Serving Communities of Color 

A Staff Report on the Federal Trade Commission’s

Efforts to Address Fraud and Consumer Issues

Affecting Communities of Color 

Federal Trade Commission

October 2021
Serving Communities of Color

A Staff Report on the Federal Trade Commission’s Efforts to Address 

Fraud and Consumer Issues Affecting Communities of Color

October 2021

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Acknowledgements

The primary drafters of this staff report are Joannie Wei, Midwest Region, Rosario Méndez, 

Division of Consumer and Business Education, and Kati Daffan, Patti Poss, and Rhonda Perkins,

Division of Marketing Practices. This staff report reflects the work of staff throughout the Federal Trade 

Commission’s Bureau of Consumer Protection and its Regional Offices, as well as that of Dr. Devesh 

Raval, an Economist in the Bureau of Economics. Much of the work stems from the FTC’s Every 

Community Initiative, which currently includes the following members:

Heather Allen

Faye Chen Barnouw

Margaret Burgess

Nick Coates

Kristin Cohen

Kati Daffan

Maria Del Monaco

Ami Dziekan

Robin Eichen

Emma Fletcher

Luis Gallegos

Seena Gressin

Carolyn Hann

Karen Hobbs

Eddie Hynes

Adrienne Jenkins

Tara Koslov

Ari Lazarus

Jennifer Leach

Amber Lee

Karen Mandel

Rosario Méndez

Kate Moody

Kerry O’Brien

Rhonda Perkins

Patti Poss

Lisa Rothfarb

Dan Salsburg

Matt Schiltz

Maricela Segura

Gideon Sinasohn 

Bridget Small

Annette Soberats

Laura Solis

Claire Stewart

Monica Vaca

Delilah Vinzon

Joannie Wei

Robin Wetherill

Devin Willis

Erika Wodinsky

Nicole Worley

Emily Wu

The views expressed in this report are those of the authors and do not necessarily reflect the 

views of the Commission or any individual Commissioner.
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Table of Contents

Acknowledgements..............................................................................................................i

Executive Summary ...........................................................................................................1

I. Introduction................................................................................................................4

II. Law Enforcement Affecting Communities of Color..............................................6

A. Automobile Buying Issues........................................................................................................ 7

B. For-Profit School Advertising ................................................................................................ 10

C. Student Loan Debt Relief ....................................................................................................... 11

D. Marketing Prepaid Cards........................................................................................................ 12

E. Government Impersonators .................................................................................................... 12

F. Marketing for Inmate Services............................................................................................... 14

G. Deceptive and Unsubstantiated Advertising Claims.............................................................. 15

H. Jobs and Money-Making Opportunities................................................................................. 16

I. Credit, Background Checks, and Access to Housing ............................................................. 20

J. Payday Loans and Debt Collection......................................................................................... 21

III. Outreach and Education Initiatives to Communities of Color .......................23

A. Listening to Communities ...................................................................................................... 23

B. Engaging Ethnic and Community Media ............................................................................... 25

C. Connecting with Trusted Partners .......................................................................................... 27

D. Educating Through Storytelling ............................................................................................. 29

E. Serving Communities in Various Languages......................................................................... 30

F. Responding to the COVID-19 Pandemic ............................................................................... 31

G. Making Reporting Channels More Accessible....................................................................... 34
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IV. FTC Workshops and Industry Studies.................................................................35

A. Workshops.............................................................................................................................. 35

B. Industry Studies...................................................................................................................... 38

C. Advocacy Work Related to the Equal Credit Opportunity Act.............................................. 39

V. Research Relating to Communities of Color ........................................................40

A. Differences in the Prevalence of Fraud .................................................................................. 40

B. Disparities in Consumer Reporting of Marketing Practices................................................... 41

1. Rates of Reporting........................................................................................................... 41

2. Types of Reports ............................................................................................................. 43

3. Payment Methods Reported ............................................................................................ 45

C. Disparities in FTC Cases........................................................................................................ 46

VI. Looking Forward .....................................................................................................47

Appendix A .......................................................................................................................50
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Executive Summary

The Federal Trade Commission’s core mission is to protect all consumers from unfair and 

deceptive practices in the marketplace. What has become abundantly clear based on research and 

experience is that fraud, as well as certain other business practices, have a disproportionately negative 

impact on communities of color, as compared to White communities. The COVID-19 pandemic has only 

further exposed and exacerbated these disparities.

The FTC’s Every Community Initiative, created in 2014, has served to modernize and expand 

the agency’s work and to develop a strategic plan for addressing disparities and other issues affecting 

communities of color. In June 2016, the Federal Trade Commission issued the congressionally mandated 

report, Combating Fraud in African American & Latino Communities: The FTC’s Comprehensive 

Strategic Plan (hereinafter “2016 Report”), which detailed the agency’s strategy to reduce fraud in 

Black and Latino communities, summarizing the FTC’s relevant law enforcement work as well as its 

targeted consumer outreach and education initiatives. 

During the five years since the issuance of the 2016 Report, the FTC has made extensive strides 

in addressing fraud in Black and Latino communities. It has also expanded its efforts to include other 

communities of color such as Asian American and Native American communities, and other non-fraud 

related consumer issues that also disproportionately affect communities of color. This report provides an 

update on the FTC’s progress, with a focus on law enforcement, outreach, engagement, and research. 

The FTC engages in aggressive law enforcement to protect people in all communities across the 

country. Since 2016, the FTC has brought more than 25 actions where the agency could identify that the 

conduct either specifically targeted or disproportionately impacted communities of color. Case examples 

came from many areas that the FTC regulates.

• Auto buying cases, for example, involved defendants who allegedly: discriminated – blatantly 

so – against Black and Latino car buyers; falsified information on the applications and contracts 

of Navajo people; and targeted the Latino community with deceptive ads in Spanish. 

• For-profit colleges allegedly targeted Latinos – along with military consumers – with ads and 

lead generation that created false impressions about those colleges and possible job 

opportunities. And still more defendants allegedly targeted Spanish speakers with false promises 

of student loan forgiveness – and illegal upfront fees. Case data for several other student loan 

debt relief cases also showed a significant, disproportionate impact on Black communities.

• Scammers often gain credibility by posing as someone official. For example, one defendant 

marketed prepaid cards to Black and Latino customers, allegedly saying their cards were like 

Visa or MasterCard – when, really, people either could not use the cards or lost all the money 

they loaded on them. Defendants who allegedly pretended to be the government – or affiliated 
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with it – marketed bogus immigration form preparation services and language courses to Spanish 

speakers. 

• According to the FTC, marketers capitalized on health concerns during the pandemic to push 

unproven products and services claimed to prevent, treat, or cure COVID-19, including products 

advertised to Spanish-, Korean-, and Vietnamese-speaking communities. 

• Scammers also take advantage of people’s entrepreneurial spirit and their need to earn a living. 

So-called business “opportunities” and pyramid schemes allegedly made false promises about 

earning potential, either targeting the Latino community directly or with conduct that had a 

disproportionate impact on communities of color.

• Law violations related to debt, credit, and credit reporting can also disproportionately affect 

communities of color. Those include payday lending, credit and consumer reporting accuracy, 

tenant screening, and housing – all of which are areas where the FTC has brought numerous 

enforcement actions over the past five years. 

Outreach is an integral part of the FTC’s work to protect consumers in all communities. The FTC 

has grown its outreach efforts to reach communities of color by listening to and working with trusted 

sources in those communities to deliver consumer protection messages in an effective way. The FTC 

has:

• Convened community partners, government agencies, and other stakeholders across the 

country, including ethnic media, to build and strengthen partnerships, learn about consumer 

protection issues communities are facing across the country, and encourage networking and 

further collaboration among the partners and with the FTC. 

• Worked with national groups like the NAACP, the Legal Services Corporation, and the 

National Association of Consumer Advocates, among others, to reach communities of color,

but also with local organizations like faith-based groups, housing organizations, libraries, 

Tribal governments, and others across the country, including Puerto Rico. 

• Created consumer education materials in multiple formats and languages, including 

Spanish, Chinese, Korean, Tagalog, and Russian, among others, and worked with partners to get 

these resources into the hands of people that need information in their language.

• Responded quickly to the impact of the COVID-19 pandemic by creating educational 

materials in multiple formats and languages to alert people to scams and offer helpful 

information to those affected financially by the national emergency.

The FTC also has conducted numerous workshops and industry studies to explore consumer 

protection issues across a variety of topics, many of which impact communities of color. These 

workshops covered changing consumer demographics; restrictions imposed by manufacturers on the 
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reparability of products; accuracy in consumer reporting; digital “dark patterns;” how social media and 

video streaming services collect, use, and present data; and how broadband companies collect, use, and 

disclose information. The FTC also has engaged in advocacy work related to the Equal Credit 

Opportunity Act (“ECOA”) to protect communities of color in credit transactions. In addition, the FTC 

has issued business guidance to highlight that the use of racially-biased algorithms could be an unfair 

practice under the FTC Act.

The FTC has updated research related to communities of color that further informs the FTC’s 

work to protect consumers. New analysis of the consumer reports in the FTC’s Consumer Sentinel 

Network shows disparities in the reporting rates from Black, Latino, and White communities.

• Communities with different demographic populations filed reports at different rates –

predominantly Black communities filed consumer reports at a higher rate than predominantly 

White or Latino communities. 

• Communities with different demographic populations reported different types of concerns at 

different rates. 

o People living in majority Black communities filed higher percentages of reports than 

majority White communities related to credit bureaus, banks and lenders, used auto 

issues, and debt collection.

o People living in majority Latino communities filed higher percentages of reports than 

majority White communities about credit bureaus, banks and lenders, debt collection, 

auto issues, and business opportunities. 

• Analysis of reports filed by different demographic populations has shown differences in the 

payment method used by those communities. People living in majority Black and Latino 

communities filed a higher percentage of reports that included paying with debit cards, cash, 

crypto currency, and money orders – payment methods with fewer fraud protections – than 

majority White communities. In contrast, people living in majority Black and Latino 

communities filed a lower percentage of reports involving payment by credit card – a payment 

method with more fraud protection – than majority White communities.

• Analysis of data from some FTC cases has revealed disparities in the communities that 

were impacted by fraud and other consumer issues. In cases involving payday loan 

applications, student debt relief programs, and certain business opportunities, the largest number 

of affected consumers resided in predominantly Black communities.

Despite the agency’s efforts, there is much work left to do. The FTC will continue to prioritize 

this work and dedicate the resources necessary in this area, including by expanding the FTC’s efforts 

related to surveillance, algorithmic bias, and other emerging issues that may disproportionately affect

communities of color.
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I. Introduction

The FTC’s consumer protection mission is to protect people from all corners of the country from 

unfair and deceptive business practices. The FTC has always worked for all consumers, but research and 

experience make clear that fraud and other unlawful practices can target, or have a disproportionate 

negative impact on, communities of color. Fulfilling the agency’s mission requires an understanding of 

the ways such communities are affected, and a comprehensive plan to meet the needs of the diverse

U.S. population.

In 2014, as the FTC celebrated its centennial anniversary and assessed its readiness to meet the 

challenges of the future, it launched the Every Community Initiative to modernize, expand, and bring 

together under a cohesive strategic vision the agency’s work to address the disproportionate impact of 

fraud and other practices on communities of color. The FTC has assessed these issues and developed

more sophisticated strategies to combat consumer problems for these communities, with a focus on law 

enforcement, outreach and education, and research to accomplish its goals.

1

The Every Community Initiative focuses on a number of communities and population segments, 

including Black Americans, Latinos, Asian Americans, Native Americans, older adults, lower-income 

communities, veterans and service members, immigrant groups, students, women, LGBTQ+ people, the 

disability community, minority-owned small businesses, rural communities, children in foster care, 

incarcerated and re-entry populations, and others. As one key example, the Initiative collaborates with 

legal services providers on consumer protection issues facing low-income consumers, connecting them 

with FTC resources and helping the FTC learn about the issues affecting their clients. 

In June 2016, the FTC issued a congressionally mandated report, Combating Fraud in African 

American & Latino Communities: The FTC’s Comprehensive Strategic Plan (hereinafter “2016 

Report”).2 The report summarized the FTC’s work to protect consumers in these communities, including 

descriptions of relevant law enforcement and outreach efforts. As discussed in Section II, the report 

recognized that fraud can disproportionately affect Black3 and Latino communities. The report laid out a 

comprehensive strategy to reduce fraud in these communities – a strategy grounded in prevention, law 

enforcement, and consumer outreach and education. The report included, among other things, key 

recommendations to:

 1 The Every Community Initiative team consists of staff throughout the Bureau of Consumer Protection and the Regional 

offices, with the Bureau of Economics contributing heavily to the research work. A representative of the Bureau of 

Competition has recently joined the Initiative. 2 The full report can be found at https://www.ftc.gov/system/files/documents/reports/combating-fraud-african-americanlatino-communities-ftcs-comprehensive-strategic-plan-federal-trade/160615fraudreport.pdf. 3 The 2016 congressional report used the term “African American” but this update will use the term “Black” to more 

accurately refer to the intended community in its entirety. See, e.g., National Association of Black Journalists Style Guide

(June 2020), available at https://www.nabj.org/page/styleguide (“Not all black people are African Americans (if they were 

born outside of the United States). . . . In a story in which race is relevant and there is no stated preference for an individual 

or individuals, use black because it is an accurate description of race.”). This report also uses the term “Latino” rather than 

“Hispanic,” although many of the research, reports, and cases referenced may use the term Hispanic.
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• Continue to bring law enforcement actions that shut down frauds affecting Black and Latino 

communities;

• Maximize the availability and accessibility of the FTC’s education materials to Black and Latino 

communities, including making materials widely available in both English and Spanish;

• Expand the FTC’s efforts to work with state, local, and community partners and diverse media 

outlets to share FTC education information with Black and Latino communities; and

• Conduct additional research to identify and target frauds affecting Black and Latino 

communities.

The FTC has made extensive efforts to reach those goals. The FTC has brought numerous cases 

that have a direct or indirect impact on communities of color; created additional education materials and 

campaigns to reach a broader audience; organized or participated in hundreds of outreach events to 

reach these communities, which has resulted in more partnerships with trusted community advocates; 

and conducted research and held workshops and listening sessions to better understand disparities in the 

marketplace for people from different communities. In addition, since the start of the pandemic, the FTC 

has made it a top priority to combat the negative effects of the COVID-19 pandemic on consumers.4

The pandemic has had a disproporitionate impact on communities of color, exacerbating health 

and financial stressors. Scammers prey on people’s fears about cures and treatments, as well as their

financial struggles.5 Moreover, research shows that Black,6 Latino, and Native American7 households 

have been disproportionately impacted by the coronavirus pandemic, both in terms of illness and death 

from the virus, and other serious issues like problems with financial security, jobs, health care, housing, 

transportation, caregiving, and well-being.8 The majority of these households report “serious financial 

problems,” with issues ranging from “depleting their savings to serious problems paying for food and 

rent.”9 These households also face problems with internet connectivity, which can impact employment 

and schoolwork.10 Reports show that the Latino community, in particular, has faced large losses in 

 4 See generally, FTC Staff Report, Protecting Consumers During the COVID-19 Pandemic: A Year in Review (Apr. 2021), 

available at https://www.ftc.gov/system/files/documents/reports/protecting-consumers-during-covid-19-pandemic-yearreview/covid_staff_report_final_419_0.pdf (hereinafter “FTC COVID-19 Report”). 5 See, e.g., FTC Consumer Alert, Coronavirus: Scammers follow the headlines (Feb. 10, 2020), available at

https://www.consumer.ftc.gov/blog/2020/02/coronavirus-scammers-follow-headlines. 6 NIH, The Disproportional Impact of COVID-19 on African Americans (Dec. 2020), available at

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7762908/. 7 University of Boston, the COVID Racial Data Tracker, COVID is affecting Black, Indigenous, Latinx, and other people of 

color the most (Mar. 2021), available at https://covidtracking.com/race. 8 NPR et al., The Impact of Coronavirus on Households, by Race/Ethnicity at 1 (Sept. 2020), available at

https://drive.google.com/file/d/1XoV6pqzvtag4E9YQeLRTvHaWAlN-s830/view. 9 Id. at 2. 10 Id.
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employment, due perhaps to the impact of the pandemic on the service industry.11 Growing evidence 

shows a disproportionate impact on Asian Americans as well, as compared to their White12 peers, in 

many of these same categories.13 These disparities mean that scams and other harmful practices 

perpetrated on communities of color can have an outsized impact on people who are already suffering 

some of the worst effects of a global crisis.

