Federal Register / Vol. 80, No. 25 / Friday, February 6, 2015 / Notices 6717 

1 In particular, the written request for confidential 

treatment that accompanies the comment must 

include the factual and legal basis for the request, 

and must identify the specific portions of the 

comment to be withheld from the public record. See 

FTC Rule 4.9(c), 16 CFR 4.9(c). 

official interpretation of the complaint 

or proposed order, or to modify in any 

way the proposed order’s terms. 

By direction of the Commission. 

Donald S. Clark, 

Secretary. 

[FR Doc. 2015–02376 Filed 2–5–15; 8:45 am] 

BILLING CODE 6750–01–P 

FEDERAL TRADE COMMISSION 

[File No. 132 3264] 

First American Title Lending of 

Georgia, LLC; Analysis of Proposed 

Consent Order To Aid Public Comment 

AGENCY: Federal Trade Commission. 

ACTION: Proposed Consent Agreement. 

SUMMARY: The consent agreement in this 

matter settles alleged violations of 

federal law prohibiting unfair or 

deceptive acts or practices. The attached 

Analysis to Aid Public Comment 

describes both the allegations in the 

draft complaint and the terms of the 

consent order—embodied in the consent 

agreement—that would settle these 

allegations. 

DATES: Comments must be received on 

or before March 3, 2015. 

ADDRESSES: Interested parties may file a 

comment at https://

ftcpublic.commentworks.com/ftc/

firstamericanlendingconsent/ online or 

on paper, by following the instructions 

in the Request for Comment part of the 

SUPPLEMENTARY INFORMATION section 

below. Write ‘‘First American Title 

Lending of Georgia, LLC—Consent 

Agreement; File No. 1323264’’ on your 

comment and file your comment online 

at https://ftcpublic.commentworks.com/

ftc/firstamericanlendingconsent/ by 

following the instructions on the webbased form. If you prefer to file your 

comment on paper, write ‘‘First 

American Title Lending of Georgia, 

LLC—Consent Agreement; File No. 

1323264’’ on your comment and on the 

envelope, and mail your comment to the 

following address: Federal Trade 

Commission, Office of the Secretary, 

600 Pennsylvania Avenue NW., Suite 

CC–5610 (Annex D), Washington, DC 

20580, or deliver your comment to the 

following address: Federal Trade 

Commission, Office of the Secretary, 

Constitution Center, 400 7th Street SW., 

5th Floor, Suite 5610 (Annex D), 

Washington, DC 20024. 

FOR FURTHER INFORMATION CONTACT: 

Helen Wong, Bureau of Consumer 

Protection, (202) 326–3779, 600 

Pennsylvania Avenue NW., Washington, 

DC 20580. 

SUPPLEMENTARY INFORMATION: Pursuant 

to Section 6(f) of the Federal Trade 

Commission Act, 15 U.S.C. 46(f), and 

FTC Rule 2.34, 16 CFR 2.34, notice is 

hereby given that the above-captioned 

consent agreement containing consent 

order to cease and desist, having been 

filed with and accepted, subject to final 

approval, by the Commission, has been 

placed on the public record for a period 

of thirty (30) days. The following 

Analysis to Aid Public Comment 

describes the terms of the consent 

agreement, and the allegations in the 

complaint. An electronic copy of the 

full text of the consent agreement 

package can be obtained from the FTC 

Home Page (for January 30, 2015), on 

the World Wide Web, at http://

www.ftc.gov/os/actions.shtm. 

You can file a comment online or on 

paper. For the Commission to consider 

your comment, we must receive it on or 

before March 3, 2015. Write ‘‘First 

American Title Lending of Georgia, 

LLC—Consent Agreement; File No. 

1323264’’ on your comment. Your 

comment—including your name and 

your state—will be placed on the public 

record of this proceeding, including, to 

the extent practicable, on the public 

Commission Web site, at http://

www.ftc.gov/os/publiccomments.shtm. 

As a matter of discretion, the 

Commission tries to remove individuals’ 

home contact information from 

comments before placing them on the 

Commission Web site. 

Because your comment will be made 

public, you are solely responsible for 

making sure that your comment does 

not include any sensitive personal 

information, like anyone’s Social 

Security number, date of birth, driver’s 

license number or other state 

identification number or foreign country 

equivalent, passport number, financial 

account number, or credit or debit card 

number. You are also solely responsible 

for making sure that your comment does 

not include any sensitive health 

information, like medical records or 

other individually identifiable health 

information. In addition, do not include 

any ‘‘[t]rade secret or any commercial or 

financial information which . . . is 

privileged or confidential,’’ as discussed 

in Section 6(f) of the FTC Act, 15 U.S.C. 

46(f), and FTC Rule 4.10(a)(2), 16 CFR 

4.10(a)(2). In particular, do not include 

competitively sensitive information 

such as costs, sales statistics, 

inventories, formulas, patterns, devices, 

manufacturing processes, or customer 

names. 

