plan, program, or campaign which is conducted to induce 

the purchase of goods or services or a charitable contribution by use of one or more telephones 

and which involves more than one interstate telephone call. 

I. "Defendant Tow" means Wendi Tow. 

ORDER 

I. BAN ON SELLING HEALTHCARE-RELATED 

BENEFITS OR DISCOUNT PROGRAMS 

IT IS ORDERED that Defendant Tow is permanently restrained and enjoined from 

advertising, marketing, promoting, offering for sale, or selling, or assisting in the advertising, 

marketing, promoting, offering for sale, or selling, of any Healthcare-Related Benefits or 

Discount Programs. 

II. PROHIBITION AGAINST MISREPRESENTATIONS 

IT IS FURTHER ORDERED that Defendant Tow, her 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 promoting or 

offering for sale any good or service ( other than Healthcare-Related Benefits or Discount 

Programs) are permanently restrained and enjoined from misrepresenting or assisting others in 

misrepresenting, expressly or by implication: 

A. That consumers will save a substantial sum of money; 

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B. Any material aspect of the nature or terms of the Seller's refund, cancellation, exchange, 

or repurchase policies; and 

C. Any other fact material to consumers concerning any good or service, such as: the total 

costs; any material restrictions, limitations, or conditions; or any material aspect of its 

performance, efficacy, nature, or central characteristics. 

III. PROHIBITION AGAINST VIOLATING THE TSR 

IT IS FURTHER ORDERED that Defendant Tow, her 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, are permanently restrained and 

enjoined from violating any provision of the Telemarketing Sales Rule, 16 C.F .R. Part 310, 

attached as Attachment A, including: 

A. Section 310.3(a)(l)(iii) of the TSR, 16 C.F.R. § 310.3(a)(l)(iii), by failing to disclose 

truthfully, in a Clear and Conspicuous manner, before a customer consents to pay for goods or 

services offered in connection with Telemarketing: (I) if the Seller has a policy of not making 

refunds, cancellations, exchanges, or repurchases, a statement informing the customer that this is 

the Seller's policy; or (2) if the Seller or Telemarketer makes a representation about a refund, 

cancellation, exchange, or repurchase policy, a statement of all material terms and conditions of 

such policy; 

B. Section 310.3(a)(2) of the TSR, 16 C.F.R. § 310.3(a)(2), by misrepresenting, directly or by 

implication, in the sale of goods or services any of the following material information: (1) the 

total costs to purchase, receive, or use, and the quantity of, any goods or services that are the 

subject of a sales offer; (2) any material restriction, limitation, or condition to purchase, receive, 

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or use goods or services that are the subject of a sales offer; (3) any material aspect of the 

performance, efficacy, nature, or central characteristics of goods or services that are the subject of 

a sales offer; or ( 4) any material aspect of the nature or terms of the Seller's refund, cancellation, 

exchange or repurchase policies; and 

C. Section 310.4(d) of the TSR, 16 C.F.R. § 310.4(d), by failing to disclose truthfully, 

promptly, and in a Clear and Conspicuous manner to the person receiving a call in connection 

with Telemarketing: (1) the identity of the Seller; (2) that the purpose of the call is to sell goods 

or services; or (3) the nature of the goods or services. 

IV. MONETARY JUDGMENT 

IT IS FURTHER ORDERED that: 

A. Judgment in the amount of Five Million Dollars ($5,000,000) is entered in favor of the 

Commission against Defendant Tow as monetary relief. 

8. The judgment is suspended subject to the Subsections below. 

C. Defendant Tow shall relinquish any and all right, title, and interest she may possess in any 

funds held by the Escrow Agent, including funds held on behalf of any Defendant, in favor of the 

FTC. 

D. The Commission's agreement to the suspension of the judgment is expressly premised 

upon the truthfulness, accuracy, and completeness of Defendant Tow's sworn financial statements 

and related documents (collectively, "financial representations") submitted to the Commission, 

namely the Financial Statement oflndividual Defendant Wendi Tow signed on June 22,2021, 

including the attachments. 

E. The suspension of the judgment will be lifted as to Defendant Tow if, upon motion by the 

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Commission, the Court finds that Defendant Tow failed to disclose any material asset, materially 

misstated the value of any asset, or made any other material misstatement or omission in the 

financial representations identified above. 

F. If the suspension of the judgment is lifted, the judgment becomes immediately due as to 

Defendant Tow in the amount specified in Subsection A. above (which the parties stipulate only 

for purposes of this Section represents the consumer injury alleged in the First Amended 

Complaint), less any payment previously made pursuant to this Section, plus interest computed 

from the date of entry of this Order. 