The FTC recognizes that continuing to tackle these many issues will require strategic and 

creative use of its resources, and the agency is committed to this work. This report provides an update 

about the FTC’s efforts since the 2016 Report and includes a broader view of the types of consumer 

issues under the FTC’s jurisdiction – beyond fraud and scams. Finally, the report concludes with a 

roadmap for action and recommendations going forward.14

II. Law Enforcement Affecting Communities of Color

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

color.15 Most FTC cases involve schemes affecting a wide range of communities. In some cases, the 

population affected by a case is obvious, such as when the defendant advertised in Spanish. Identifying 

 11 Latinos Face Disproportionate Health and Economic Impacts From COVID-19, Center for American Progress (Mar. 

2021), available at https://www.americanprogress.org/issues/economy/reports/2021/03/05/496733/latinos-facedisproportionate-health-economic-impacts-covid-19/. 12 The FTC will capitalize “white” in this report when referring to race and ethnicity. This conforms with the 

recommendation of the National Association of Black Journalist’s (“NABJ”) Style Guide, see NABJ Statement on 

Capitalizing Black and Other Racial Identifiers (June 2020), available at https://www.nabj.org/page/styleguide, as well as 

the guidance from numerous other organizations. See, e.g., The Diversity Style Guide, available at 

https://www.diversitystyleguide.com/; Ann Thuy Nguyen et al., Recognizing Race in Language: Why We Capitalize “Black” 

and “White,” Center for the Study of Social Policy (Mar. 23, 2020), available at https://cssp.org/2020/03/recognizing-racein-language-why-we-capitalize-black-and-white/; see Kristen Mack et al., Capitalizing Black and White: Grammatical 

Justice and Equity, MacArthur Foundation (Aug. 26, 2020), available at

https://www.macfound.org/press/perspectives/capitalizing-black-and-white-grammatical-justice-and-equity; Kwame Anthony 

Appiah, The Case for Capitalizing the B in Black, The Atlantic (June 18, 2020), available at 

https://www.theatlantic.com/ideas/archive/2020/06/time-to-capitalize-blackand-white/613159/; WashPost PR Blog, The 

Washington Post announces writing style changes for racial and ethnic identifiers (July 29, 2020), available at

https://www.washingtonpost.com/pr/2020/07/29/washington-post-announces-writing-style-changes-racial-ethnicidentifiers/. 13 Matthew K. Chin et al., Asian American Subgroups and the COVID-19 Experience: What We Know and Still Don’t Know, 

Health Affairs Blog (May 24, 2021), available at https://www.healthaffairs.org/do/10.1377/hblog20210519.651079/full/. 14 This work supports the agency’s broader work to implement the Executive Order on Advancing Racial Equity and Support 

for Underserved Communities Through the Federal Government (Jan. 20, 2021), available at

https://www.whitehouse.gov/briefing-room/presidential-actions/2021/01/20/executive-order-advancing-racial-equity-andsupport-for-underserved-communities-through-the-federal-government/. 15 When staff identifies unfair or deceptive acts or practices that harm consumers, or violations of rules promulgated by the 

FTC, the FTC often sues the actors in federal district court seeking injunctive and monetary relief, though the ability to obtain 

monetary relief pursuant to Section 13(b) of the FTC Act was recently limited by the Supreme Court in AMG Capital Mgmt., 

LLC v. FTC, 141 S.Ct. 1341 (Apr. 2021). The agency also can bring cases through the administrative process. In some 

circumstances, the DOJ files cases on the FTC’s behalf for rule violations or to secure civil penalties for violations of FTC 

administrative orders.
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cases affecting certain communities of color, when the marketing language is in English, is more 

difficult. Deliberate efforts are necessary to ensure the FTC’s law enforcement efforts are responsive to 

the needs of diverse communities the agency serves in this country. To this end, the FTC has developed 

targeting and tracking tools to help identify potential case leads. These efforts, combined with the 

research and community engagement described in this report, have resulted in the filing of a variety of 

enforcement actions affecting communities of color. Below is a summary of more than 25 FTC

enforcement actions since June 2016 that directly or indirectly combatted practices harmful to

communities of color.

A. Automobile Buying Issues

For many consumers, buying a car is one of the 

most expensive purchases they make – and one of the most 

essential. The FTC has brought numerous cases alleging 

deceptive practices in the sale of cars.16 Research indicates 

that consumers of color experience discrimination in the 

sale and financing of cars, and often pay higher prices as a 

result.17 As described more fully below, FTC cases have challenged discrimination, unfair practices, and 

deception in the sale of cars to specific demographic communities. 

In Bronx Honda,

18 the FTC alleged that the company and its general manager discriminated 

against Black and Latino car buyers. The defendants were accused of violating the ECOA when 

arranging financing for customers by charging the average Black and Latino borrowers about $163 and 

$211 more in interest, respectively, than similarly situated non-Latino White borrowers. The defendants 

allegedly told employees that these groups should be targeted due to their limited education, and not to 

try the same practices with non-Latino White customers. The FTC also alleged that Bronx Honda 

advertised vehicles for sale at a specific price but failed to honor those prices, targeting those ads to

 16 See, e.g., In the Matter of CarMax, Inc., No. C-4605 (FTC filed Mar. 22, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3202/carmax-inc-matter; In the Matter of Asbury Automotive 

Group, Inc., No. C-4606 (FTC filed Mar. 22, 2017), available at https://www.ftc.gov/enforcement/cases-proceedings/152-

3103/asbury-automotive-group-inc-matter-0; In the Matter of West-Herr Automotive Group, Inc., No. C-4607 (FTC filed 

Mar. 22, 2017), available at https://www.ftc.gov/enforcement/cases-proceedings/152-3105/west-herr-automotive-group-incmatter-0; FTC v. Norm Reeves, Inc., No. 8:17-cv-01942 (C.D. Cal. filed Nov. 3, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/c-4436/norm-reeves; In the Matter of Traffic Jam Events, LLC, No. 9395 

(FTC filed Aug. 7, 2020), available at https://www.ftc.gov/enforcement/cases-proceedings/x200041-2023127/traffic-jamevents-llc-matter. 17 John W. Van Alst, Time to Stop Racing Cars: The Role of Race and Ethnicity in Buying and Using a Car, National 

Consumer Law Center (Apr. 2019), available at https://www.nclc.org/images/pdf/car_sales/report-time-to-stop-racing-carsapril2019.pdf; see also Lisa Rice & Erich Schwartz Jr., Discrimination When Buying a Car: How The Color of Your Skin 

Can Affect Your Car-Shopping Experience, National Fair Housing Alliance (Jan. 2018), available at

https://nationalfairhousing.org/wp-content/uploads/2018/01/Discrimination-When-Buying-a-Car-FINAL-1-11-2018.pdf. 18 FTC v. Liberty Chevrolet, No. 1:20-cv-03945 (S.D.N.Y. filed May 21, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/162-3238/bronx-honda.

FTC cases have challenged 

discrimination, unfair practices, and 

deception in the sale of cars to 

specific demographic communities.
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predominantly Black or Latino neighborhoods. To settle these and other alleged violations, the 

defendants paid $1.5 million, which was returned to consumers as redress.

In Tate’s Auto,

19 the FTC alleged that a group of four auto dealerships and their owner falsified 

consumers’ income on vehicle financing applications, falsified consumers’ down payment information 

on financing applications and contracts, and disseminated deceptive ads offering vehicles for sale, 

financing, and lease. Many of Tate’s Auto’s customers were citizens of the Navajo Nation, and Tate’s 

Auto frequently ran radio and print ads in Navajo media. The FTC settled with the auto dealerships in 

August 2020, requiring them to cease operations and obtaining a suspended monetary judgment20 of 

$7,203,227. In July 2021, the FTC settled with the individual defendant, prohibiting him from making 

misrepresentations and falsifying financial information in connection with selling vehicles, and 

obtaining $450,000 for consumer redress.

The FTC has brought actions against other auto dealers alleged to have engaged in deceptive 

advertising, including Spanish-language advertising. In Sage Auto Group,

21 the FTC alleged the 

defendants made enticing claims about key terms – such as the sales price, monthly payment amount, 

and down payment amount – in Spanish, and other languages, but hid additional material terms in 

English. The FTC further alleged that the defendants subjected consumers, particularly non-English 

speakers and individuals with poor credit, to deceptive, misleading, and unfair practices when offering 

add-on products and services or when arranging 

financing. To settle the FTC’s charges, the defendants 

paid $3.6 million to return to consumers.

An analysis of the full list of consumers contacted for 

redress22 in this case by Dr. Devesh Raval, an 

economist in the FTC’s Bureau of Economics, 

showed that consumers affected were 539% more 

likely to live in a majority Latino zip code compared 

to the general population. 

In Cowboy Toyota,

23 the FTC alleged that an auto dealer placed illegal Spanish-language ads in a 

Spanish-language newspaper. These ads, said the FTC, prominently touted the availability of deals for

 19 FTC v. Tate’s Auto Ctr., No. 3:18-cv-08176 (D. Ariz. filed July 31, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/162-3207/tates-auto-center. 20 Due to the bankruptcy of the auto dealerships, the FTC’s judgment is for general unsecured claims against the dealerships 

in their bankruptcy proceedings. The settlement order prohibits the bankruptcy trustee from challenging the FTC’s claims, 

which are deemed allowed in the individual bankruptcy proceedings. 21 FTC v. Universal City Nissan, Inc., No. 2:16-cv-07329 (C.D. Cal. filed Sept. 29, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3008/universal-city-nissan-inc-et-al. 22 During the course of an investigation or litigation, the FTC may gain access to the list of consumers who purchased a 

defendant’s goods or services, i.e., the “customer database.” In cases where the FTC is able to refund money to consumers, 

this database often is a valuable tool in locating consumers. 

23 In the Matter of Cowboy AG LLC, No. 1723009 (FTC filed Jan. 4, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3009/cowboy-ag-llc-matter.

An analysis of the full list of consumers 

contacted for redress in this case . . . 

showed that consumers affected were 

539% more likely to live in a majority 

Latino zip code compared to the 

general population.
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consumers with bad credit, but included fine print disclaimers written in English that contradicted the 

prominent claims. The defendant dealer agreed to a settlement order that, among other things, prohibits

future misrepresentations regarding cost and availability of vehicles, requires accurate representations of 

any qualifications or restrictions on a consumer’s ability to obtain offered financing or leasing terms,

and requires clear and conspicuous disclosure of all financing and leasing terms in advertisements. The 

order also required the disclosures to be made in the same language the representations are made — a 

standard requirement of FTC orders. 

Advertisement from Cowboy Toyota Complaint and Corresponding Fine Print Disclaimer24

In Southwest Kia,

25 the U.S. Department of Justice (“DOJ”), acting on behalf of the FTC, alleged 

that the dealer made claims in Spanish-language ads without properly disclosing the terms necessary to 

understand the offer, in violation of a prior consent order between the company and the FTC. The 

company paid a civil penalty of $85,000 to resolve the charges. 

 24 See supra note 23, Complaint, ¶¶ 8, 11, & Exhibit A, available at 

https://www.ftc.gov/system/files/documents/cases/cowboy_complaint_.pdf and

https://www.ftc.gov/system/files/documents/cases/cowboy_exhibit_a_0.pdf (translation: Deals available to individuals with 

bad credit without requiring a down payment, a Social Security number, or a driver’s license). 25 United States v. New World Auto Imports, Inc., No. 3:16-cv-02401 (N.D. Tex. filed Aug. 18, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/132-3165/new-world-auto-imports-inc-dba-southwest-kia-et-al-matter.
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B. For-Profit School Advertising

Research shows that communities of color are 

disproportionately represented at for-profit colleges,

26

and the FTC has alleged problematic advertising 

practices by for-profit colleges that involved – and at 

times targeted – students in these communities. In 

University of Phoenix,

27 the FTC alleged that the 

defendants relied on deceptive advertising to attract 

students, including specific ads that targeted Latino

consumers, as well as members of the military.

The companies’ ads featured employers such as Microsoft, Twitter, Adobe, and Yahoo!, giving the false 

impression that the school worked with those companies to create job opportunities for its students and 

tailored its curriculum for such jobs. Under a settlement, the defendants were required to pay $50 

million in cash and cancel $141 million in debts owed to the school by students who were harmed by

the deceptive ads. Dr. Raval analyzed the customer database in this case and determined that consumers 

affected were 64% more likely to live in a majority Black zip code compared to the general 

population.28

In Career Education Corporation,29 the FTC alleged that the defendants used an illegal and 

deceptive scheme to lure consumers to their post-secondary and vocational schools, including by using 

lead generators that posed online as official U.S. military recruiters or as job-finding services. Some of 

the defendants’ marketing targeted certain demographics, such as military or Spanish-speaking 

consumers. Under a settlement, the defendants were required to pay $30 million and launch a system to 

review all materials that lead generators use to market defendants’ schools, among other relief. The FTC 

recently sent payments totaling nearly $30 million to more than 8,000 people in this case.

30 

 26 Dyvonne Body, Worse Off Than When They Enrolled: The Consequence of For-Profit Colleges for People of Color, Aspen 

Institute (Mar. 19, 2019), available at https://www.aspeninstitute.org/blog-posts/worse-off-than-when-they-enrolled-theconsequence-of-for-profit-colleges-for-people-of-color. 27 FTC v. The University of Phoenix, Inc., No. 2:19-cv-05772 (D. Ariz. filed Dec. 10, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/152-3231/university-phoenix-inc. 28 In another case, DeVry University, Dr. Raval found that the people affected were over 92% more likely to live in a Black 

majority zip code compared to the general population. FTC v. DeVry Educ. Grp, Inc., No. 2:16-cv-00579 (C.D. Cal. filed Jan. 

27, 2016), available at https://www.ftc.gov/enforcement/cases-proceedings/132-3278/devry-university. The FTC alleged that 

the defendants’ ads deceptively touted high employment success rates and income levels upon graduation. 29 FTC v. Career Educ. Corp., No. 1:19-cv-05739 (N.D. Ill. Filed Aug. 27, 2019), available at

https://www.ftc.gov/enforcement/cases-proceedings/152-3264/career-education-corporation. 30 See Press Release, FTC, FTC Sends Nearly $30 Million in Refunds to People Tricked into Enrolling by School Operator’s 

Lead Generators (June 2021), available at https://www.ftc.gov/news-events/press-releases/2021/06/ftc-sends-nearly-30-

million-refunds-people-tricked-enrolling. 
FEDERAL TRADE COMMIS SION FTC. GOV 11

C. Student Loan Debt Relief

Since 2016, the FTC has brought 

sixteen enforcement actions against student 

loan debt relief operations and led a joint effort 

that included 36 legal actions by the FTC,

along with eleven states and the District of 

Columbia. Analysis of the customer data in 

student debt relief cases filed by the FTC

reveals the substantial effects of these schemes 

on communities of color.31 Dr. Raval matched 

the zip code information of consumers affected in two FTC cases, EZ Docs Prep and Strategic Student 

Solutions, to the U.S. Census Bureau demographic information and found that “communities with a 

100% Black population were affected by these cases [had] a 190% higher rate of victimization [in these 

two cases] than 0% Black communities . . . .”32 Further analysis of the customer databases for four

student loan debt relief cases, Strategic Student Solutions,

33 Manhattan Beach Venture,34 Student Debt 

Relief Group,

35 and American Student Loan Consolidators,36 revealed that the people affected in the 

cases were over 196%, 170%, 130%, and 116% more likely to live in a Black majority zip code

compared to the general population. FTC staff provided assistance to the California Department of 

Justice’s parallel investigation of Manhattan Beach Venture and in 2020 the two individual defendants 

in the case, as well as three other individuals involved, were arrested and criminally charged.

37

In another recent case, Student Debt Doctor,38 the FTC alleged the defendants falsely promised 

loan forgiveness to consumers and charged an illegal upfront fee. Using social media, e-mail, and 

 31 See Devesh Raval, Who is Victimized by Fraud? Evidence from Consumer Protection Cases, Journal of Consumer Policy

at 10-11, 19-20, 31-32, 36, 46 (June 2, 2020), available at https://deveshraval.github.io/victim.pdf. Other research has

demonstrated disparities related to student debt in communities of color. See Sarah Sattelmeyer & Jon Remedios, Race and 

Financial Security Play Central Roles in Student Loan Repayment, Pew (Dec. 15, 2020), available at 

https://www.pewtrusts.org/en/research-and-analysis/articles/2020/12/15/race-and-financial-security-play-central-roles-instudent-loan-repayment; Melanie Hanson, Student Loan Debt by Race, Educatordata.org (updated July 10, 2021), available 

at https://educationdata.org/student-loan-debt-by-race. 32 Raval, Who is Victimized by Fraud?, supra note 31 at 19-20. 33 FTC v. Strategic Student Solutions LLC, No. 9:17-cv-80619-WPD (S.D. Fla. filed May 15, 2017), available at

https://www.ftc.gov/enforcement/cases-proceedings/162-3239/strategic-student-solutions-llc. Dr. Raval analyzed this case in 

two different research papers.

34 FTC v. Manhattan Beach Venture LLC, No. 2:19-cv-7849 (C.D. Cal. filed Sept. 11, 2019), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3041/manhattan-beach-venture-llc-et-al. 35 FTC v. M&T Fin. Grp., No. 2:17-cv-06855-ODW(PLAx) (C.D. Cal. filed Sept. 18, 2017), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3065/mt-financial-group-student-debt-relief-group. 36 FTC v. Am. Student Loan Consols., LLC, No. 0:17-cv-61862-DPG (S.D. Fla. Sept. 25, 2017), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3076/american-student-loan-consolidators. 37 Press Release, California Department of Justice, Attorney General Becerra Announces Arrest, Charges Against Five 

Individuals for Student Loan Scam and Related Security and Computer Crimes, available at https://oag.ca.gov/news/pressreleases/attorney-general-becerra-announces-arrest-charges-against-five-individuals (Mar. 4, 2020.) 38 FTC v. Student Debt Doctor, No. 0:17-cv-61937 (S.D. Fla. filed Oct. 2, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3055/student-debt-doctor-llc.

Further analysis of the customer databases for 

four student loan debt relief cases . . . 

revealed that the people affected in the cases 

were over 196%, 170%, 130%, and 116% 

more likely to live in a Black majority zip code 

compared to the general population.
FEDERAL TRADE COMMIS SION FTC. GOV 12

telemarketing, the defendants promoted their services across the United States, including in Puerto Rico,

in English and Spanish. The settlement in this matter bans the defendants from the debt relief industry. It 

also includes a partially suspended $13 million judgment and requires the defendants to pay 

approximately $2.2 million.

D. Marketing Prepaid Cards

Prepaid cards are cards preloaded with funds that act as a debit or credit card but are not linked 

to any financial account. For households that do not have a traditional bank account, prepaid cards are 

an important tool for critical financial services such as transferring funds, making deposits, writing

checks, and making online or other purchases. In November 2016, the FTC sued NetSpend,

39 alleging 

that the company marketed reloadable prepaid payment cards to “unbanked” or “underbanked” 

consumers, and deceived consumers about access to funds they loaded onto the cards. The complaint 

alleged that NetSpend marketed specific products to groups such as “African Americans who are either 

unbanked or underbanked,” as well as Spanish-speaking consumers (through Spanish-language ads).