If you want the Commission to give 

your comment confidential treatment, 

you must file it in paper form, with a 

request for confidential treatment, and 

you have to follow the procedure 

explained in FTC Rule 4.9(c), 16 CFR 

4.9(c).1 Your comment will be kept 

confidential only if the FTC General 

Counsel, in his or her sole discretion, 

grants your request in accordance with 

the law and the public interest. 

Postal mail addressed to the 

Commission is subject to delay due to 

heightened security screening. As a 

result, we encourage you to submit your 

comments online. To make sure that the 

Commission considers your online 

comment, you must file it at https://

ftcpublic.commentworks.com/ftc/

firstamericanlendingconsent/ by 

following the instructions on the webbased form. If this Notice appears at 

http://www.regulations.gov/#!home, you 

also may file a comment through that 

Web site. 

If you file your comment on paper, 

write ‘‘First American Title Lending of 

Georgia, LLC—Consent Agreement; File 

No. 1323264’’ on your comment and on 

the envelope, and mail your comment to 

the following address: Federal Trade 

Commission, Office of the Secretary, 

600 Pennsylvania Avenue NW., Suite 

CC–5610 (Annex D), Washington, DC 

20580, or deliver your comment to the 

following address: Federal Trade 

Commission, Office of the Secretary, 

Constitution Center, 400 7th Street SW., 

5th Floor, Suite 5610 (Annex D), 

Washington, DC 20024. If possible, 

submit your paper comment to the 

Commission by courier or overnight 

service. 

Visit the Commission Web site at 

http://www.ftc.gov to read this Notice 

and the news release describing it. The 

FTC Act and other laws that the 

Commission administers permit the 

collection of public comments to 

consider and use in this proceeding as 

appropriate. The Commission will 

consider all timely and responsive 

public comments that it receives on or 

before March 3, 2015. You can find 

more information, including routine 

uses permitted by the Privacy Act, in 

the Commission’s privacy policy, at 

http://www.ftc.gov/ftc/privacy.htm. 

Analysis of Proposed Consent Order To 

Aid Public Comment 

The Federal Trade Commission 

(‘‘FTC’’ or ‘‘Commission’’) has accepted, 

subject to final approval, an agreement 

containing a consent order from First 

American Title Lending of Georgia, LLC, 

or respondent. The proposed consent 


asabaliauskas on DSK5VPTVN1PROD with NOTICES
6718 Federal Register / Vol. 80, No. 25 / Friday, February 6, 2015 / Notices 

order has been placed on the public 

record for thirty (30) days for receipt of 

comments by interested persons. 

Comments received during this period 

will become part of the public record. 

After thirty (30) days, the FTC will again 

review the agreement and the comments 

received, and will decide whether it 

should withdraw from the agreement 

and take appropriate action or make 

final the agreement’s proposed order. 

The respondent is a car title loan 

company. According to the FTC 

complaint, respondent has advertised its 

loans with advertisements that broadly 

state that the title loans are available for 

‘‘0% Interest!’’ Sometimes, but not 

always, these advertisements state in 

much smaller print, ‘‘Certain terms and 

conditions may apply’’ or ‘‘Some 

restrictions apply.’’ However, 

respondent’s advertisements fail to 

disclose that unless the loan is 

completely repaid in 30 days, the 0% 

offer does not apply and there is a 

significant finance charge. If a consumer 

does not repay the loan in full in 30 

days, he or she would then be required 

to pay the finance charge for the first 30 

days in addition to any additional 

finance charges incurred on day 31 (to 

start the second 30-day period). The 

advertisements also fail to disclose the 

amount of the finance charge after 

expiration of the 30-day introductory 

period. The proposed complaint alleges 

that these material omissions constitute 

a deceptive act or practice under 

Section 5 of the FTC Act. 

The Commission is also alleging a 

Truth in Lending Act (‘‘TILA’’) violation 

against respondent. Some 

advertisements displayed ‘‘9.5%’’ next 

to the claim of ‘‘0% interest.’’ First 

American allegedly violated TILA by 

advertising a finance rate (9.5%), but 

failing to state the rate as an APR. 

The proposed order is designed to 

prevent the respondent from engaging in 

similar deceptive practices, or violating 

TILA, in the future. Part I prohibits the 

respondent from stating an introductory 

or temporary finance charge without 

disclosing, clearly and conspicuously, 

the finance charge after the introductory 

or temporary period ends; or the full 

effect of failing to make a timely 

complete repayment of the loan within 

the introductory or temporary time 

period. Respondent must further 

disclose all qualifying terms associated 

with obtaining the loan at its advertised 

rate, including but not limited to, 

minimum loan requirements, new 

customer requirements, and any other 

material term; all costs associated with 

obtaining the loan, including but not 

limited to transaction costs, registration 

costs or fees, recording costs or fees, and 

title fees. The respondent also cannot 

misrepresent any other material fact 

about the terms of the loan. 

