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FTC Staff Comment: Proposed Dental Services Rules in Texas Would Likely Reduce the Benefits of Competition for Consumers

Federal Trade Commission staff, in response to a notice requesting public comments, urged the Texas State Board of Dental Examiners to reject two proposed rules that impose new restrictions on the ability of Texas dentists to enter into contracts with non-dentists, such as dental service organizations (DSOs), for the provision of nonclinical, administrative services. The comment explains that such restrictions may reduce competition, likely resulting in higher prices and reduced access to dental services, especially for underserved populations.

The comment is part of the FTC’s ongoing efforts to promote competition in the health care sector, which benefits consumers through lower costs, better care, and more innovation.

The comment, submitted by staff of the FTC’s Office of Policy Planning, Bureau of Competition, and Bureau of Economics, states that the rules (proposed 22 Tex. Admin. Code § 108.70 and § 108.74) seem likely to discourage dentists from affiliating with DSOs by mandating that dentists assume responsibility for the types of functions that DSOs typically provide, and by expanding the Board’s authority to take disciplinary action against dentists who enter into these prohibited agreements. By contrast, under the current regulations, such service agreements for many business functions such as accounting and bookkeeping are presumed not to violate the Texas Dental Practice Act.

The comment states that the proposed rules, if adopted, may deny consumers the benefits of competition spurred by the efficiencies that DSOs can offer. By restricting dentists’ choices when deciding upon the most efficient way to organize the nonclinical aspects of their practices, the rules could deny dentists potentially significant cost savings and the ability to focus on providing dental care, rather than on the business management aspects of running a dental practice. These savings may lead to lower prices, improved service, and increased access to care.

The staff urged the Board to consider whether reliable evidence indicates that the rules will serve any important public purpose, such as addressing substantiated health and safety concerns or concerns about fraud; and if so, whether the proposed restrictions may be broader than necessary to address such concerns; and whether less restrictive alternatives might be available. Because the sweeping restrictions appear unnecessary to address any concerns about the independent judgment of dental professionals or fraud, but can be expected to inhibit competition, increase prices, and decrease access to dental services, the comment urges the Board to reject the proposed rules.

The Commission vote to issue the staff comment was 5-0. It was sent to Simone Salloum, Assistant General Counsel, Texas State Board of Dental Examiners, on October 6, 2014. (FTC File No. V140013; the staff contact is Karen Goldman, Office of Policy Planning, 202-326-2574).

The FTC’s Office of Policy Planning works with the Commission and its staff to develop long-range competition and consumer policy initiatives, consistent with the FTC’s unique mission to conduct research and engage in advocacy on issues that affect competition, consumers, and the U.S. economy. The Office of Policy Planning submits advocacy filings; conducts research and studies; organizes public workshops; issues reports; and advises staff on cases raising new or complex policy and legal issues. To reach the Office of Policy Planning, send an e-mail to [email protected]. Like the FTC on Facebook, follow us on Twitter, read our blogs, and subscribe to press releases for the latest FTC news and resources.

FTC Settlement Bars WordSmart from Deceiving Parents With Unsupported Claims About its Education Products

Educational services company WordSmart Corporation and its president have agreed to settle Federal Trade Commission charges that they deceptively marketed the company’s programs to the parents of school-age children in advertising that included a television infomercial featuring quiz show host Alex Trebek.

The settlement order prohibits WordSmart and David A. Kay from misrepresenting the benefits of educational goods or services, and from violating the agency’s Telemarketing Sales Rule (TSR).

The FTC’s complaint alleges that the defendants targeted parents who wanted to improve their children’s performance in school or help them prepare for standardized tests, such as the SAT or ACT. They sold the programs via telemarketing and their website, charging between $15 and $300 for each program.

The defendants’ allegedly false and unsubstantiated claims included that, by using WordSmart for a total of 20 hours, students were guaranteed to improve letter grades by at least one GPA point, SAT scores by at least 200 points, ACT scores by at least four points, GRE and GMAT scores by at least 100 points, and IQ scores. They also falsely claimed they would provide a full refund within 30 days if the buyer was not satisfied.