The complaint also noted that NetSpend’s customers included “low-income consumers” and those 

“facing financial uncertainty.” Many consumers allegedly found that, after loading substantial sums onto 

NetSpend’s prepaid cards, they were unable to activate the cards, and their balances were then depleted

by NetSpend-imposed “inactivity” fees. NetSpend agreed to settle the FTC’s charges by providing 

monetary relief, which was required to amount to no less than $53 million. Redress checks have been 

sent to nearly half a million consumers as a result of the settlement.40 

E. Government Impersonators

Government impersonator scams are some of the top frauds reported to the FTC, and 

communities of color can be specifically targeted. In American Immigration Center,

41 the FTC charged 

that the defendants operated a myriad of websites, deceptively designed to look like U.S. government 

websites ̶with URLs such as usimmigration.us, us-immigration.com, uscitizenship.info, and 

usimmigrationcitizenship.com – that offered immigration and naturalization form preparation services 

for a fee. The complaint alleged that consumers who searched online for terms such as “USCIS,” “INS,” 

or “US Immigration” and clicked on defendants’ search advertisements were then directed to these 

websites, which displayed government-related images, such as the American flag and the U.S. Capitol. 

The FTC alleged that thousands of consumers paid the defendants’ fees ranging from $120 to $300, 

believing that they were paying the applicable government agency filing fees for their applications – but 

in reality, the defendants kept the fees. The FTC’s complaint also noted that the forms consumers 

received were available for free on the USCIS website. The settlement order in the case bars the 

 39 FTC v. NetSpend Corp., No. 1:16-cv-04203 (N.D. Ga. filed Nov. 10, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/netspend-corporation. 40 See Press Release, FTC, FTC Returns more than $10 million to NetSpend Customers (Sept. 2018), available at 

https://www.ftc.gov/news-events/press-releases/2018/09/ftc-returns-more-10-million-netspend-customers. 41 FTC v. Forms Direct, Inc., No. 3:18-cv-06294 (N.D. Cal. filed Oct. 16, 2018), available at

https://www.ftc.gov/enforcement/cases-proceedings/152-3272/american-immigration-center.
FEDERAL TRADE COMMIS SION FTC. GOV 13

defendants from implying an affiliation with the government and requires them to clearly and 

conspicuously disclose the opposite – that they are not affiliated with the government – and that 

consumers must separately submit their completed immigration applications to the government and pay 

applicable government filing fees. The order also imposes a $2.2 million judgment, which the FTC used 

to redress consumers.

Portion of a website from American Immigration Center Complaint42

In 2017, the FTC alleged that the defendants in ABC Hispana Inc.43 operated a nationwide 

telemarketing scheme that targeted Spanish-speaking consumers with deceptive and abusive tactics to 

sell them products for learning English. Using telemarketers in Peru, the defendants allegedly made 

unsolicited calls to consumers, typically conducted in Spanish, and falsely represented that they were 

affiliated with the government or a centro de ayuda (“help center”), well-known companies such as 

Walmart, or a Spanish-language radio station. The FTC charged that the defendants falsely told people

they were specifically selected for a language course, would receive personal instruction for a highly 

discounted price, or that they had won a tablet and only needed to pay for shipping or taxes. If 

consumers declined the sales pitch or cancelled early, the telemarketers allegedly said they were lawyers 

or government officials and told consumers that they must immediately pay defendants or they could 

face lawsuits, arrest, incarceration, referral to law enforcement authorities, losing their home, damage to 

credit, and other serious consequences. The court issued a default judgment against the defendants that 

imposes a $6.3 million monetary judgment and bans the defendants from telemarketing and prohibits 

them from future misrepresentations. Through the FTC’s Criminal Liaison Unit,44 the FTC referred this 

case to the DOJ and in 2020, five Peruvian nationals connected to the operation were extradited to the 

 42 See id., FTC’s Complaint, Attachment A, available at

https://www.ftc.gov/system/files/documents/cases/152_3272_american_immigration_center_attachment_a_to_complaint.pdf. 43 FTC v. ABC Hispana, Inc., No. 5:17-cv-00252-JGB-DTB (C.D. Cal. filed Feb. 13, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3108/abc-hispana-inc-et-al. A legal services group in Washington, 

D.C., AYUDA, informed the FTC about the defendants’ illegal practices. 44 The FTC’s Criminal Liaison Unit helps prosecutors bring more criminal consumer fraud cases. See

https://www.ftc.gov/enforcement/criminal-liaison-unit. 
FEDERAL TRADE COMMIS SION FTC. GOV 14

United States and faced a 55-count indictment of conspiracy, mail fraud, wire fraud, and extortion.45

Two more were extradited in 2021, and five of the Peruvian defendants recently pleaded guilty and face 

maximum penalties of 20 years in prison.46

F. Marketing for Inmate Services

The FTC has filed two recent cases which are currently pending in federal court concerning 

deceptive marketing of products to incarcerated individuals and their families and friends. These are 

cases that disproportionately impact people of color. Data from the DOJ shows that while the 

imprisonment rate of Black Americans has decreased, there is still a significant difference in the 

proportion of people of color who are incarcerated as compared to those who are White.47

In Inmate Call,

48 the FTC alleges that the defendants used false advertisements to sell 

nonexistent inmate calling plans to friends and family members of incarcerated individuals. The FTC's 

complaint alleges that the defendants' advertisements falsely promised unlimited minutes and 

impersonated telecommunications companies contracted to provide calling services to jails and prisons.

In Inmate Magazine Service,

49 the FTC and the Florida Office of the Attorney General charged 

the defendants with deceptively selling magazine subscription services to inmates and the family 

members of inmates trying to send reading materials to loved ones serving time. The complaint alleges 

that the defendants collected full payment of fees for magazine subscriptions upfront, but then pocketed 

those payments and either never delivered, or delivered the products far later than promised, with no 

notification to consumers and no chance for them to cancel or get refunds as required by law. A

 45 Press Release, DOJ, Five Peruvians Extradited For Overseeing Call Centers That Threatened and Defrauded SpanishSpeaking U.S. Consumers (Oct. 27, 2020), available at https://www.justice.gov/opa/pr/five-peruvians-extradited-overseeingcall-centers-threatened-and-defrauded-spanish-speaking. 46 Press Release, DOJ, Three Peruvian Nationals Plead Guilty to Conspiring to Defraud Thousands of Spanish-Speaking U.S. 

Residents (May 14, 2021), available at https://www.justice.gov/opa/pr/three-peruvian-nationals-plead-guilty-conspiringdefraud-thousands-spanish-speaking-us; see also Press Release, DOJ, Peruvian National Sentenced to 90 Months in Prison 

for Conspiring to Defraud Thousands of Spanish-Speaking Immigrants (July 9, 2021), available at

https://www.justice.gov/opa/pr/peruvian-national-sentenced-90-months-prison-conspiring-defraud-thousands-spanishspeaking. 47 In 2018, the imprisonment rate of Black males was 5.8 times that of White males, while the imprisonment rate of Black 

females was 1.8 times the rate of White females. E. Ann Carson, Prisoners in 2018, U.S. Department of Justice, Office of 

Justice Programs, Bureau of Justice Statistics at 1 (Apr. 2020), available at https://www.bjs.gov/content/pub/pdf/p18.pdf. In 

2018, Black Americans represented 33% of the sentenced prison population, nearly triple their 12% share of the U.S. adult 

population. Whites accounted for 30% of prisoners, about half of their 63% share of the adult population. Latinos accounted 

for 23% of inmates, compared with 16% of the adult population. See John Gramlich, Black imprisonment rate in the U.S. has 

fallen by a third since 2006, Pew Research Center (May 6, 2020), available at https://www.pewresearch.org/facttank/2020/05/06/share-of-black-white-hispanic-americans-in-prison-2018-vs-2006/. 48 FTC v. Disruption Theory LLC, No. C20-6919VC (N.D. Cal. filed Oct. 5, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/192-3156/disruption-theory-llc-inmate-call. The FTC alleged, “[b]ecause 

a disproportionate number of incarcerated individuals are from communities of color or lower-income communities, many of 

the consumers harmed by [the d]efendants’ practices are likely from these communities.” See id., Complaint ¶ 15, available 

at https://www.ftc.gov/system/files/documents/cases/complaint_-_inmate_call.pdf. 49 FTC v. Inmate Magazine Serv., Inc., No. 3:21cv294-TKW-HTC (N.D. Fla. filed Feb. 16, 2021), available at

https://www.ftc.gov/enforcement/cases-proceedings/202-3089/inmate-magazine-service-inc.
FEDERAL TRADE COMMIS SION FTC. GOV 15

settlement in this matter with the owner and operator of Inmate Magazine Service bans him from selling 

or marketing magazine subscriptions. It also includes a partially suspended $2.2 million judgment and 

requires the defendant to turn over nine different bank accounts used for the scheme.

G. Deceptive and Unsubstantiated Advertising Claims

The FTC has identified cases where deceptive claims are made in Spanish, Vietnamese, and 

other languages. In Wellco, Inc.,

50 the FTC alleged that marketers of indoor TV antennas and signal 

amplifiers made deceptive performance claims on their websites in both English and Spanish. The 

defendants allegedly made deceptive claims that these products would let users cancel their cable service 

and still get all their favorite channels for free, using customer testimonials plagiarized from competitors

as part of their pitch. In settling this matter, the defendants agreed to an order that prohibits a variety of 

deceptive claims about their antennas and any other product they sell. The order also prohibits phony 

“news” stories and misrepresentations conveyed through endorsements, and imposes a judgment of 

$31.82 million, which was partially suspended after payment of $650,000.

In Global Concepts Limited,

51 the FTC alleged that the defendants failed to substantiate their 

claims that their electronic sound amplifier product allowed users to hear up to 30 times better and hear 

clearly in crowded places such as restaurants. The defendants advertised the amplifiers directly to 

consumers via TV ads, as well as company-owned websites, including a Spanish-language site. The 

defendants generated $47.2 million in sales. To settle the case, the defendants agreed to an order that, 

among other things, requires human clinical testing to support future representations similar to the 

claims challenged in the complaint and imposes a judgment of $47.2 million, which was partially 

suspended after payment of $500,000.

In QYK Brands LLC, the FTC alleged that online marketers failed to deliver on promises that 

they could quickly ship products such as face masks, sanitizers, and other personal protective equipment 

related to the coronavirus pandemic.52 The FTC also alleged that the defendants sold a deceptive 

COVID-19 preventative, marketed to Vietnamese-American communities in the United States using 

Vietnamese language videos and an “interview style” news broadcast on Saigon Entertainment 

Television (SET), a Vietnamese-American television station in Southern California. The FTC filed its 

complaint in federal district court in August 2020, and the case is currently pending.

 50 FTC v. Wellco, Inc., No. 1:21-cv-02081 (S.D.N.Y. filed Mar. 10, 2021), available at 

https://www.ftc.gov/enforcement/cases-proceedings/192-3004/wellco-inc-ftc-v. 51 FTC v. Global Concepts Ltd., Inc., No. 0:18-cv-60990 (S.D. Fla. filed May 2, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/162-3225/msa-30x-sound-amplifier. 52 FTC v. QYK Brands, LLC, No. 8:20-cv-01431-JLS-KES (C.D. Cal. filed Aug. 4, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/202-3147/qyk-brands-llc-dba-glowwy. 
FEDERAL TRADE COMMIS SION FTC. GOV 16

During the first year of the pandemic,

deceptive COVID-19 treatment and prevention 

claims proliferated in the marketplace.

53 To date, 

the FTC has issued hundreds of warning letters to 

marketers,54 including those targeting Latino and

Korean-American communities. For example, the 

FTC issued warning letters to two multi-level 

marketing companies55 and a joint warning letter with the U.S. Food and Drug Administration to 

marketers,

56 challenging claims made in Spanish about their products’ ability to treat or prevent 

COVID-19. The agency also issued two letters in Spanish to entities targeting Latino communities with 

deceptive advertisements and Facebook posts, which allegedly claimed in Spanish that their products 

could prevent or treat COVID-19.57 In addition, the FTC issued a warning letter to a social media 

marketer challenging COVID-19 treatment and prevention claims made in Korean about its products.

58

The FTC’s letters warned that the marketers’ false claims were unlawful and demanded that the 

entities immediately cease the conduct and report back to the FTC. Overwhelmingly, companies that 

received FTC warning letters quickly removed the false COVID-19 claims from their advertising.

H. Jobs and Money-Making Opportunities

As noted above, communities of color can be disproportionately affected by offers for economic 

and entrepreneurial opportunities. In June 2021, the FTC, along with the State of Arkansas, filed 

Blessings in No Time,

59 alleging that perpetrators of a “blessing loom” pyramid scheme falsely promised 

people, many of whom were suffering financial hardship as a result of the COVID-19 pandemic, that 

they would receive investment returns as high as 800%.

60 The FTC’s complaint states that the 

 53 See FTC COVID-19 Report, supra note 4 at 6-7. 54 A full list of all of the warning letters sent during the pandemic is available at 

https://www.ftc.gov/coronavirus/enforcement/warning-letters. 55 See Warning letters to Youngevity International, Inc. and Vivri USA, LLC (June 5, 2020), available at 

https://www.ftc.gov/news-events/press-releases/2020/06/second-round-warning-letters-to-mlms-regarding-coronavirus. 56 See Warning letter to OCLO LLC (May 27, 2021), available at https://www.ftc.gov/system/files/warning-letters/fda-covid19-letter-oclo.pdf. 57 See Warning letters in Spanish to Cebilon Y. Vivenso and Gotay’s Group Systems (Oct. 20, 2020), available at 

https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_cebilon_y_vivenso_spanish.pdf and 

https://www.ftc.gov/system/files/warning-letters/covid-19-letter_to_gotays_group_systems_spanish.pdf. 58 See Warning letter to UWell Life, Inc. (June 16, 2020), available at https://www.ftc.gov/system/files/warningletters/covid-19-letter_to_uwell_life_inc.pdf. 59 FTC v. BINT Operations LLC, No. 4:21-cv-00518-KGB (E.D. Ark. filed June 16, 2021), available at

https://www.ftc.gov/enforcement/cases-proceedings/2123043/blessings-no-time. 60 Blessing looms imitate an informal savings club. For additional background on blessing looms, see generally Karen Hobbs, 

A real or fake savings club?, FTC Consumer Information Blog (Aug. 10, 2020), available at

https://www.consumer.ftc.gov/blog/2020/08/real-or-fake-savings-club; Seena Gressin, This “game” is a chain letter scam, 

FTC Consumer Information Blog (May 21, 2020), available at

https://www.consumer.ftc.gov/blog/2020/05/game-chain-letter-scam. See also Emma Fletcher, Scams starting on social 

media proliferate in early 2020, FTC Data Spotlight (Oct. 21, 2020), available at https://www.ftc.gov/newsTo date, the FTC has issued hundreds of 

warning letters to marketers, including those 

targeting Latino and Korean-American 

communities.
FEDERAL TRADE COMMIS SION FTC. GOV 17

defendants primarily targeted Black communities, noting that the scheme’s membership bylaws have 

stated that all members “MUST BE OF AFRICAN-AMERICAN DESCENT. ABSOLUTELY NO 

EXCEPTIONS!” The FTC also alleged that the defendants specifically targeted financially distressed 

consumers, claiming that the scheme could help them pay for surgery or fulfill “a student’s dream of 

attending college,” and that it would provide an alternative “[w]hen funding from the government and 

nonprofits falls short[.]” Instead, the complaint states, most members did not earn returns but instead lost 

the money they paid to participate and, moreover, were prohibited from posting publicly on social media 

and the internet about the scheme. Litigation in this matter is ongoing.

In 2020, the FTC coordinated a joint enforcement effort, Operation Income Illusion, with 19 

federal, state, and local law enforcement partners that encompassed more than 50 actions against 

operators of work-from-home and employment scams, pyramid schemes, investment scams, bogus 

coaching courses, and other schemes.

61 Some of the schemes targeted in Operation Income Illusion had 

a noted impact on one or more specific groups, such as military families, people on a limited fixed 

income, immigrants, Black Americans, and Latinos.62

For example, in one of the cases, Moda Latina BZ Inc.,

63 the FTC alleged that the defendants 

targeted Latina consumers with Spanish-language ads on TV and telemarketing pitches offering workat-home business opportunities that would generate “large profits” selling luxury products – all of this in 

the midst of the COVID-19 health and economic crisis.

64 Instead of the promised profits, the FTC 

charged that consumers were left with hundreds of dollars in losses and unsellable products. The 

settlement order permanently bans the defendants from selling money-making opportunities and 

imposes a monetary judgment of $7 million, suspended upon payment of $20,000 by each individual 

defendant due to the defendants’ financial condition.

 

events/blogs/data-spotlight/2020/10/scams-starting-social-media-proliferate-early-2020 (“As people seek more ways to earn 

money, reports about multi-level marketing (MLM) companies and pyramid schemes – including blessing circles and other 

gifting schemes – on social media have increased. The numbers were up a staggering fivefold in the second quarter of 

2020.”).