Part II of the proposed order prohibits 

the respondent, in connection with any 

advertisement to promote, directly or 

indirectly, any extension of consumer 

credit in or affecting commerce, from 

expressly or by implication stating the 

amount or percentage of down payment, 

the number of payments or period of 

repayment, the amount of any payment, 

or the amount of any finance charge, 

without disclosing clearly and 

conspicuously all of the terms required 

by Section 144 of TILA, 15 U.S.C. 1664, 

and Section 1026.24(c) of Regulation Z, 

including but not limited to the amount 

of percentage or the down payment; the 

terms of repayment; and the annual 

percentage rate, using that term or the 

abbreviation ‘‘APR.’’ If the annual 

percentage rate or APR may be 

increased after the consummation of the 

credit transaction, that fact must also be 

disclosed. Moreover, the respondent 

cannot state a rate of finance charge 

without stating the rate as an ‘‘annual 

percentage rate’’ using that term or the 

abbreviation ‘‘APR,’’ as required by 

Section 144 of the TILA, 15 U.S.C. 1664, 

and Section 1026.24(c) of Regulation Z; 

or fail to comply in any other respect 

with the TILA, 15 US.C. §§ 1601–1667, 

as amended, and its implementing 

Regulation Z, 12 CFR 1026 as amended. 

Parts III through VII of the proposed 

order are reporting and compliance 

provisions. Part III is an order 

distribution provision that requires 

respondent to provide the order to 

current and future principals, officers, 

directors, and managers and to all 

current employees, agents, and 

representatives having responsibilities 

with respect to the advertisement of 

consumer credit. Part IV of the proposed 

order requires respondent to maintain 

and upon request make available to the 

Commission certain compliance-related 

records, including all advertisements 

and also consumer complaints and 

records that demonstrate compliance 

with the proposed order for a period of 

five years. Part V requires respondent to 

notify the Commission of corporate 

changes that may affect compliance 

obligations within 30 days of such a 

change. Part VI requires respondent to 

submit a compliance report to the 

Commission 60 days after entry of the 

order, and also additional compliance 

reports within 10 business days of a 

written request by the Commission. Part 

VII ‘‘sunsets’’ the order after 20 years, 

with certain exceptions. 

The purpose of this analysis is to aid 

public comment on the proposed order. 

It is not intended to constitute an 

official interpretation of the complaint 

or proposed order, or to modify in any 

way the proposed order’s terms. 

By direction of the Commission. 

Donald S. Clark, 

Secretary. 

[FR Doc. 2015–02373 Filed 2–5–15; 8:45 am] 

BILLING CODE 6750–01–P 

FEDERAL TRADE COMMISSION 

[File No. 141 0134] 

Sun Pharmaceutical Industries Ltd., 

Ranbaxy Laboratories Ltd., and Daiichi 

Sankyo Co., Ltd.; Analysis of Proposed 

Consent Orders To Aid Public 

Comment 

AGENCY: Federal Trade Commission. 

ACTION: Proposed Consent Agreement. 

SUMMARY: The consent agreement in this 

matter settles alleged violations of 

federal law prohibiting unfair methods 

of competition. The attached Analysis to 

Aid Public Comment describes both the 

allegations in the draft complaint and 

the terms of the consent orders— 

embodied in the consent agreement— 

that would settle these allegations. 

DATES: Comments must be received on 

or before March 3, 2015. 

ADDRESSES: Interested parties may file a 

comment at https://

ftcpublic.commentworks.com/ftc/

sunpharmaceuticalconsent/ online or 

on paper, by following the instructions 

in the Request for Comment part of the 

SUPPLEMENTARY INFORMATION section 

below. Write ‘‘Sun Pharmaceutical 

Industries Ltd.—Consent Agreement; 

File No. 141–0134’’ on your comment 

and file your comment online at https:// 

ftcpublic.commentworks.com/ftc/

sunpharmaceuticalconsent/ by 

following the instructions on the webbased form. If you prefer to file your 

comment on paper, write ‘‘Sun 

Pharmaceutical Industries Ltd.— 

Consent Agreement; File No. 141–0134’’ 

on your comment and on the envelope, 

and mail your comment to the following 

address: Federal Trade Commission, 

Office of the Secretary, 600 

Pennsylvania Avenue NW., Suite CC– 

5610 (Annex D), Washington, DC 20580, 

or deliver your comment to the 

following address: Federal Trade 

Commission, Office of the Secretary, 

Constitution Center, 400 7th Street SW., 

5th Floor, Suite 5610 (Annex D), 

Washington, DC 20024. 

FOR FURTHER INFORMATION CONTACT: 

Aylin M. Skroejer, Bureau of 

Competition, (202–326–2459), 600 

Pennsylvania Avenue NW., Washington, 

DC 20580. 


asabaliauskas on DSK5VPTVN1PROD with NOTICES