The order also would require the defendants to obtain written authorization before debiting consumers' checking accounts or charging their credit cards, and to disclose all terms and conditions of any refund policy. Finally, the order contains various record keeping and reporting requirements that would assist the FTC in monitoring the defendants' compliance. The Commission vote to approve the settlement for filing in court was 5-0. It was filed today in U.S. District Court for the Southern District of New York, in New York City, and requires the court's approval to become binding. This consent order is for settlement purposes only and does not constitute an admission by the defendant of a law violation.
Consent orders have the force of law when signed by the judge.
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