61 See Press Release, FTC, As Scammers Leverage Pandemic Fears, FTC and Law Enforcement Partners Crack Down on 

Deceptive Income Schemes Nationwide (Dec. 14, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/12/scammers-leverage-pandemic-fears-ftc-law-enforcement-partners; Lesley Fair, Operation Income Illusion 

cracks down on illusory income claims, FTC Business Blog, (Dec. 14, 2020), available at https://www.ftc.gov/newsevents/blogs/business-blog/2020/12/operation-income-illusion-cracks-down-illusory-income-claims. 62 See List of Federal, State, and Local Actions (2020), available at https://www.ftc.gov/system/files/attachments/pressreleases/scammers-leverage-pandemic-fears-ftc-law-enforcement-partners-crack-down-deceptive-incomeschemes/operation_income_illusion_-_federal_state_and_local_actions_2020.pdf. 63 FTC v. Moda Latina BZ Inc., No. 2:20-cv-10832 FMO-SK (C.D. Cal. filed Nov. 30, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/2023068/moda-latina-bz-inc. 64 According to the complaint, the defendants also advertised work-at-home opportunities through social media. Id. The FTC 

has seen an increase in reports about scams that started on social media over the past few years. See Fletcher, Scams starting 

on social media proliferate in early 2020, supra note 60. In addition, analysis of consumer reporting data by Dr. Raval in 

which consumers specified how they were contacted demonstrated that people living in majority Black and Latino 

communities filed a higher share of reports about experiences in which they were contacted through social media than people 

living in majority White communities. For more on Dr. Raval’s methodology, see infra Section V. This trend raises concerns 

about how bad actors may use social media to target certain communities. 
FEDERAL TRADE COMMIS SION FTC. GOV 18

Screenshot of television advertisement from Moda Latina BZ Inc. Complaint65

In Herbalife,

66 the FTC alleged that the multilevel marketing company aggressively promoted its 

business opportunity through videos, live 

presentations, and print materials in Spanish and 

English, telling people they could quit their jobs, earn 

thousands of dollars a month, make a career-level 

income, or even get rich as Herbalife distributors. 

Herbalife’s “Presentation Book” and magazines, 

which were distributed in Spanish, contained 

numerous testimonials touting financial independence as an Herbalife distributor. In reality, the FTC 

charged, people made little or no money, and a substantial percentage lost money. Herbalife settled the 

FTC’s claims, agreeing to pay $200 million for consumer redress, fully restructure its U.S. business 

operations to comply with the law, and pay for an independent auditor. The order also prohibits 

Herbalife from misrepresenting potential or likely earnings. The FTC mailed redress checks to nearly 

350,000 Herbalife distributors who lost money. Dr. Raval analyzed the list of consumers used for 

redress in this case and determined that the people affected were more than 211% more likely to live in a 

Latino majority zip code compared to the general population.

 65 See id., Complaint ¶ 32, available at https://www.ftc.gov/system/files/documents/cases/001_complaint.pdf (translation: 

“You too will earn a lot of Money.”).

66 FTC v. Herbalife Int’l of America, Inc., No. 2:16-cv-05217 (C.D. Cal. filed July 15, 2016), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3037/herbalife-international-america-inc-et-al; see also Statement of 

the Federal Trade Commission, FTC v. Herbalife Int’l of America, Inc. (July 15, 2016), available at

https://www.ftc.gov/system/files/documents/public_statements/971213/160715herbalifestatement.pdf. 

Dr. Raval analyzed the list of consumers 

used for redress in this case and 

determined that the people affected were 

more than 211% more likely to live in a 

Latino majority zip code compared to the 

general population.
FEDERAL TRADE COMMIS SION FTC. GOV 19

In AWS, LLC,

67 the FTC alleged that the defendants, including FBA Stores, falsely claimed their 

“Amazing Wealth System” would let people create a profitable online business selling products on 

Amazon. Defendants had no affiliation with Amazon. Most consumers lost significant amounts of 

money and experienced problems with their Amazon stores, including losing their ability to sell. The 

defendants widely disseminated their advertising in multiple languages, including English and Spanish. 

The settlement orders ban the defendants from making false earnings claims, among other things. One 

order imposed a judgment of more than $63.5 million, which was partially suspended after payment of 

roughly $2.55 million in funds and assets. Another order imposed a judgment of more than $102 

million, which was partially suspended upon surrender of about $10.8 million. The FTC has returned

more than $9.1 million to people who lost money.

In addition, analysis of the customer databases of two prior FTC money-making scheme cases, 

Mobile Money Code and Digital Altitude,

68 showed a disproportionate impact on communities of color

for lower price products. Specifically, when people lost less than $500 (which was the case for all

consumers in Mobile Money Code and a portion of the consumers in Digital Altitude), Dr. Raval found 

that a higher number of those consumers lived in predominantly Black communities rather than 

predominantly White communities.

69

The FTC has also pursued cases against companies that allegedly deceived workers about 

potential earnings from delivery and ride-hailing services booked through online platforms. Research 

has shown that communities of color are disproportionately represented in the internet-enabled gig 

economy.70 In Amazon Flex,

71 the FTC alleged that the respondents deceptively advertised that delivery 

drivers who signed up for its Amazon Flex program would get 100% of tips received from customers 

who placed orders through services like Prime Now and AmazonFresh. According to the FTC, for a two

and a half year period, the respondents did not deliver $61.7 million of those tips to Amazon Flex 

drivers. Under a settlement, the respondents paid the total amount to return to affected drivers. 

 67 FTC v. AWS, LLC, No. 2:18-cv-00442-JCM-PAL (D. Nev. filed Mar. 12, 2018), available at 

https://www.ftc.gov/enforcement/cases-proceedings/172-3149/aws-llc-et-al-fba-stores. 68 FTC v. Montano (“Mobile Money Code”), No. 6:17-cv-2203-JA-KRS (M.D. Fla. filed Dec. 28, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/142-3170/ronnie-montano; FTC v. Digital Altitude LLC, No. 2:18-cv00729-JAK-MRW (C.D. Cal. filed Jan. 29, 2018), available at https://www.ftc.gov/enforcement/cases-proceedings/172-

3060/digital-altitude-llc. 69 See Raval, Who is Victimized by Fraud?, supra note 31 at 10, 12, 20, 28. Dr. Raval also found a disparity in another FTC 

case filed prior to 2016 involving a moneymaking scheme where the consumers lost less than $500, FTC v. Indep. Mktn. 

Exchange, Inc. (“IME”), No. 10:cv-00568-NHL-KMW (D.N.J. filed Feb. 2, 2010), available at

https://www.ftc.gov/enforcement/cases-proceedings/independent-marketing-exchange-inc. See id. at 10, 12. 70 See U.S. Bureau of Labor Statistics, Electronically mediated work: new questions in the Contingent Worker Supplement, 

U.S. Dep’t of Labor tbls. 3 & 4 (Sept. 2018), available at https://www.bls.gov/opub/mlr/2018/article/electronically-mediatedwork-new-questions-in-the-contingent-worker-supplement.htm; see also Chris Benner et al., On-Demand and on-the-edge: 

Ride-hailing and Delivery Workers in San Francisco (May 2020), available at https://transform.ucsc.edu/on-demand-and-onthe-edge/; Edison Research, The Gig Economy (Dec. 2018), available at http://www.edisonresearch.com/wpcontent/uploads/2019/01/Gig-Economy-2018-Marketplace-Edison-Research-Poll-FINAL.pdf. 71 In the Matter of Amazon.com, Inc., No. C4746 (FTC filed June 9, 2021), available at 

https://www.ftc.gov/enforcement/cases-proceedings/1923123/amazon-flex.
FEDERAL TRADE COMMIS SION FTC. GOV 20

In Uber Technologies,

72 the FTC alleged that the defendant exaggerated the yearly and hourly 

income drivers could make in certain cities, and misled prospective drivers about the terms of its vehicle 

financing options. The defendant agreed to pay $20 million in consumer redress to resolve the charges.

I. Credit, Background Checks, and Access to Housing

Issues related to credit and consumer reporting accuracy raise significant concerns, given the 

pivotal role they play in people getting employment, credit, and housing opportunities. According to 

recently released complaint data from the Consumer Financial Protection Bureau (“CFPB”), 

communities of color appear to face significantly more issues when it comes to credit and consumer 

reporting.73 The importance of accurate information in tenant screening reports74 is of particular 

concern, as the eviction crisis due to the pandemic is falling hardest on communities of color.75 The 

CFPB noted that a significant number of credit or consumer reporting complaints related to attempts to 

address identity-theft related issues, as well as concerns about the accuracy of information on a 

consumer’s report.76 The FTC has brought numerous actions under the Fair Credit Reporting Act 

(“FCRA”) against credit reporting agencies, users of consumer reports, and furnishers of information to 

credit reporting agencies.77 With the eviction crisis falling hardest on communities of color, and the 

need for these consumers to seek out new housing, the importance of accurate information in tenant 

screening reports is of particular concern. Recently, through a complaint filed by the DOJ on the FTC’s 

behalf in MyLife.com,

78 the FTC alleged that MyLife, which promoted the use of its reports in 

employment and tenant screenings, violated the FCRA by failing to maintain reasonable procedures to 

verify how its reports would be used, to ensure the information was accurate, and to make sure that the 

information it sold would be used only for legally permissible purposes. The reports, the FTC alleged, 

often misrepresented that searched-for individuals had criminal or sexual offender records. The litigation 

is ongoing. The FTC also has filed cases under the FCRA alleging companies that provide tenant 

screening reports have failed to maintain reasonable procedures to assure the maximum possible 

 72 FTC v. Uber Technologies, Inc., No. 3:17-cv-00261 (N.D. Cal. filed January 19, 2017), available at 

https://www.ftc.gov/enforcement/cases-proceedings/152-3082/uber-technologies-inc. 73 CFPB, Complaint Bulletin at 10 (Apr. 2021), available at https://files.consumerfinance.gov/f/documents/cfpb_complaintbulletin_county-level-demographic-overview-consumer-complaints_2021-04.pdf (“Credit or consumer reporting appears to 

cause significantly more issues for consumers in predominantly minority counties than in predominantly white, non-Hispanic 

counties”). 

74 Tenant screening reports result from tenant background checks, and can include a variety of information including rental 

and eviction history, credit, or criminal records. 

75 According to a recent CFPB report, nine percent of renters reported in December 2020 that it was likely they would be 

evicted in the next two months, with rates highest for Black and Latino renters. CFPB, Housing insecurity and the COVID-19 

pandemic at 15 (Mar. 2021), available at

https://files.consumerfinance.gov/f/documents/cfpb_Housing_insecurity_and_the_COVID-19_pandemic.pdf. 76 See infra note 147. 77 See FTC Report, Fair Credit Reporting Act, Efforts to Promote Consumer Report Accuracy and Disputes (2020), available 

at https://www.ftc.gov/system/files/documents/reports/fair-credit-reporting-act-efforts-promote-consumer-report-accuracydisputes-report-congress/ftc_disputes_and_accuracy_report_2020_corrected_version.pdf. 78 United States v. MyLife.com, Inc., No. 2:20-cv-06692 (C.D. Cal. filed July 27, 2020) (filed by the DOJ on behalf of the 

FTC), available at https://www.ftc.gov/enforcement/cases-proceedings/182-3022/mylifecom-inc.
FEDERAL TRADE COMMIS SION FTC. GOV 21

accuracy of consumer report information. These actions include settlements with tenant background 

report providers RealPage79 and Appfolio.

80 

The FTC also has served public housing recipients, who are disproportionately from Black 

communities. In 2016, out of 2.2 million low-income households that used Section 8 housing choice 

vouchers, 47% of the heads of households were Black and 17% were Latino.81 In Apartment Hunters, 

Inc.,

82 the FTC shut down an operation that it charged with making misrepresentations about the 

availability of Section 8 housing vouchers. The defendants operated rental listing websites, such as 

WeTakeSection8.com, on which they made false and unfounded claims of having accurate, up-to-date 

listings approved for Section 8 housing vouchers. In reality, after consumers paid to access the listings, 

they found that most of the listed properties were either unavailable or did not accept Section 8 housing 

vouchers. The court ordered the defendants to pay more than $6 million and permanently banned them 

from future marketing or sales of subscriptions for or access to rental listings.

J. Payday Loans and Debt Collection

The FTC has prioritized a number of other problematic practices that research and experience 

show disproportionately affect communities of color. For example, the payday loan industry has been 

criticized by consumer advocates for troubling practices that impact communities of color with low 

incomes.

83 Indeed, Dr. Raval’s analysis, published in 2020, of three FTC payday lending cases (filed 

prior to 2016) supported this notion. His review of the customer databases from these cases revealed a 

 79 FTC v. RealPage, No. 3:18-cv-02737-N (N.D. Tex. filed Oct. 16, 2018), available at

https://www.ftc.gov/enforcement/cases-proceedings/152-3059/realpage-inc. The FTC’s complaint alleged that the defendant 

failed to take reasonable steps to ensure the accuracy of tenant screening information that it provided to landlords and 

property managers in violation of the FCRA, a violation that caused some potential renters to be falsely associated with 

criminal records. In addition to injunctive relief, the settlement required RealPage to pay a $3 million civil penalty. 

80 United States v. Appfolio, Inc., No. 1:20-cv-03563 (D.D.C. filed Dec. 8, 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/1923016/appfolio-inc. The DOJ filed a complaint on behalf of the FTC, 

alleging that Appfolio violated the FCRA by failing to ensure that criminal and eviction records it received from a third-party 

vendor were accurate before including such information in its tenant screening reports. The FTC also alleged that AppFolio 

illegally included eviction or non-conviction criminal records more than seven years old in its reports. In addition to 

injunctive relief, the settlement required Appfolio to pay a $4.25 million civil penalty.

81 See National Housing Law Project, Section 8 Housing Choice Vouchers, Overview (Sept. 2016), available at 

https://www.nhlp.org/wp-content/uploads/2018/03/3-NHLP-Voucher-Outline.pdf; see also Housing Spotlight, National Low 

Income Housing Coalition, Who Lives in Federally Assisted Housing? at 3 (Nov. 2012), available at 

https://nlihc.org/sites/default/files/HousingSpotlight2-2.pdf (American Community survey indicates that while Black 

households compose 12% of all households and 19% of renters, they are overrepresented among Project-Based Section 8 

public housing units (33%)). 

82 FTC v. Apartment Hunters, Inc., No. 8:18-cv-01636 (C.D. Cal. filed Sept. 11, 2018), available at

https://www.ftc.gov/enforcement/cases-proceedings/172-3007/apartment-hunters-inc-et-al-wetakesection8com. 83 See Aracely Panameño & Keith Corbett, Wealth-Stripping Payday Loans Trouble Communities of Color, Center for 

Responsible Lending (Oct. 2, 2008), available at https://www.responsiblelending.org/payday-lending/research-analysis/azpayday-communities-of-color-10-2-final.pdf; Graciela Aponte-Diaz, State Research Shows That Payday Lending Stores Are 

Heavily Concentrated In African American and Latino Communities Across California, Center for Responsible Lending

(Dec. 9, 2016), available at https://www.responsiblelending.org/media/state-research-shows-payday-lending-stores-areheavily-concentrated-african-american-and.
FEDERAL TRADE COMMIS SION FTC. GOV 22

disproportionate impact on Black communities.84 This area remains a priority for the FTC. In 2020, the 

FTC sued a payday loan operation that it said was targeting cash-strapped consumers, promising shortterm loans that would be repaid through a fixed number of payments.85 In reality, people found that,

long after the promised number of payments had been made, the defendants had allegedly applied their 

funds to finance charges only and were continuing to make regular finance-charge-only withdrawals 

from their checking accounts. The defendants agreed to a final order banning them from lending 

activities in the future and imposing a $114 million judgment. 

Studies also have shown that a significantly higher percentage of communities of color have 

debts in collection86 and that debt collection contacts87 and lawsuits disproportionately affect Black 

Americans.88 The FTC has brought numerous law enforcement actions against debt collectors that 

engage in egregious violations of the law, including phantom debt collectors.89 In 2020 alone, the FTC 

filed or resolved seven debt collection cases against 39 defendants and obtained $26 million in 

judgments.90 The Commission also led Operation Corrupt Collector, a coast-to-coast debt collection 

crackdown by the FTC and several federal and state partners, that encompassed more than 50 actions 

challenging some of the worst-of-the-worst debt collection tactics.91

 84 He also found that residents in heavily Black zip codes were more likely to have been affected by the schemes. See FTC 

Report, Combating Fraud in African American & Latino Communities at 15 (June 15, 2016), available at 

https://www.ftc.gov/system/files/documents/reports/combating-fraud-african-american-latino-communities-ftcscomprehensive-strategic-plan-federal-trade/160615fraudreport.pdf (analysis of Ideal Financial data showed residents of 

heavily Black zip codes more than four times more likely to have been harmed in that case than people living in 

predominantly White or Latino zip codes); Raval, Who is Victimized by Fraud?, supra note 31 at 19 (analysis of Ideal 

Financial and Platinum Trust Card showed that communities with a 100% black population were affected at a 209% higher 

rate than 0% Black communities). In another case, CWB Services, Dr. Raval found that the people affected were over 167% 

more likely to live in a Black majority zip code compared to the general population. FTC v. CWB Servs., LLC, No. 4:14-cv00783-DW (W.D. Mo. filed Sept. 5, 2014), available at https://www.ftc.gov/enforcement/cases-proceedings/132-3184-

x140065/cwb-services-llc. 85 FTC v. Lead Express, Inc., No. 2:20-cv-00840-JAD-NJK (D. Nev. filed May 11, 2020), available at 

https://www.ftc.gov/enforcement/cases-proceedings/192-3208/lead-express-inc-harvest-moon-financial. 86 See Urban Institute, Debt in America: An Interactive Map (updated Mar. 31, 2021), available at 

https://apps.urban.org/features/debt-interactive-map/?type=overall&variable=pct_debt_collections (credit bureau data 

indicates that 39% of people in predominantly communities of color have a debt in collections, compared with only 24% of 

those in predominantly White communities). 87 See FINRA, Financial Capability in the United States 2016 at 27 (July 2016), available at https://gflec.org/wpcontent/uploads/2016/07/NFCS_2015_Report_Natl_Findings.pdf (31% of Black survey respondents reported having been 

contacted by a debt collector in the past year, compared with 18% of respondents overall).