G. Defendant Tow 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. 

H. The facts alleged in the First Amended Complaint will be taken as true, without further 

proof, in any subsequent civil litigation by or on behalf of the Commission, including in a 

proceeding to enforce its rights to any payment or monetary judgment pursuant to this Order, such 

as a nondischargeability complaint in any bankruptcy case. 

I. The facts alleged in the First Amended Complaint establish all elements necessary to 

sustain an action by 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. 

J. Defendant Tow acknowledges that her Taxpayer Identification Number (Social Security 

Number), which Defendant Tow previously submitted to the Commission, may be used for 

collecting and reporting on any delinquent amount arising out of this Order, in accordance with 

31 u.s.c. §7701. 

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

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administered by the Commission or its designee to be used for 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 Defendants' practices alleged in the First Amended Complaint. Any money not used 

for such relief is to be deposited to the U.S. Treasury. Defendant Tow has no right to challenge 

any actions the Commission or its representatives may take pursuant to this Subsection. 

L. If Defendant Tow fails to pay fully the amount due at the time specified, Defendant Tow 

must cooperate fully with the Commission and their representatives in all attempts to collect the 

judgment. In such an event, Defendant Tow agrees to provide federal and state tax returns for 

the preceding 2 years, and to complete a new financial disclosure form fully and accurately within 

IO business days of receiving a request from the Commission. Defendant Tow further authorizes 

the Commission to verify all information provided on her financial disclosure form with all 

appropriate third parties, including financial institutions. 

M. The Commission may request any tax-related information, including amended tax returns 

and any other filings, that Defendant Tow has the authority to release. Within 14 days of receipt 

of a written request from a representative of the Commission, Defendant Tow must take all 

necessary steps (such as filing a completed IRS Form 4506 or 8821) to cause the Internal 

Revenue Service or other tax authority to provide the information directly to the Commission. 

V. CUSTOMER INFORMATION 

IT IS FURTHER ORDERED that Defendant Tow, her officers, agents, employees, and 

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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, are permanently restrained and 

enjoined from directly or indirectly: 

A. disclosing, using, or benefitting from customer information, including the name, address, 

telephone number, email address, social security number, other identifying information, sensitive 

health information, or any data that enables access to a customer's account (including a credit 

card, bank account, or other financial account), that any Defendant obtained prior to entry of this 

Order in connection with the sale of medical discount plans; and 

B. failing to destroy such customer information in all forms in their possession, custody, or 

control within 30 days after entry of a stipulated final order against the last remaining Defendant 

or receipt of written direction to do so from a representative of the Commission. 

Provided, however, that customer information need not be disposed of, and may be 

disclosed, to the extent requested by a government agency or required by law, regulation, or court 

order. 

VI. COOPERATION 

IT IS FURTHER ORDERED that Defendant Tow must fully cooperate with 

representatives of the Commission in this case and in any investigation related to or associated 

with the transactions or the occurrences that are the subject of the First Amended Complaint. 

Defendant Tow must provide truthful and complete information, evidence, and testimony. 

Defendant Tow must appear for interviews, discovery, hearings, trials, and any other proceedings 

that a Commission representative may reasonably request upon 5 days written notice, or other 

reasonable notice, at such places and times as a Commission representative may designate, 

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without the service of a subpoena. 

VII. ORDER ACKNOWLEDGMENTS 

IT IS FURTHER ORDERED that Defendant Tow obtain acknowledgments of receipt of 

this Order: 

A. Defendant Tow, within 7 days of entry of this Order, must submit to the Commission an 

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

B. For 3 years after entry of this Order, Defendant Tow for any business that she, 

individually or collectively with any other Defendants, is the majority owner or controls directly 

or indirectly, must deliver a copy of this Order to: (1) all principals, officers, directors, and LLC 

managers and members; (2) all employees, agents, and representatives with managerial 

responsibilities for conduct related to the subject matter of the Order and all agents and 

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

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

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

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

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

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

this Order. 

