If giving refunds to consumers proves impracticable in this case, the money will be deposited in the U.S. Treasury. If these defendants are found to have misrepresented their financial condition, the settlements would permit the FTC to reopen the matters and seek additional redress. The Commission vote to file the complaint and proposed consent orders in court was 5-0. They were filed this morning in U.S. District Court for the District of New Jersey, in Newark. These consent orders are for settlement purposes only and do not constitute admissions by the defendants of law violations.
Consent orders have the force of law when signed by the judge.