88 See Paul Kiel & Annie Waldman, The Color of Debt: How Collection Suits Squeeze Black Neighborhoods, ProPublica, 

(Oct. 8, 2015), available at https://www.propublica.org/article/debt-collection-lawsuits-squeeze-black-neighborhoods. 89 “Phantom debt” is debt that does not exist or that consumers do not owe. 90 See FTC Staff Letter on Debt Collection Activities (Feb. 19, 2021), available at 

https://www.ftc.gov/system/files/documents/reports/federal-trade-commission-enforcement-fair-debt-collection-practices-actcalendar-year-2020-report/p064803_ftc_report_fdcpa_to_cfpb.pdf. 91 See Press Release, FTC, State, and Federal Law Enforcement Partners Announce Nationwide Crackdown on Phantom and 

Abusive Debt Collection (Sept. 29, 2020), available at https://www.ftc.gov/news-events/press-releases/2020/09/ftc-statefederal-law-enforcement-partners-announce-nationwide. 
FEDERAL TRADE COMMIS SION FTC. GOV 23

III. Outreach and Education Initiatives to Communities of Color

Since 2016, the FTC has continued to build and solidify its consumer outreach and education 

strategies to reach communities of color. While this work is led by BCP’s Division of Consumer and 

Business Education, the entire Bureau – including the regional offices – are actively engaged. The 

agency’s approach has been to: a) listen to communities; b) engage with ethnic and community media; 

c) work with trusted partners; d) use storytelling; and e) provide materials in-language. The agency has 

worked especially hard to respond to the COVID-19 pandemic, recognizing its impact on communities 

of color.

A. Listening to Communities

To deepen its connection with those 

who work every day with communities of 

color, the FTC, since 2016, has hosted nine 

Common Ground Conferences92 and three 

Latino Roundtables,93 both of which are events that brought together law enforcement, community 

stakeholders, and partners across the country. Most Common Ground Conferences have included panels 

on how fraud affects specific communities. For example, the Madison, Wisconsin Common Ground 

Conference kicked off with a panel on how law enforcement and education can address fraud in 

communities that are disproportionately targeted or impacted by fraud.94 And a Common Ground event 

in Birmingham, Alabama, jointly hosted with the Birmingham NAACP, offered training to the 

NAACP’s volunteer leadership on issues they had defined as important to their community, including 

impersonator and job scams, debt collection, and credit.95

While Common Ground Conferences seek information on the state of scams and bad business 

practices affecting every community, sometimes a deeper dive into a particular community is needed. 

Latino Roundtables in Chicago, Washington, D.C., and Los Angeles focused on discussing consumer 

issues and developing and deepening partnerships – both with the FTC and among the groups 

themselves. The Washington, D.C. Roundtable led to regular quarterly calls and the opportunity to 

further develop partnerships. For example, at the FTC’s April 2021 quarterly call with D.C. area Latino 

leaders, FTC staff established a new working relationship with Supporting and Mentoring Youth 

Advocates (“SMYAL”), an organization that works with LGBTQ+ youth in the D.C. area. This new 

collaboration helps amplify the FTC’s consumer protection messages to Latino LGBTQ+ youth in the

 92 A list of Common Ground Conferences can be found at https://www.consumer.gov/content/common-ground-conferencesand-roundtables-calendar. 93 See, e.g., Illinois Latino Roundtable: https://www.ftc.gov/news-events/events-calendar/2016/12/combating-fraud-latinocommunities; Washington, D.C. Latino Roundtable: https://www.ftc.gov/news-events/events-calendar/hablemos-lets-talk-ftclatino-roundtable. 94 See Agenda, Working Together to Protect Midwest Consumers, available at https://www.ftc.gov/news-events/eventscalendar/2016/10/working-together-protect-midwest-consumers-common-ground. 95 See Agenda, Protecting Alabama Against Fraud, available at

https://www.consumer.gov/sites/www.consumer.gov/files/alnaacpevent.93016.pdf.
FEDERAL TRADE COMMIS SION FTC. GOV 24

city, facilitates creation of networks between that organization and Latino leaders in the city, and helps

the FTC learn how to adapt its messages for the broader LGBTQ+ community. 

Small businesses are integral to every community across the country, and many of them are

owned by people of color.96 Starting in 2017, the FTC prioritized outreach and education for small 

businesses, with a focus on common scams97 and data security issues.98 In a series of FTC-led listening 

sessions, business owners across the country shared their interest in getting support for training their 

employees about basic online safety and cybersecurity, and to have the materials available in Spanish.

Based on this feedback, the agency launched a Cybersecurity for Small Business campaign and its 

Spanish counterpart, Ciberseguridad para Pequenos Negocios,

99 standing on the shoulders of the 

popular Start With Security publication.100 To promote the business education campaign, the FTC has 

worked closely with the Small Business Administration’s Small Business Development Centers 

(“SBDCs”) and District Offices across the country in addition to other state and local partners. For 

example, FTC staff has presented at webinars hosted by SBDCs in English and Spanish, which then lead 

to invitations to do further presentations. 

In 2019, the FTC refreshed and relaunched its successful Green Lights & Red Flags: FTC Rules 

of the Road for Business workshop (“GLRF”),101 specifically marketing the event to groups such as the 

Austin Asian American Bar Association, the Harris County Black Lawyers Association, the Hispanic 

Bar Association of Houston, and the Mexican American Bar Association of San Antonio. One of the 

most recent GLRF events was hosted by Thurgood Marshall School of Law, which is part of Texas 

Southern University, a Historically Black College and University (“HBCU”). The FTC will continue to 

actively reach out to bar associations and business groups in communities of color and bring GLRF 

events to law and business schools in HBCUs and Hispanic-Serving Institutions (“HSI”).

102

This past year, the FTC has also met with numerous groups working to combat surveillance

practices that harm communities of color, including algorithmic discrimination and disparate impacts 

 96 See Brian Headd, Small Business Facts, Business Ownership Demographics, U.S. Small Business Administration Office of 

Advocacy (Mar. 2021), available at https://cdn.advocacy.sba.gov/wp-content/uploads/2021/03/16095912/BusinessOwnership-Demographics-Fact-Sheet.pdf. 97 See FTC Business Center, Scams and Your Small Business: A Guide for Business (May 2018), available in English at 

https://www.ftc.gov/tips-advice/business-center/guidance/scams-your-small-business-guide-business and in Spanish at

https://www.ftc.gov/es/consejos/para-empresarios/las-estafas-y-su-pequeno-negocio-una-guia-para-los-negocios. 98 See FTC Business Center, Cybersecurity for Small Business, available at https://www.ftc.gov/tips-advice/businesscenter/small-businesses/cybersecurity. 99 See id. in Spanish at https://www.ftc.gov/es/tips-advice/business-center/small-businesses/cybersecurity/espanol. 100 See FTC Business Center, Start with Security: A Guide for Business (June 2015), available in English at 

https://www.ftc.gov/tips-advice/business-center/guidance/start-security-guide-business and in Spanish at 

https://www.bulkorder.ftc.gov/es/system/files/publications/spdf0205-startwithsecurity.pdf. 101 See events in Atlanta: https://www.ftc.gov/news-events/events-calendar/green-lights-red-flags-ftc-rules-road-business, 

Cleveland: https://www.ftc.gov/news-events/events-calendar/green-lights-red-flags-2020-workshop, and Dallas: 

https://www.ftc.gov/news-events/events-calendar/green-lights-red-flags-2021-ftc-rules-road-business. 102 An HSI is an institution of higher education that has an enrollment of undergraduate full-time equivalent students that is at 

least 25% Hispanic students. To become an HSI, an institution has to apply for designation via the U.S. Department of 

Education. See https://sites.ed.gov/hispanic-initiative/hispanic-serving-institutions-hsis/. 
FEDERAL TRADE COMMIS SION FTC. GOV 25

resulting from the use of facial recognition technology,103 to learn more about the effects of these 

technologies on communities of color. These meetings have included representatives from several civil 

rights groups including, among others, Color of Change and the Lawyers’ Committee for Civil Rights. 

As noted above, the COVID-19 pandemic has had, 

and will continue to have, a disproportionate impact on 

low-income communities and communities of color. 104

Millions of people have lost jobs, businesses, income, 

housing, and savings due to the financial impact of the 

pandemic. To better deliver needed resources to people in 

financial distress, the FTC convened listening sessions 

with community advocates.105 The goal was to better 

understand and respond to the challenges facing people in 

their communities. To date, the agency has hosted 15 virtual Financial Impact Listening Sessions with 

advocates, leaders, and organizations that work with diverse communities in 26 states and the District of 

Columbia. The FTC is using these insights to create and deploy a comprehensive outreach effort 

responsive to these concerns and accessible to every community. The agency has held, for example, 

nationwide radio tours – some jointly with the National Association of Attorney General (“NAAG”) –

that specifically targeted communities of color with information on pandemic-related scams, and 

reaching an estimated audience of nearly 11 million listeners.

B. Engaging Ethnic and Community Media

Ethnic and community media are among the most trusted sources of information in many 

communities of color. Since the 2016 Report, FTC staff has conducted 17 Ethnic and Community Media 

Briefings, bringing the total to 30 since the program’s inception in 2015.106 During these events, 

journalists have the opportunity to hear from state and local law enforcement, legal services, and 

community advocates. Together, they discuss the scams and practices affecting the communities in that 

locality, and how these groups can better work together to address the issues. These events have built 

local and state partnerships, connected groups that had never before collaborated, and resulted in 

hundreds of articles in multiple languages about consumer protection issues, FTC cases, and the 

 103 See Rebecca Kelly Slaughter, Algorithms and Economic Justice, Yale Journal of Law and Technology (August 2021), 

available at 

https://law.yale.edu/sites/default/files/area/center/isp/documents/algorithms_and_economic_justice_master_final.pdf; Joy 

Buolamwini and Timnit Gebru, Gender Shades: Intersectional Accuracy Disparities in Commercial Gender Classification, 

available at buolamwini18a.pdf (mlr.press); National Institute of Standards and Technology (NIST), Face Recognition 

Vendor Test (FRVT) Part:3 Demographic Effect, NISTIR 8280 (December 2019), available at 

https://nvlpubs.nist.gov/nistpubs/ir/2019/NIST.IR.8280.pdf. 104 See Whitney Airgood-Obrycki & Alexander Hermann, Interactive Tool Illustrates The Disparate Economic Impacts of 

The Pandemic, Joint Center for Housing Studies of Harvard University (Feb. 8, 2021), available at 

https://www.jchs.harvard.edu/blog/interactive-tool-illustrates-disparate-economic-impacts-pandemic. 105 See, e.g., Midwest Regional Office – Consumer Protection and Financial Impact Listening Session, available at

https://www.ftc.gov/news-events/events-calendar/midwest-regional-office-consumer-protection-financial-impact-listening. 106 A list of Ethnic and Community Media Briefings can be found at www.consumer.gov/commonground. 

To date, the agency has hosted 15 

virtual Financial Impact Listening 

Sessions with advocates, leaders, 

and organizations that work with 

diverse communities in 26 states and 

the District of Columbia.
FEDERAL TRADE COMMIS SION FTC. GOV 26

importance to the community of reporting fraud and bad business practices.

107 During the pandemic, 

these briefings have been virtual, but they continue to be a successful way to connect with a range of 

communities in a locality, hear their experiences and needs, give other agencies a platform, and share 

FTC resources. Briefings in large cities like New York, Chicago, Los Angeles, and San Francisco, have 

resulted in more than 30 media stories each in English and in other languages.108 In smaller venues, with 

smaller media markets, these briefing have generated 12-15 stories each on average, as well as 

developing relationships with ethnic media journalists in both large and small markets. 

Screen shots of news coverage resulting from Ethnic and Community Media Briefings

In addition to the ethnic and community media briefings, FTC staff has regularly hosted Ethnic 

Media Tele-briefings on topics important to the Commission and ethnic media audiences. These

briefings serve as a way to give ethnic media ready access to FTC experts, while also providing 

journalists an opportunity to share related experiences from their community. Topics covered have 

included cases, such as Herbalife;

109 refunds to consumers resulting from FTC action like Western 

Union;

110 and the annual release of the FTC’s Data Book.111 And, as a matter of course, Spanishlanguage media outlets often seek out interviews with bilingual FTC subject matter experts on consumer 

 107 See, e.g., Reporte Hispano (July 16, 2020), available at https://reportehispano.com/en/2020/07/el-coronavirus-ha-creadouna-lluvia-de-estafas/; Nepal24Hours (July 14, 2020), available at https://www.nepal24hours.com/coronavirus-opens-apandoras-box-of-scams/; Hola America News (July 14, 2020), available at https://holaamericanews.com/es/corona-virusopens-a-pandoras-box-of-scams/; Hispanic LA (July 14, 2020), available at https://hispanicla.com/el-coronavirus-ha-creadouna-lluvia-de-estafas-48095; India Post (July 3, 2020), available at

https://drive.google.com/file/d/1suRmbQlBg5t8ugiNRRJgTLMK_hP4lzcN/view; Kyocharo America (Korean) (July 14, 

2020), available at http://sem.kyocharoamerica.com/board/contentsView.php?idx=1476335; Kyosko Magazine (July 14, 

2020), available at https://kioskonews.com/2020/07/14/el-coronavirus-ha-creado-una-lluvia-de-estafas/; Blackfacts (July 15, 

2020), available at https://www.blackfacts.com/fact/coronavirus-opens-a-pandora-s-box-of-scams. 108 News outlets in a variety of media, including television, radio, online, and in print have served Black, Latino, South Asian, 

Southeast Asian, Korean, Chinese, Filipino, Bangladeshi, Turkish, Pakistani, Haitian, Somali, Ethiopian, Eritrean, Bosnian, 

Polish, and Hungarian communities, among many others. 109 See Press Release, FTC, Herbalife Will Restructure Its Multi-level Marketing Operations and Pay $200 Million For 

Consumer Redress to Settle FTC Charges (July 15, 2016), available at https://www.ftc.gov/news-events/pressreleases/2016/07/herbalife-will-restructure-its-multi-level-marketing-operations. 110 See FTC FAQs regarding FTC and Department of Justice’s settlement with Western Union (Sept. 2020), available at

https://www.ftc.gov/enforcement/cases-proceedings/refunds/western-union-settlement-faqs. 111 See FTC, Consumer Sentinel Network Data Book 2020 (Feb. 2021), available at https://www.ftc.gov/reports/consumersentinel-network-data-book-2020.
FEDERAL TRADE COMMIS SION FTC. GOV 27

protection issues. This media coverage helps disseminate current and relevant alerts to the Latino 

community on a regular basis. 

C. Connecting with Trusted Partners

Building upon more than 15 years of concentrated outreach to communities of color, the FTC 

continues to apply those lessons to expand its reach to these communities and audiences. By following 

its trusted sources approach, the FTC works to build relationships with key players in communities of 

color, while developing the kinds of resources they recommend. 

Well-known, national organizations like the NAACP and the Urban League are key partners 

when it comes to reaching Black communities across the nation. The FTC has, for example, offered 

train-the-trainer sessions to NAACP State Economic Chairs and to their State Conference Leaders to 

help them to alert their local chapter members about job scams, fake business opportunities, problems 

with background checks, tax identity theft, and other barriers to economic opportunity. 

The agency is also taking a local approach to reaching Black communities by working with 

groups like churches, libraries, and community colleges and universities. For example, FTC staff has 

regularly attended events with Black churches on the South Side of Chicago and faith-based groups in 

New York, where they gave presentations on top frauds and financial literacy, and distributed print 

materials. FTC staff has also spoken at events presented by the Delta Sigma Theta Sorority, a sisterhood 

of predominantly Black, college-educated women. FTC staff has spoken at in-person and virtual town 

halls held by members of Congress, which reach a diverse range of constituents. These partnerships are 

important because these institutions have a unique and powerful historic role in providing the Black 

community with social services, education, and outreach. 

The FTC also has spent years building trusted partnerships within Native American 

communities. Following the FTC’s 2014 Native American Common Ground Conference,

112 the 

Oklahoma Native Assets Coalition, Inc. invited staff from the FTC’s Southwest Regional Office to 

present a seminar about avoiding consumer fraud such as government impersonators, tech support 

scams, debt collection and debt relief scams, opportunity scams, automobile dealerships, funeral 

services, and identity theft to Native American tribes throughout Oklahoma. In addition, staff from the 

FTC’s Northwest Regional Office, which regularly engages with Tribal communities, participated in the 

annual Alaska Federation of Natives Annual Convention, which draws approximately 6,000 attendees 

each year and is the largest representative annual gathering of Native peoples in the United States.113

Staff has also presented on consumer issues on the Blackfeet Reservation, and held an open dialog with 

the Tribal community during the 2021 Montana Ethnic Media Roundtable.114

 112 See Agenda, Native American Common Ground Conference, available at https://www.ftc.gov/news-events/eventscalendar/2014/05/native-american-common-ground. 113 Statement from the organization’s website, available at https://www.nativefederation.org/. 114 See Spotting and Preventing Pandemic Related Scams and Other Fraud in Montana/The Mountain West, available at

https://www.consumer.gov/sites/www.consumer.gov/files/ftc_invite_montana.pdf.
FEDERAL TRADE COMMIS SION FTC. GOV 28

Over the past several years, the FTC has built relationships with housing agencies nationwide to 

help protect low-income communities from scams and bad business practices. One example is the FTC’s 

partnership with the Washington, D.C. Housing Authority) to educate tenants about how to spot and 

avoid scams, including credit repair, identity theft, and government impersonators. A national example 

is the FTC’s partnership with the U.S. Department of Housing and Urban Development’s (“HUD”) 

EnVision Centers across the country. These centers support people in and around public housing, as well 

as Section 8 residents,115 with programs on financial empowerment, job training, high school 

equivalency testing, and other education-centered programs. In a separate program, FTC staff is 

presently collaborating with HUD’s Housing Counseling Office to develop trainings for HUD housing 

counselors in response to COVID-related rental, housing, and eviction scams. 

