Under the terms of the proposed settlement, the defendants would be prohibited in the future from violating the TSR, misrepresenting an affiliation with any consumer credit card issuer, misrepresenting any legal rights or obligations of consumers, or misrepresenting any other material fact. The settlement also would prohibit the defendants from selling information about any consumer who purchased credit card protection from them. Finally, the settlement contain recordkeeping requirements to assist the FTC in monitoring the defendants' compliance. The Commission vote to forward the complaint and the proposed consent decree to the Department of Justice for filing was 4-0. This consent decree is for settlement purposes only and does not constitute an admission by the defendants of law violations.
Consent decrees have the force of law when signed by the judge.