VIII. COMPLIANCE REPORTING 

IT IS FURTHER ORDERED that Defendant Tow make timely submissions to the 

Commission: 

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

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sworn under penalty of perjury, to: 

1. identify all telephone numbers and all physical, postal, email and Internet 

addresses, including all residences; 

2. identify all business activities, including any business for which Defendant Tow 

performs services whether as an employee or otherwise and any entity in which Defendant 

Tow has any ownership interest; 

3. describe in detail Defendant Tow's involvement in each such business, including 

title, role, responsibilities, participation, authority, control, and any ownership; 

4. 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 Defendant Tow; 

5. identify all of Defendant Tow's businesses by all of their names, telephone 

numbers, and physical, postal, email, and Internet addresses; 

6. describe the activities of each business, including the goods and services offered, 

the means of advertising, marketing, and sales, and the involvement of any other 

Defendant (which Defendant Tow must describe if she knows or should know due to her 

own involvement); 

7. describe in detail whether and how Defendant Tow is in compliance with each 

Section of this Order; and 

8. provide a copy of each Order Acknowledgment obtained pursuant to this Order, 

unless previously submitted to the Commission. 

B. For 5 years after entry of this Order, Defendant Tow must submit a compliance notice, 

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sworn under penalty of perjury, within 14 days of any change in the following: 

I. name, including aliases or fictitious name, or residence address; 

2. title or role in any business activity, including any business for which Defendant 

Tow performs services whether as an employee or otherwise and any entity in which 

Defendant Tow has any ownership interest, and identify the name, physical address, and 

any Internet address of the business or entity; 

3. any designated point of contact; or 

4. the structure of any entity that Defendant Tow has any ownership interest in or 

controls directly or indirectly that may affect compliance obligations arising under this 

Order, including: creation, merger, sale, or dissolution of the entity or any subsidiary, 

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

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

petition, insolvency proceeding, or similar proceeding by or against her 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 

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Consumer Protection, Federal Trade Commission, 600 Pennsylvania Avenue NW, Washington, 

DC 20580. The subject line must begin: FTC v. Tow, X100042. 

IX. RECORDKEEPING 

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

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

any business that she, individually or collectively with any other Defendants, is a majority owner 

or controls directly or indirectly, must create and retain the following records: 

A. accounting records showing the revenues from all goods or services sold; 

B. personnel records showing, for each person providing services, 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 and refund requests, whether received directly or 

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

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

including all submissions to the Commission; and 

E. a copy of each unique advertisement or other marketing material. 

X. COMPLIANCE MONITORING 

IT IS FURTHER ORDERED that, for the purpose of monitoring Defendant Tow's 

compliance with this Order, including the financial representations upon which part of the 

judgment was suspended and any failure to transfer any assets as required by this Order: 

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

Defendant Tow must: submit additional compliance reports or other requested information, 

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which must be sworn under penalty of perjury; appear for depositions; and produce documents for 

inspection and copying. The Commission is also authorized to obtain discovery, without further 

leave of court, using any of the procedures prescribed by Federal Rules _of CivilProcedure,22, 30 

(including telephonic depositions), 3 I, 33, 34, 36, 45, and 69. 

B. For matters concerning this Order, the Commission is authorized to communicate directly 

with Defendant Tow. Defendant Tow must permit representatives of the Commission to 

interview any employee or other person affiliated with her who has agreed to such an interview. 

The person interviewed 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 Defendant Tow or any 

individual or entity affiliated with Defendant Tow, 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-l. 

D. Upon written request from a representative of the Commission, any consumer reporting 

agency must furnish consumer reports concerning Defendant Tow, pursuant to Section 604(1) of 

the Fair Credit Reporting Act, 15 U.S.C. §1681b(a)(l). 

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XI. RETENTION OF JURISDICTION 

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

of construction, modification, and enforcement of this Order. 

SO ORDERED this __ 

8th

day of __________ 

December

2021. 

/s/ I. Leo Glasser

I. LEO GLASSER 

UNITED STATES DISTRICT JUDGE 

SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

/s/ Karen Dahlberg O'Connell 

Karen Dahlberg O'Connell, Attorney 

Federal Trade Commission 

Northeast Region 

I Bowling Green, Suite 318 

New York, NY 10004 

212-607-2821 

212-607-2822 (fax) 

koconnell@ftc.gov 

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SO STIPULATED AND AGREED: 

FOR PLAINTIFF: 

FEDERAL TRADE COMMISSION 

Karen Dahlberg O'Connell, Attorney 

Federal Trade Commission 

Northeast Region 

l Bowling Green, Suite 318 

New York~ NY I 0004 

212-607-2821 

212-607-2822 (fax) 

koconnell@ftc.gov 

FOR DEFENDANT TOW: 

Date: Jfa IL I 

:vfartin R. Raskin 

Raskin & Raskin. P.A. 

Miami Office 

Suntrust Plaza 

201 Alhambra Circle 

Suite 1050 

Coral Gables. Florida 33134 

305-444-3400 

mrasKin@raskinlaw.com 

DEFENDANT TOW: 

WENDI TOW~ INDIVIDUA[LY 

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