Over the past five years, the FTC has continued to expand its work with legal service providers 

who work with low income consumers in underserved communities.116 National organizations like the 

Legal Services Corporation and the National Association of Consumer Advocates are frequent

participants in FTC outreach campaigns and regularly invite FTC staff to present on their webinars. 

Recent webinars have covered topics including deceptive debt collection practices, helping Latino 

consumers spot and avoid scams, and counseling identity theft victims. 

At the local, state, and regional level, FTC staff regularly participate in calls with legal services 

providers to learn about the consumer protection issues their clients are facing and to offer the FTC’s 

free educational resources and expertise. In fact, this exchange of ideas is longstanding and constructive, 

as feedback from legal services providers inspired the FTC’s creation of its website, consumer.gov 

(consumidor.gov in Spanish). These sites give people consumer protection basics in a straightforward, 

easily-navigated design, with increased accessibility through an audio read-along of the content, video 

explanation of key issues, and easy conversion to larger font. The FTC continues to expand the 

websites’ accessibility and relevance by adding mobile responsiveness to make the websites easily 

viewed on smart phones, and by adding new topics and resources. These include an article on higher 

education117 new videos,118 and updates on impersonator scams119 and identity theft sections.

120

The agency’s work with libraries continues. Librarians are a trusted source of information in the 

communities they serve. Staff attends the national conference for either the American Library 

 115 See supra note 81 (data regarding demographics of users of Section 8 vouchers). 116 The FTC also participates on the federal Legal Aid Interagency Roundtable (LAIR), a partnership created to raise federal 

agencies’ awareness of how civil legal aid can help advance federal objectives. The DOJ and the White House Domestic 

Policy Council launched the LAIR in 2012 to work with legal aid partners to advance government programs; create and 

disseminate tools to provide information about civil legal aid and federal funding opportunities; and generate research to 

inform policy that improves access to justice.

117 See Your Education After High School, available at https://www.consumer.gov/articles/0042-your-education-after-highschool. 118 See FTC Videos, Avoiding Student Loan Debt Relief Scams, available at https://youtu.be/--Ky877xcD8 and Cashing a 

Paycheck - Personal Finance Tips, available at https://youtu.be/PHwUyw7x8EA. 119 See Impersonator Scams, available at https://www.consumer.gov/articles/imposter-scams. 120 See Avoiding Identity Theft, available at https://www.consumer.gov/articles/1015-avoiding-identity-theft; see also

Recovering from Identity Theft, available at https://www.consumer.gov/articles/1016-recovering-identity-theft.
FEDERAL TRADE COMMIS SION FTC. GOV 29

Association (“ALA”) or the Public Library Association every year. In 2018 the FTC attended the Joint 

Conference of Librarians of Color in Albuquerque, New Mexico, which is hosted by the ALA’s ethnic 

affiliates – American Indian Library Association, the Asian/Pacific American Librarians Association, 

the Black Caucus of the American Library Association, the Chinese American Librarians Association, 

and REFORMA: The National Association to Promote Library & Information Services to Latinos and 

the Spanish Speaking. The FTC has established strong partnerships with individual library systems that 

display FTC print publications in their locations and make these free materials available for their 

patrons.

D. Educating Through Storytelling

As the agency continues to work to reach broader audiences in more 

effective ways, FTC staff experience, communication experts, ethnic media, and 

partners in the Latino community and other communities of color all point to the 

power of storytelling to convey important messages. The FTC continues to print 

its popular fotonovelas series – graphic novels with stories based on Spanish 

speakers’ reports to the FTC.121 The storytelling strategy is similarly used in the 

Fraud Affects Every Community Video Series.

122 These first-person stories of 

fraud – and advice from the FTC and legal services on avoiding it – help a wider 

range of people identify with the person’s experience. Both the videos and 

fotonovelas tell stories in a way to encourage those who engage with them, 

encouraging people to talk about scams and report them to the FTC as a way to 

help fight fraud in their community. They form part of the FTC’s high-quality consumer education 

materials that are widely available in multiple formats: websites, blogs, videos, audio, and print.123 The 

agency offers these for other groups to use, share, and even co-brand, with or without attribution. The 

goal is always to get practical and actionable information into the hands of people who need it, at the 

moment they need it, delivered by someone they trust.

 121 The full series is available at ftc.gov/fotonovelas and in English at https://www.consumer.ftc.gov/features/feature-0031-

fotonovelas, with topics including government impersonators, immigration scams, debt collection, telemarketing fraud, and 

the importance of reporting scams.

122 Examples can be found at www.ftc.gov/everycommunity. 123 See consumer websites at https://www.consumer.ftc.gov/and https://www.consumer.gov/, and in Spanish 

https://www.consumidor.ftc.gov/ and https://www.consumidor.gov/, and for military at https://www.militaryconsumer.gov/;

see consumer blogs in English at https://www.consumer.ftc.gov/blog and in Spanish at https://www.consumidor.ftc.gov/blog;

see business blogs at https://www.ftc.gov/news-events/blogs/business-blog; see videos at 

https://www.youtube.com/user/FTCvideos. For an example of a read-along page, see

https://www.consumer.gov/articles/1002-making-budget.
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Examples of Fraud Affects Every Community videos

E. Serving Communities in Various Languages

One question that frequently comes up in outreach to communities of color is how to provide 

resources in appropriate languages. While all FTC consumer and small business education is available in 

both English and Spanish,124 the agency worked strategically to provide information in additional 

languages when there is both interest in and demand for those resources. The FTC has made significant 

investments in providing immigration resources in a range of languages,125 as well as some scamspotting basics for refugee case workers.126 More recently, the agency has sought to gather in one place 

useful information in some of the most widely-spoken languages.127 Each of these efforts has been 

accompanied by a communications campaign, so that organizations in each of those linguistic 

communities know how to find and use those resources. 

 124 See resources in English for consumers: https://www.consumer.ftc.gov/ and small business: https://www.ftc.gov/tipsadvice/business-center/small-businesses, and in Spanish for consumers: https://www.consumidor.ftc.gov/ and small business: 

https://www.ftc.gov/es/tips-advice/business-center/small-businesses/espanol. 125 Immigration resources are available in Arabic, traditional Chinese, Creole, English, Korean, Russian, Spanish, and 

Vietnamese at https://www.consumer.ftc.gov/features/feature-0012-scams-against-immigrants. 126 Information for recent immigrants and refugees is presented in Amharic, Arabic, Dari, English, French, Somali, and 

Spanish at https://www.consumer.ftc.gov/features/feature-0033-avoiding-scams-information-recent-refugees-andimmigrants. 127 Resources are available in simplified Chinese, Korean, Spanish, Tagalog, and Vietnamese at 

https://www.consumer.ftc.gov/consumer-resources-other-languages.
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FTC staff also has conducted sustained and onthe-ground outreach in Spanish, when needed. The 

devastation that followed 2017 Hurricane Maria led to 

increased engagement and partnership-building with 

many groups throughout Puerto Rico. The resulting 

relationships have led to numerous opportunities for 

outreach and collaboration, including delivering a 

continuing legal education program with the Puerto 

Rico Bar Association and training to legal services 

providers. This has been true not only in the wake of 

the hurricane, but during the COVID-19 pandemic. For 

example, FTC staff has collaborated with government 

agencies from Puerto Rico, the AARP office in Puerto Rico, and the Elder Justice program in the U.S.

Attorney’s office in Puerto Rico on a COVID-19 scam awareness campaign. These and other 

organizations are now working with the FTC throughout Puerto Rico to help people spot and avoid 

scams, and to encourage them to report fraud to the FTC.128

Co-branded infographics that are part of the

COVID-19 scam awareness campaign in Puerto Rico

F. Responding to the COVID-19 Pandemic 

The FTC’s quick and comprehensive response to the COVID-19 pandemic continues. The FTC 

has worked aggressively to educate consumers of all communities and backgrounds about coronavirusrelated scams. The agency created a page for consumers129 within ftc.gov/coronavirus, with resources in 

 128 Organizations include the Puerto Rico Department of Consumer Affairs, Legal Services of Puerto Rico, One Stop Career 

Center, the Puerto Rico Bar Association, and local universities. 129 See Coronavirus Advice for Consumers, available at https://www.ftc.gov/coronavirus/scams-consumer-advice and in 

Spanish, Las estafas relacionadas con el coronavirus, available at https://www.ftc.gov/es/coronavirus/las-estafasrelacionadas-con-el-coronavirus.
FEDERAL TRADE COMMIS SION FTC. GOV 32

numerous languages to help people spot and avoid coronavirus scams – along with a page for 

businesses.130 These sites are intended to give the audience a one-stop shop for materials to help spot, 

avoid, and report scams related to COVID-19 and the financial challenges that have resulted from the 

pandemic. Resources on the FTC’s coronavirus site include blog posts, videos, social media graphics, 

comprehensive infographics, and audio tips.

131 Through regular outreach with a range of organizations, 

FTC staff encouraged the broader use of these materials. For example, a large chain of Asian 

supermarkets in California included the infographic, below, in their electronic newsletter, which it 

delivered to 30,000 subscribers. In addition, the FTC has partnered with both the Better Business Bureau 

and the NAAG to create and promote, respectively, videos and graphics to a broader audience.

Infographics in various languages with advice on how to avoid COVID-19 related scams

Since the beginning of the pandemic – in fact, starting in February 2020132 – the FTC has issued more 

than 120 Consumer Alerts on COVID-related topics, including Economic Impact Payments, false health 

and treatment claims, charity fraud, government impersonator scams, contact tracing, privacy issues, 

income scams, and scams targeting small business. These alerts, which were also available in Spanish –

and many in other langauges, too – served as the basis for ongoing conversations among the FTC, 

partner organizations serving communities of color, and ethnic media. They also drew significant public 

attention to the financial impact of the pandemic. For example, a single Consumer Alert about potential 

scams related to the Economic Impact Payments received more than 1.6 million views.133 The agency 

also put out more than 45 Business Alerts covering topics including scams targeting small business, 

health and earnings claims, scams related to loans issued by the U.S. Small Business Administration

(“SBA”), unemployment benefits fraud, privacy considerations for videoconferencing and at-home 

 130 See Business Guidance During Coronavirus, available at https://www.ftc.gov/coronavirus/business-guidance. 131 Find resources in multiple languages at https://www.ftc.gov/coronavirus/resources and in Spanish at 

https://www.ftc.gov/es/coronavirus/recursos. 132 See FTC Consumer Alert, Coronavirus: Scammers follow the headlines (Feb. 10, 2020), available at 

https://www.consumer.ftc.gov/blog/2020/02/coronavirus-scammers-follow-headlines. 133 See FTC Consumer Alert, Checks from the government (Mar. 18, 2020), available at

https://www.consumer.ftc.gov/blog/2020/03/checks-government.
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school, and a warning to nursing homes that stimulus payments were for their residents, not for them.134

The FTC also ran a multi-part “Back to Business” blog series for companies returning to the in-person 

workplace, addressing data security issues and the latest COVID-related scams targeting small 

business.135 Local media and community partners, including libraries, banks, and local law enforcement, 

subscribe to both Business and Consumer Alerts, and are a force-multiplier. They frequently share and 

forward the information to their members, expanding the FTC’s audience exponentially, and calling on 

FTC staff to share their expertise in media interviews. 

As the pandemic deepened, the FTC quickly adapted its messaging and its outreach methods, 

presenting in English and Spanish at scores of webinars, Facebook live events, virtual conferences and 

other virtual events on pandemic-related scams affecting both consumers and small businesses. For 

example, FTC staff spoke at the FDIC’s Alliance for Economic Inclusion events in Texas, Louisiana, 

and Mississippi about COVID-19 scams targeting small business;136 SBA events on the same topic; 

AARP webinars and tele-town halls on COVID-related scams, as well as those related to the pandemic’s 

financial impact; various webinars sponsored by the Puerto Rico Bar Association on scams and the 

financial impact of the pandemic; and events with federal partners like the USPIS and FEMA conducted 

entirely in Spanish to help consumers and business owners spot and avoid COVID-related scams and 

learn basic online safety and cybersecurity information. 

To ensure that important messages about pandemic-related scams reach people and communities 

with limited or no access to broadband internet, the FTC used USPS’s Every Door Direct Mailer service 

to deliver postcards with tips on spotting, avoiding, and reporting COVID-related scams. The mailer 

went to more than 237,000 households in late 2020. To further amplify its outreach, the FTC also mailed 

letters to more than 5,000 community health clinics – including 2,332 rural clinics — to encourage 

healthcare professionals to share the FTC’s COVID-related materials and consumer protection tips with 

patients and older adults.

FTC Mailer sent to 237,000 households

 134 See FTC Business Blog, available at https://www.ftc.gov/news-events/blogs/business-blog. 135 See FTC Back to Business Blog series, available at https://www.ftc.gov/consumer-protection/small-business. 136 See events in Texas, https://www.fdic.gov/consumers/community/events/2020-07-16-small-bussiness-resourcestexas.html; Mississippi, https://www.fdic.gov/consumers/community/events/2020-08-19-fdic-alliance-for-economicinclusion-mississippi.html; and Louisiana, https://www.fdic.gov/consumers/community/events/2020-11-19-louisiana-smallbusiness.html.
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As the pandemic shifted, and responses to it changed, the scams also changed. To serve both 

communities of color and its broader audience, the FTC worked to get messages to the public ahead of 

scammers, including before and during the vaccine rollout. Numerous Consumer Alerts and graphics, 

created and promoted in partnership with NAAG, sought to combat vaccine-related scams that exploited 

confusion about when, how, and where to sign up and get vaccinated. The agency recently released joint 

guidance on vaccine certifications and passports,137 and stands ready to address the next phase of the 

pandemic, as well as ensure that it gets the word out to every community.

G. Making Reporting Channels More Accessible

A key tool that the FTC has to hear directly from consumers is its Consumer Sentinel 

(“Sentinel”) reporting system, which is an online database where reports from consumers about fraud 

and other consumer problems are collected. The agency has taken significant steps to increase reports in 

Sentinel from all communities. In October 2020, the FTC launched ReportFraud.ftc.gov, a new site 

designed to make it easier for people to report fraud and other illegal business practices online. The 

process is now simpler and more user-friendly and, once a report is submitted, the user now gets 

concrete next steps to attempt to get their money back, recover from the experience they are reporting, 

and avoid future fraud. The entire site is available in Spanish at Reportefraude.ftc.gov. The FTC 

engaged in a multi-faceted outreach strategy that is ongoing to promote ReportFraud.ftc.gov in every 

community, which includes videos, blogs, social media messages, presentations and outreach to national 

and local partners, and paid online search ads in English and Spanish. Preliminary analysis of the report 

data by Dr. Michel Grosz and Dr. Raval in the FTC’s Bureau of Economics shows an average increase 

of approximately 27% in the number of online and mobile reports filed with the FTC immediately 

following the launch.

ReportFraud.ftc.gov landing page

 137 See FTC Consumer Alert, Scammers cash in on confusion over vaccine verification methods (May 28, 2021), available at

https://www.consumer.ftc.gov/blog/2021/05/scammers-cash-confusion-over-vaccine-verification-methods.
FEDERAL TRADE COMMIS SION FTC. GOV 35

In March 2021, the FTC launched the Community Advocate Center to increase the number of 

reports the FTC receives from lower-income communities.

138 The Report Fraud Community Advocates 

are organizations providing free or low-cost legal representation which have partnered with the FTC to 

help their clients work through fraud and other bad business experiences. Participating organizations 

receive a custom link to ReportFraud.ftc.gov through which they can report their clients’ experiences 

with fraud and get advice to help them try to recover money lost. Participants can also track the reports 

they have filed and receive quarterly reports about consumer issues in their regions. 

The FTC values these connections with legal services providers, which have provided important 

information on concerns affecting the communities they serve.139 Key organizations that support legal 

services work and advocate for communities of color, such as the Legal Services Corporation, the 

National Legal Aid & Defender Association, the National Consumer Law Center, and the National 

Association of Consumer Advocates,

140 support the Community Advocate Center initiative. 

IV. FTC Workshops and Industry Studies

The FTC has conducted a number of workshops and other engagements to gather information 

and to learn from industry, advocates, and other stakeholders. It also has published reports, business 

guidance, and comments on pertinent topics. 

A. Workshops

In December 2016, the FTC conducted a workshop, The Changing Consumer Demographics, 

examining how the aging population and growing racial and ethnic diversity in the United States will 

affect the future of consumer protection.141 The workshop brought together demographers, researchers, 

marketers, consumer groups, and federal, state, and local law enforcement to examine the predicted 

changes in various diverse groups and discuss what impact those changes will have on the marketplace. 

 138 FTC Community Advocate Center, available at https://reportfraud.ftc.gov/community. 139 See, e.g., FTC Blog, I’d like to thank (July 2015), available at https://www.consumer.ftc.gov/blog/2015/07/id-thank; 

Fraud Affects Every Community: Debt Settlement Companies, available at https://vimeo.com/352058978 (FTC video 

highlighting work of Community Legal Services); and Fraud Affects Every Community: Debt Collection (FTC video 

highlighting work of Pine Tree Legal Assistance), available at https://vimeo.com/352069281. 140 See, e.g., Legal Services Corporation Press Release, Legal Services Corporation Requests Supplemental Funding to Help 

Implement American Jobs Plan (Apr. 5, 2021), available at https://www.lsc.gov/press-release/legal-services-corporationrequests-supplemental-funding-help-implement-american-jobs-plan (“Sixty percent of [Legal Service Corporation’s] 

grantees’ clients are people of color, the majority of whom are women. Civil legal aid attorneys help tackle barriers to justice 

created by the intersection of race and poverty.”); National Legal Aid & Defender Association, Racial Justice Action Plan 

(Oct. 2018), available at

https://www.nlada.org/sites/default/files/pictures/NLADA_Racial_Justice_Action_Plan_%28Oct%202018%29.pdf; National 

Consumer Law Center, Racial Justice and Equal Economic Opportunity Project, available at https://www.nclc.org/specialprojects/racial-justice.html. 141 See The Changing Consumer Demographics (Dec. 6, 2016), available at https://www.ftc.gov/news-events/eventscalendar/2016/12/changing-consumer-demographics. 
FEDERAL TRADE COMMIS SION FTC. GOV 36

According to demographers at the workshop, the U.S. population will be even more racially and 

ethnically diverse in the future, and by 2060, no group will be the majority.142 The biggest growth in 

population segments is expected among Latinos born in the U.S., Asian Americans, multiracial 

Americans, and the aging baby boomers. Experts recommended working with trusted partners – such as 

community organizations and ethnic media – to reach diverse consumers, and recommended using 

tailored language and culturally appropriate messaging to best reach different audiences.

In July 2019, the FTC hosted a workshop, Nixing the Fix: A Workshop on Repair Restrictions, to 

examine the ways in which manufacturers may limit third-party repairs and whether those limitations 

affect consumer protection.143 The FTC submitted a congressional report on repair restrictions in May 

2021.144 For the report, the FTC synthesized knowledge gained from the workshop, as well as public 

comments, responses to a request for empirical research and data, and independent research. Among 

other things, the report made observations relating to communities of color, including that the burden of 

repair restrictions may fall more heavily on communities of color and lower-income communities.145

The FTC will continue to examine the many consumer protection issues raised by repair restrictions, and 

pursue appropriate law enforcement and regulatory options, as well as consumer education. 

In December 2019, the FTC and the CFPB hosted a public workshop, Accuracy in Consumer Reporting, 

to explore issues affecting the accuracy of both traditional credit reports and employment and tenant 

background screening reports, including the use of machine learning and alternative data in making 

eligibility determinations.146 Among other topics, the panelists explored the interplay between these 

issues, and their impact on people of color obtaining credit, housing and employment. One panelist 

stated that a consumer’s data itself, as it enters into the credit reporting system, can be biased, without 

even accounting for the biases against communities of color at the point of service.147

 142 See id., Changing Demographics Workshop Slides Part 1, available at 

https://www.ftc.gov/system/files/documents/public_events/955193/consumer_demographics_part1_0.pdf. 143 See Nixing the Fix, A Workshop on Repair Restrictions (July 16, 2019), workshop webpage, including transcript, available 

at https://www.ftc.gov/news-events/events-calendar/nixing-fix-workshop-repair-restrictions. 144 See Nixing the Fix: An FTC Report to Congress on Repair Restrictions (May 2021), available at 

https://www.ftc.gov/system/files/documents/reports/nixing-fix-ftc-report-congress-repairrestrictions/nixing_the_fix_report_final_5521_630pm-508_002.pdf. 145 The report noted that many Black-owned small businesses are in the repair and maintenance industries, and difficulties 

facing small businesses can disproportionately affect small businesses owned by people of color from underserved 

communities. In addition, repair restrictions for some products, such as smartphones, also may place a greater financial 

burden on communities of color and lower-income Americans, as research shows that Black and Latino consumers are about 

twice as likely as White consumers to have smartphones, but no broadband access at home. See supra note 144 at 3-4. 146 See Accuracy in Consumer Reporting: An FTC/CFPB Workshop (Dec. 10, 2019), available at https://www.ftc.gov/newsevents/events-calendar/accuracy-consumer-reporting-workshop. 147 See FTC Transcript (Morning Session) of Accuracy in Consumer Reporting Workshop at 16 (Dec. 10, 2019), available at

https://www.ftc.gov/system/files/documents/videos/accuracy-consumer-reporting-workshop-session1/ftc_accuracy_in_consumer_reporting_workshop_transcript_segment_1_12-10-19.pdf (“sometimes just the data from where 

you are and who you are, as it enters the credit reporting system, can be biased. If you were to account for biases at point of 

service for communities of color, then yes, the credit reporting system would be very biased.”). The panelist further 

highlighted his concerns about using alternative data to determine credit worthiness given issues with the “accuracy, 

transparency, predictive capacity, the impact of using such data, especially on communities of color.” Id. at 35. Another 

panelist noted during a discussion of using criminal records data in the area of housing, given “what we know about mass 
FEDERAL TRADE COMMIS SION FTC. GOV 37

In April 2021, the FTC hosted a workshop, Bringing Dark 

Patterns to Light: An FTC Workshop, to examine digital “dark 

patterns” – user interface design features that can manipulate 

consumers into taking unintended or undesired actions.148 The 

workshop featured panel discussions and presentations by 

experts in human-computer interaction, user experience design, privacy, and consumer protection, and 

covered a range of topics, including the impact of dark patterns on communities of color. In addition, 

some panelists observed that greater economic stress, language barriers, and cultural differences all may 

make non-English speakers and people of color more susceptible to dark patterns and lead to disparate 

impacts that exacerbate existing racial and socioeconomic disparities. They emphasized the need for 

companies and organizations to examine the effects that their technologies are having on different 

communities, as well as the need for increased government regulation and enforcement regarding 

deceptive and unfair dark patterns.149

Surveillance practices and the use of artificial intelligence (“AI”) also raise concerns for people 

in different population segments. Every year since 2016, the FTC holds PrivacyCon, a conference in 

which researchers present cutting-edge work on privacy, data security, and AI, which helps inform the 

FTC’s policy and enforcement work. For example, advances in AI technology promise to revolutionize 

our approach to medicine, finance, business operations, media, and more. But research has highlighted 

how apparently “neutral” technology can produce troubling outcomes – including discrimination by race 

or other legally protected classes. For example, during a panel on Bias in Algorithms at PrivacyCon 

2020, researchers presented a study demonstrating that an algorithm used with good intentions – to 

target medical interventions to the sickest patients – ended up funneling resources to a healthier, White 

population, to the detriment of sicker, Black patients.150 Similar to PrivacyCon 2020, PrivacyCon 2021 

also examined bias in algorithms. The event included a number of presenters addressing algorithmic 

bias, and how best to combat it.151 For example, researchers presented a study on auditing for 

 

incarceration in this country . . . any way in which you’re using blanket rules to disqualify people based on their criminal 

records is anything but colorblind and will have a huge disproportionate impact on people of color in this country.” See FTC 

Transcript (Afternoon Session) of Accuracy in Consumer Reporting Workshop at 31-33, available at 

https://www.ftc.gov/system/files/documents/videos/accuracy-consumer-reporting-workshop-session2/ftc_accuracy_in_consumer_reporting_workshop_transcript_segment_2_12-10-19.pdf. 148 See Bringing Dark Patterns to Light: An FTC Workshop (Apr. 29, 2021), workshop webpage available at 

https://www.ftc.gov/news-events/events-calendar/bringing-dark-patterns-light-ftc-workshop. 149 See FTC Transcript of the Dark Patterns Workshop at 43-52 (Apr. 29, 2021), available at 

https://www.ftc.gov/system/files/documents/public_events/1586943/ftc_darkpatterns_workshop_transcript.pdf. 150 Ziad Obermeyer et al., Dissecting racial bias in an algorithm used to manage the health of populations, 366 Science 6464, 

447-53 (Oct. 25, 2019), available at https://science.sciencemag.org/content/366/6464/447. 151 See PrivacyCon2021 Event Description and Agenda available at https://www.ftc.gov/news-events/eventscalendar/privacycon-2021.
FEDERAL TRADE COMMIS SION FTC. GOV 38

discrimination in algorithms delivering job ads.152 More research is needed, however, to better 

understand these issues and their impact on communities of color. 

FTC staff recently published posts on the FTC’s Business Blog providing guidance on using AI

and algorithms—including a recommendation that companies test their algorithms, both at the outset and 

periodically thereafter, to make sure they do not create a disparate impact on a protected class.153

B. Industry Studies

The FTC is conducting an industry study of social media and video streaming platforms to better 

understand how these companies collect, use, and present personal and demographic information, their 

advertising and user engagement practices, and how these practices may impact consumers, including 

communities of color. Specifically, our study will help us understand how these platforms use 

consumers’ sensitive information to target or exclude specific communities from ads and marketplace 

opportunities, as well as what steps these platforms are taking to ensure that their algorithms are not 

biased by, for example, missing significant information from communities of color.

In December 2020, the FTC issued orders to nine companies to obtain relevant data,

154 the study 

of which will help inform and guide the FTC’s policy and enforcement approaches. 

The FTC also is conducting an industry study regarding how broadband companies collect, use, 

and disclose information about consumers and their devices.155 In March 2019, the FTC issued orders to 

 152 See Basileal Imana, Aleksandra Korolova, Johan Heidemann, Auditing for Discrimination in Algorithms Delivering Job 

Ads, In Proceedings of the Web Conference 2021 (Apr. 19-23, 2021), available at

https://www.ftc.gov/system/files/documents/public_events/1582978/auditing_for_discrimination_in_algorithms_delivering_j

ob_ads.pdf. 153 See Elisa Jillson, Aiming for truth, fairness, and equity in your company’s use of AI, FTC Business Alert (Apr. 19, 2021), 

available at https://www.ftc.gov/news-events/blogs/business-blog/2021/04/aiming-truth-fairness-equity-your-companys-use-ai, citing 

Eliane Röösli, Brian Rice, Tina Hernandez-Boussard, Bias at warp speed: how AI may contribute to the disparities gap in the 

time of COVID-19, Journal of the American Medical Informatics Association (Aug. 17, 2020); FTC Business Blog, Using 

Artificial Intelligence and Algorithms (Apr. 8, 2020), available at https://www.ftc.gov/news-events/blogs/businessblog/2020/04/using-artificial-intelligence-algorithms. 154 See Press Release, FTC, FTC Issues Orders to Nine Social Media and Video Streaming Services Seeking Data About How 

They Collect, Use, and Present Information (Dec. 14, 2020), available at https://www.ftc.gov/news-events/pressreleases/2020/12/ftc-issues-orders-nine-social-media-video-streaming-services. 155 See Press Release, FTC, FTC Seeks to Examine the Privacy Practices of Broadband Providers (Mar. 26, 2019), available 

at https://www.ftc.gov/news-events/press-releases/2019/03/ftc-seeks-examine-privacy-practices-broadband-providers; see 

also Press Release, FTC, FTC Revises List of Companies Subject to Broadband Privacy Study (Aug. 29, 2019), available at 

https://www.ftc.gov/news-events/press-releases/2019/08/ftc-revises-list-companies-subject-broadband-privacy-study. 
FEDERAL TRADE COMMIS SION FTC. GOV 39

seven U.S. internet broadband providers and related 

entities to obtain relevant data. As the internet 

assumes an increasingly pervasive role in the most 

personal aspects of our lives, including telehealth and 

distance learning, the privacy of consumer data 

requires increased attention, especially for 

communities of color and low-income communities.

These consumers may have fewer choices when it 

comes to protecting the privacy of their activities 

online, either because they have fewer internet 

options or because even though they have options, they have no choice but to accept low-price services 

in exchange for giving up their privacy. The Pew Research Center has shown disparities between White, 

Black, and Latino communities when it comes to access to home broadband service.156 Recent research 

from UCLA found that Black and Hispanic households are 1.3 to 1.4 times as likely as White 

households to experience limited connectivity, and low-income households are most affected by digital 

unavailability, with more than 2 in 5 having only limited access to a computer or the internet.157

C. Advocacy Work Related to the Equal Credit Opportunity Act 

The FTC engages in advocacy work to help protect communities of color in credit transactions. 

For example, FTC staff recently commented on the disparate impact standard under the Equal Credit 

Opportunity Act (“ECOA”) and Regulation B158 and the credit needs of small businesses, including 

those that are minority-owned.159 Also, in a joint amicus brief with the CFPB in TeWinkle v. Capital 

One, N.A., the FTC argued that the term “applicants” in the ECOA applies to those who are currently 

 156 According to Pew Research, as of February 2021, 80% of White U.S. adults are home broadband users, as compared to 

71% of Black U.S. adults and 65% of Hispanic U.S. adults. See Pew Research Center, Internet/Broadband Fact Sheet (Apr. 7, 

2021), available at https://www.pewresearch.org/internet/fact-sheet/internet-broadband/?menuItem=3109350c-8dba-4b7fad52-a3e976ab8c8f; Sara Atske & Andrew Perrin, Home broadband adoption, computer ownership vary by race, ethnicity in 

the U.S., Pew Research Center (July 16, 2021), available at https://www.pewresearch.org/fact-tank/2021/07/16/homebroadband-adoption-computer-ownership-vary-by-race-ethnicity-in-the-u-s/ (“A quarter of Hispanics are “smartphone-only” 

internet users – meaning they own a smartphone but lack traditional home broadband services. By comparison, 12% of White 

adults fall into this category. Among Black adults, 17% are smartphone dependent, but this share is not statistically different 

from their White or Hispanic counterparts.”).

157 John McDonald, Despite improved access, digital divide persists for minority, low-income students, UCLA Newsroom 

(Dec. 8, 2020), available at https://newsroom.ucla.edu/releases/digital-divide-persists-for-minority-low-income-students. 158 ECOA and Regulation B, its implementing regulation, prohibit discrimination in credit transactions. 159 FTC Staff Comment to the CFPB, Regarding Regulation B, the Implementing Regulation of the Equal Credit Opportunity 

Act (Dec. 2020), available at https://www.ftc.gov/policy/advocacy/advocacy-filings/2020/12/ftc-staff-comment-cfpbregarding-regulation-b-implementing. 

As the internet assumes an increasingly 

pervasive role in the most personal 

aspects of our lives, including telehealth 

and distance learning, the privacy of 

consumer data requires increased 

attention, especially for communities of 

color and low-income communities.
FEDERAL TRADE COMMIS SION FTC. GOV 40

seeking credit as well as those who sought and have now received credit.160 In doing so, the FTC sought 

to ensure that protections against discrimination were not unduly limited. 

V. Research Relating to Communities of Color

The FTC conducts research and analysis to identify the impact of consumer problems on various groups 

and population segments. This research and work by others has highlighted disparities in the 

marketplace for consumers living in communities of color. Such research has been helpful in guiding the 

FTC’s efforts described above, but more is needed to further understand the disparities.

A. Differences in the Prevalence of Fraud

Since 2004, the FTC has conducted four surveys looking at the prevalence of fraud in the United 

States, which have demonstrated the magnitude of fraud.

161 The most recent survey, released in 2019,

found that 15.9% of participants – representing 40 million U.S. adult consumers – reported experiencing

one or more of the frauds included in the survey.162 All of the surveys found that Black and Latino163

consumers were more likely to have experienced the surveyed frauds than White consumers.164

Although the fourth survey did not find a statistical significance in the disparity,165 these surveys overall 

reveal some differences among the different population segments in the marketplace.

The National Crime Victim Survey on financial fraud by the DOJ’s Bureau of Justice Statistics 

(“BJS”), which focused on more limited and severe types of fraud than the FTC’s survey, also showed 

 160 Brief of Amici Curiae CFPB and FTC In Support of Appellant and Reversal at 13, TeWinkle v. Capital One, N.A., No. 20-

2049, ECF No. 62 (2d Cir. Oct. 7, 2020), available at https://www.ftc.gov/policy/advocacy/amicus-briefs/2020/10/bradleytewinkle-v-capital-one-na. The appeal is still pending. 161 FTC, Bureau of Economics Staff Report, Consumer Fraud in the United States: An FTC Survey (Aug. 2004), available at

https://www.ftc.gov/sites/default/files/documents/reports/consumer-fraud-united-states-ftc-survey/040805confraudrpt.pdf

(hereinafter “Fraud Survey 2004”); FTC, Bureau of Economics Staff Report, Consumer Fraud in the United States: The 

Second Survey (Oct. 2007), available at https://www.ftc.gov/sites/default/files/documents/reports/consumer-fraud-unitedstates-second-federal-trade-commission-survey-staff-report-federal-trade/fraud.pdf (hereinafter “Fraud Survey 2007”); FTC, 

Bureau of Economics Staff Report, Consumer Fraud in the United States, 2011: The Third FTC Survey (Apr. 2013), 

available at https://www.ftc.gov/reports/consumer-fraud-united-states-2011-third-ftc-survey (hereinafter “Fraud Survey 

2013”); FTC, Bureau of Economics Staff Report, Mass-Market Consumer Fraud in the United States: A 2017 Update (Oct. 

2019), available at https://www.ftc.gov/system/files/documents/reports/mass-market-consumer-fraud-united-states-2017-

update/p105502massmarketconsumerfraud2017report.pdf (hereinafter “Fraud Survey 2019”). 162 Fraud Survey 2019, supra note 161 at 23-24. 163 The fraud surveys used the terms “African Americans” and “Hispanics,” but this update uses the terms “Black” and 

“Latino.”

164 Fraud Survey 2004, supra note 161 at 61; Fraud Survey 2007, supra note 161 at S-2; Fraud Survey 2013, supra note 161

at 98; Fraud Survey 2019, supra note 161 at 112. The first two FTC fraud surveys also found that those who are American 

Indians or Alaska Natives were significantly more likely to have experienced fraud than Whites. Fraud Survey 2004, supra

note 161 at 55-62; Fraud Survey 2007, supra note 161 at 26-27, 30. While the 2005 data analyzed in the 2007 survey showed 

that American Indians or Alaska Natives have a higher incidence of fraud than Whites, the difference was not statistically 

significant. Fraud Survey 2007, supra note 161 at 26, n. 32. 165 Fraud Survey 2019, supra note 161 at 112 (estimated likelihood of being a victim of one of the surveyed frauds: 19.2% for 

African Americans, 17.3% for Hispanics, 14.9% for Non-Hispanic Whites).
FEDERAL TRADE COMMIS SION FTC. GOV 41

disparities.166 BJS’s first supplement to National Crime Victim Survey on financial fraud conducted in 

2017 estimated 3 million persons, or about 1.25% of those age 18 or older, reported that they were 

victims of personal financial fraud during the prior 12 months. The survey found disparities in the 

demographics of the participants, stating that “[a] smaller percentage of [W]hite persons were victims of 

financial fraud (1.19%) than [B]lack persons (1.67%) and persons who were Native Hawaiian or Other 

Pacific Islander, American Indian or Alaska Native, or two or more races (2.19%).”167

B. Disparities in Consumer Reporting of Marketing Practices

Reports from consumers about marketing practices that are collected through the Sentinel 

database provides an important source of information to the FTC for law enforcement purposes, and also 

illuminate trends and disparities. The agency collects and analyzes the reports and also provides federal, 

state, and local law enforcement agencies with secure access to them. Law enforcement agencies and 

other organizations contribute consumer reports to the database, which is searchable by criteria such as 

the type of report and the name, address, and telephone number of the reported entity.168 Using Sentinel, 

the FTC and its law enforcement partners can analyze reports to look for patterns and trends, identify 

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

investigation.169 In 2020, the agency received more than 4.7 million consumer reports, a notable increase 

over prior years.170 Analysis of this information provides insights into the communities that report to the 

FTC, such as what types of concerns they report, the payment methods reported, and other details about 

the consumers’ experiences.

1. Rates of Reporting

FTC consumer reporting data analysis 

demonstrates disparities in the rates of reporting by 

people residing in Black and Latino communities as 

compared to those residing in White communities. The 

FTC’s 2016 report, Combating Fraud in African 

 

166 Rachel E. Morgan, Fraud in the United States, 2017, DOJ, Bureau of Justice Statistics (Apr. 2017), available at 

https://www.bjs.gov/index.cfm?ty=pbdetail&iid=7366. 167 Id. at 5. 168 A list of Sentinel data contributors is located at https://www.ftc.gov/enforcement/consumer-sentinel-network/datacontributors. 169 To make reporting data more transparent, in 2018, the agency began making aggregate reporting data on fraud, identity 

theft, and other consumer problems available in interactive online dashboards. This tool, accessible at ftc.gov/exploredata, 

provides a timely snapshot of what consumers are reporting, allowing users to explore data by types of fraud, state, and other 

criteria.

170 The number of consumer reports increased by 1.7 million from 2015, when the agency received 3 million reports. This 

figure includes reports about fraud, identity theft, and other consumer problems. It does not include reports regarding Do Not 

Call violations. See FTC Report, Consumer Sentinel Network Data Book 2020, at 4 (Feb. 2021), available at

https://www.ftc.gov/system/files/documents/reports/consumer-sentinel-network-data-book2020/csn_annual_data_book_2020.pdf. A number of factors likely contributed to this increase since 2015, including an 

increase in data contributors, increased agency outreach on the importance of reporting, and, most recently, the rise in reports 

related to the pandemic. 

FTC consumer reporting data analysis 

demonstrates disparities in the rates of 

reporting by people residing in Black 

and Latino communities as compared 

to those residing in White communities.
FEDERAL TRADE COMMIS SION FTC. GOV 42

American and Latino Communities,

171 included research conducted by the FTC’s Bureau of Economics 

that matched the zip code information voluntarily provided when people filed Sentinel reports in 2015 to 

the U.S. Census Bureau’s demographic information for those zip code areas. Analyzing the aggregate 

information, Dr. Raval could draw inferences as to the likely demographics of the consumers filing 

reports and provide insight into the reporting trends for predominantly Black, Latino, and White 

communities. That research showed that people living in predominantly Latino communities submitted

substantially fewer reports than people in predominantly White zip code areas.172

The 2016 Report also analyzed customer data from an FTC case, Ideal Financial Solutions, 

which involved unauthorized debiting from the bank accounts of people who applied for payday loans. 

People who lived in zip codes heavily populated with Black residents were more than four times more 

likely to have experienced unauthorized bank debits by the defendants than people living in areas that 

were predominantly White or Latino.173 Dr. Raval found that despite the higher rates of loss in 

predominantly Black communities in Ideal Financial, people in those same zip code areas filed reports 

about the defendants about 45% less often than heavily White communities.174

New research analyzing the consumer reports received in Sentinel in 2020 shows disparities in 

the reporting rates from Black, Latino, and White communities when mapping this data to the Census 

Bureau’s zip code information.175 Figure A below illustrates the rate at which each community filed 

reports in 2020; that is, how many reports were filed for every 1,000 people in the community. The 

communities are defined by the Black, Latino, and White population concentrations in zip code areas 

where complainants reside, shown as 0% to 100% in Figure A.176 Figure A shows that communities with 

more than 50% Latino residents filed reports at rates that were much lower than those of communities 

with a majority of Black or White residents.177 Further, the rate of filing for Latino communities gets 

 171 See FTC Report, Combating Fraud in African American and Latino Communities (June 15, 2016), available at 

https://www.ftc.gov/system/files/documents/reports/combating-fraud-african-american-latino-communities-ftcscomprehensive-strategic-plan-federal-trade/160615fraudreport.pdf. 172 FTC Staff Economist Devesh R. Raval in the Bureau of Economics conducted this research examining the zip codes

provided in Consumer Sentinel reports. See FTC Report, Combating Fraud in African American and Latino Communities,

supra note 171 at 4-6; see also Devesh Raval, Which Communities Complain To Policymakers? Evidence From Consumer 

Sentinel, Economic Inquiry (2021), available at https://deveshraval.github.io/complaintSentinel.pdf. 173 See FTC Report, Combating Fraud in African American and Latino Communities, supra note 171 at 15. 174 Id. at 16. Note that the Dr. Raval’s analysis takes factors such as income and education into account. The disparities would 

be larger without controlling for these factors. Further, in a subsequent paper, Dr. Raval analyzed the customer data and the 

complaint data for eight additional FTC matters and again found “strong evidence” that residents of heavily Black and 

heavily Latino areas complain at lower rates than other areas compared to their level of victimization. See Devesh Raval, 

Whose Voice Do We Hear in the Marketplace?: Evidence from Consumer Complaining Behavior, Marketing Science (2020),

available at https://deveshraval.github.io/complaintBehavior.pdf. 175 The analysis does not include Native American, Asian American, or other communities because the number of zip codes 

with a majority of residents from other groups is very small. 

176 Figure A shows the raw number of reports in the FTC’s Consumer Sentinel database for every 1,000 persons in that zip 

code. The analysis is limited to reports that included a zip code and that related to fraud and other consumer protection 

problems (such as financial and credit problems) in Consumer Sentinel, and does not include reports about identity theft or 

Do Not Call violations. Consumers voluntarily provided a zip code in 88% of the relevant reports. Zip codes that 

corresponded to unique organizations, PO boxes, or areas with a population of less than 100 were excluded from the analysis. 

Zip code demographics are based on data from the Census Bureau’s American Community Survey from 2014 to 2018. 

Individuals who filed six reports or more in a given year are excluded from the analysis to avoid distorting the results.

177 The FTC has seen a general increase of consumer reports coming to the FTC directly since 2015. The rate of reporting by 

people living in predominantly White and Black communities increased by about 85%, and the rate for people living in 

Latino communities increased by more than 100% since 2015.
FEDERAL TRADE COMMIS SION FTC. GOV 43

progressively lower as the population share of Latino residents increases. Communities with 

predominantly Black residents (75% or more) filed at a rate higher than communities with 

predominantly White and Latino residents.

178

Figure A

Consumer Sentinel Report Rates for Black, Latino, and White

Communities in 2020 for Combined Reports from All Contributors

2. Types of Reports

People living in communities with different demographic populations report different types of 

concerns at different rates. Figure B shows the types of Sentinel reports filed in 2020 for majority Black, 

Latino, and White communities. Each colored line in the graph shows the share of reports from each 

community about the various categories of reports. For example, impersonator scams179 were the top 

fraud reported in 2020, and this graphic examines how often different communities reported this scam.

The green line shows that 18% of all reports filed by people living in majority White communities were 

about impersonator scams. Likewise, the blue line shows that 17% of all reports filed by people living in 

majority Latino communities were about impersonator scams. For both groups, impersonator scams 

were the top report in Sentinel. For people living in majority Black communities, it was a different story. 

 178 Figures A and B show reports consumers filed with the FTC and all Sentinel contributors, including the CFPB. Prior 

analysis has found that the CFPB, which focuses on issues related to financial goods and services, received higher rates of 

reports from majority Black communities than the FTC or Better Business Bureaus. See Raval, Which Communities 

Complain To Policymakers?, supra note 172 at 1, 5, 25-26. 179 Impersonator scams involve scammers who falsely claim to be with the government, a well-known business, or some 

other trusted entity or person to get people to send them money. These include government impersonator scams, such as fake 

Social Security Administration calls, and business imposters, such as calls impersonating Microsoft.
FEDERAL TRADE COMMIS SION FTC. GOV 44

In majority Black communities, the top 

report was about credit bureaus, as Figure B 

illustrates. About 21% of the total reports filed by 

people living in majority Black communities were 

about credit bureaus, and impersonator scams 

came in second place ranking with 12.5% of 

reports. People living in other communities filed 

much lower percentages of reports about credit 

bureaus: only about 5.2% of total reports by 

majority White communities were about credit 

bureaus, and in majority Latino communities it was about 12%. Other categories in which people living 

in majority Black communities filed a higher percentage of reports include banks and lenders, auto 

issues, and debt collection. In fact, people living in majority Black communities filed a significantly 

higher percentage of reports about used auto sales than majority Latino and White communities. People 

living in majority Latino and White communities filed a significantly higher share of reports about new 

auto sales.180

Looking at the blue lines in Figure B, people 

living in majority Latino communities filed a higher 

share of reports about credit bureaus, banks and 

lenders, auto issues, and debt collection than majority 

White communities. In addition, people living in 

majority Latino communities filed a higher share of 

reports about business opportunities and job scams 

than people living in majority Black or White 

communities.

 180 Approximately 22% of the reports filed by consumers residing in majority Black communities about auto issues were 

about new auto sales (compared to almost 30% of the auto-related reports filed by by consumers residing in majority Latino 

and White communities), and 33% of the reports filed by consumers residing in majority Black communities about autorelated issues were about used auto sales (compared to approximately 23% of the share of reports filed by consumers residing 

in majority Latino and White communities). 

[P]eople living in majority Latino 

communities filed a higher share of 

reports about business opportunities and 

job scams than people living in majority 

Black or White communities.

In majority Black communities, the top 

report was about credit bureaus.... Other 

categories in which people living in majority 

Black communities filed a higher 

percentage of reports include banks and 

lenders, auto issues, and debt collection.
FEDERAL TRADE COMMIS SION FTC. GOV 45

Figure B

Share of Consumer Sentinel Report Types for Majority Black, Latino,

and White Communities in 2020 for Combined Reports from All Contributors181

3. Payment Methods Reported

People filing reports directly with the FTC can voluntarily provide information about the way 

they paid for the scam or bad business practice being reported. Figure C shows the differences in the 

payment methods reported by each of the three communities for reports filed directly with the FTC in 

2020.

The differences between what communities 

report about the payment methods used during 

their experiences is striking. People living in 

majority White communities filed the largest share 

of their reports about credits cards (almost 28%), 

while people living in majority Black and Latino 

communities filed the largest share of their reports 

about payments made with debit cards (about 27% 

and 24% respectively). Since the law provides 

additional fraud protection in credit card 

transactions,182 these disparities in reporting 

illustrate inequities in the legal protections 

available to the groups. In addition, people living 

in majority Black and Latino communities reported 

 181 A more comprehensive chart showing the Sentinel report numbers for additional categories can be found at Appendix A. 182 See FTC Consumer Information, Lost or Stolen Credit, ATM, and Debit Cards, available at 

https://www.consumer.ftc.gov/articles/0213-lost-or-stolen-credit-atm-and-debit-cards. 

[P]eople living in majority Black and Latino 

communities reported a larger share of 

payments using cash, cryptocurrency, and 

money orders. . . . since many of these 

payment methods do not enjoy the legal 

protections attached to credit card

payments, the people living in communities 

of color with less access to credit cards 

have, in turn, less recourse for fraud and 

other problematic experiences.
FEDERAL TRADE COMMIS SION FTC. GOV 46

a larger share of payments using cash, cryptocurrency, and money orders. People living in majority 

Black communities also filed more reports about payment apps or services and gift card or reload cards 

than people living in the other communities, while people living in majority Latino communities filed 

larger shares of reports about bank transfers or payments and wire transfers. Again, since many of these 

payment methods do not enjoy the legal protections attached to credit card payments, the people living 

in communities with less access to credit cards have, in turn, less recourse for fraud and other 

problematic experiences.

Figure C

Consumer Sentinel Reports with Payment Method for

Black, Latino, and White Communities 2020

C. Disparities in FTC Cases

Apart from examining reports from 

consumers about their experiences, the FTC also

can learn from its law enforcement cases. An 

examination of 23 FTC cases shows that 

predominantly Black communities are overrepresented in the pool of consumers who lost 

money.

The FTC cases involving payday loan applications, student debt relief programs, and certain

business opportunities had the largest number of affected consumers residing in predominantly Black 

An examination of 23 FTC cases shows 

that predominantly Black communities are 

over-represented in the pool of consumers 

who lost money.
FEDERAL TRADE COMMIS SION FTC. GOV 47

communities.183 The study found the largest effects for cases involving payday loan applications and 

student debt relief programs, with approximately a 200% higher number of consumers having purchased 

such services in predominantly Black communities than White communities. For business opportunity 

cases, Dr. Raval found higher rates of affected consumers in heavily Black communities in lower dollar 

investment schemes where participants invested under $500. In cases requiring investments of over 

$500, Dr. Raval found that Black communities were underrepresented.

184

The FTC’s Bureau of Economics is continuing to analyze additional data from consumer 

protection cases to assist in identifying the communities affected.185 Although the findings are limited to 

the particular cases analyzed, this research has provided important insight as the agency seeks to 

understand more about how certain scams and consumer problems affect people living in different 

communities. Such information can guide strategic planning both in case targeting and designing

outreach programs. It also confirms that the FTC needs to use a variety of channels to ensure the agency 

learns about issues in every community.

186

VI. Looking Forward

The Every Community Initiative is an important part of the FTC’s work to fight for all 

consumers that utilizes a coordinated, multi-pronged approach to help stop and prevent fraud and other 

problematic business practices affecting communities of color. The disproportionate health and 

economic impact of the COVID-19 pandemic on communities of color reminds us that there is much 

more to be done. 

The FTC is committed to serving communities of color through vigorous law enforcement

actions, meaningful community engagement and dialogue, and the pursuit of insightful research.

Looking forward, the FTC will focus on: 

Law Enforcement:

• Work to increase reporting of fraud and other consumer issues to the FTC by all communities, 

including by engaging with community-based organizations to use ReportFraud.ftc.gov to 

access information on how to try to recover money lost.

187 

• Enhance investigative resources to better identify conduct that either directly targets, or 

disproportionately impacts, communities of color. This includes developing or obtaining 

 183 See Raval, Who is Victimized by Fraud?, supra note 31 at 10-11. 184 Id. 185 In some instances the data has been customer databases and in others it is a list of the consumers who received redress in 

the cases, which may be a subset of all of the customers.

186 Dr. Raval suggests in one paper that policymakers consider a system of weighing consumer reports and overweight reports 

from groups that report less than their rate of victimization. See Raval, Whose Voice Do We Hear in the Marketplace?, supra 

note 174 at 1, 36-41. 187 See www.ReportFraud.ftc.gov/community.
FEDERAL TRADE COMMIS SION FTC. GOV 48

technical and other tools to improve the FTC’s ability to monitor advertising to communities of 

color and collect evidence of fraud and to develop expertise to assess potential algorithmic bias 

affecting communities of color. 

• Bring new law enforcement actions that shut down frauds that target or disproportionately affect

communities of color, and explore how the FTC may use its unfairness authority to target 

discriminatory and other problematic practices, such as algorithmic bias or discriminatory 

impacts related to facial recognition and other surveillance technology.

• Strengthen existing relationships, and form new partnerships, with agencies at the federal, state,

and local levels to further encourage information sharing, case referrals, and the opportunity to 

collaborate on matters whenever possible and logical. 

Outreach and Education:

• Make consumer and business education materials more widely available in multiple formats and 

languages, and look for new approaches to place consumer protection messages where people 

already are – physically, in the media, and online.

• Seek out additional trusted sources in communities of color, further strengthening and 

broadening relationships with community and legal services organizations and building greater 

partnerships with HBCUs, HSIs, and Tribal colleges, faith-based organizations, housing 

organizations, business organizations, and other groups that serve communities of color.

• Expand the agency’s relationships with ethnic media, working to disseminate educational 

messages to communities of color nationwide. Curate content for and deliver timely and 

informative content through the FTC’s Business and Consumer Alerts to ensure the agency is 

delivering key messages into the hands of target audiences. 

• Develop and disseminate education to increase consumer and business awareness and 

understanding of potential disparate impacts of technology, including AI and facial recognition.

Research:

• Increase the systematic review and analysis of reports in the Consumer Sentinel database, as well 

as FTC case and refund data, with a focus on identifying trends and disparities related to fraud 

and other practices that impact communities of color – including the root causes. 
FEDERAL TRADE COMMIS SION FTC. GOV 49

• Conduct industry studies and organize hearings, conferences, meetings, and other events to 

gather information and promote additional research with industry representatives, experts, 

advocates, and other stakeholders about consumer issues affecting communities of color. 

• Continue to research and improve understanding about the ways in which surveillance practices

target or create a disparate impact for people in different population segments. 
FEDERAL TRADE COMMIS SION FTC. GOV 50

Appendix A

Share of Consumer Sentinel Report Types for Majority Black, Latino,

and White Communities in 2020 for Combined Reports from All Contributors188

 188 Appendix A is a more comprehensive version of Figure B and includes additional categories of reports.