In addition, the defendants allegedly repeatedly called consumers whose phone numbers are listed on the National Do Not Call Registry, refused to honor requests to stop calling, and failed to connect a consumer to a sales representative within two seconds after a consumer answered the phone, as required by the TSR.

The stipulated final order prohibits the defendants from misrepresenting the benefits, performance, or efficacy of their educational goods or services, including claims that the products will help students learn faster, improve reading speed, or increase grades, IQ scores, or test scores. It also bars them from misrepresenting the terms of their refund policy and violating the TSR’s Do Not Call rules.

The order imposes a $18.7 million judgment that will be suspended when the defendants have paid $147,400. The full judgment will become due immediately if they are found to have misrepresented their financial condition.

The Commission vote authorizing the staff to file the complaint and proposed stipulated final order was 5-0. The order was entered by the U.S. District Court for the Southern District of California on October 7, 2014.

The Federal Trade Commission works for consumers to prevent fraudulent, deceptive, and unfair business practices and to provide information to help spot, stop, and avoid them. To file a complaint in English or Spanish, visit the FTC’s online Complaint Assistant or call 1-877-FTC-HELP (1-877-382-4357). The FTC enters complaints into Consumer Sentinel, a secure, online database available to more than 2,000 civil and criminal law enforcement agencies in the U.S. and abroad. The FTC’s website provides free information on a variety of consumer topics. Like the FTC on Facebook, follow us on Twitter, and subscribe to press releases for the latest FTC news and resources.

Federal Trade Commission, Consumer Financial Protection Bureau Announce Speakers for “Debt Collection & the Latino Community” Roundtable

The Federal Trade Commission and the Consumer Financial Protection Bureau have announced the list of speakers, panelists, and moderators for the roundtable the agencies will co-host in Long Beach, California, on October 23, 2014.

The event, which also will be webcast, is titled “Debt Collection & the Latino Community.” Participants will examine how debt collection and credit reporting issues affect Latino consumers, especially those who have limited English proficiency (LEP). The roundtable will bring together consumer advocates, industry representatives, state and federal regulators, and academics to exchange information on a range of issues.

The following is a list of the day’s events and speakers. Note that all times are Pacific Standard Time.

8:00-9:00 a.m.	Registration
9:00-9:30 a.m.	Welcome and Opening Remarks Ricardo Lara, California State Senator Edith Ramirez, Chairwoman, FTC Zixta Martinez, Associate Director for External Affairs, CFPB
9:30-10:25 a.m.	Presentation: Debt Collection & the Latino Community Marisabel Torres, Policy Analyst, National Council of La Raza
10:25-10:35 a.m.	Break
10:35 a.m.-12:05 p.m.	Panel 1: Pre-Litigation Debt Collection from Latino Consumers This session will address topics including how some Latinos experience the debt collection process and industry practices for collecting debts from LEP Latinos. Moderator: Maricela Segura, Western Region, FTC Panelists: Albert Cadena, President & CEO, USCB America, Inc. Bernard Eskandari, Deputy Attorney General, Consumer Law Section, California Office of the Attorney General Mark Naiman, Chief Operating Officer, Absolute Resolutions Corp. Karla Priego, Area Manager, Budget and Credit Department, ClearPoint Credit Counseling Solutions Rigoberto Reyes, Chief, Investigations, County of Los Angeles Department of Consumer Affairs Alysson Snow, Supervising Attorney, Legal Aid Society of San Diego, Inc.
12:05-1:05 p.m.	Lunch
1:05-2:30 p.m.	Panel 2: The Experience of LEP Latinos in Debt Collection Litigation This session will consider topics such as access to justice in court for LEP Latinos sued by debt collectors, the incidence of debt collection litigation involving Latino consumers, and debt collection litigation methods involving LEP Latino consumers. Moderator: Thomas Pahl, Managing Counsel, Office of Regulations, CFPB Panelists: Jose Alarcon, Staff Attorney, Bet Tzedek Joseph Jaramillo, Senior Attorney, Housing and Economic Rights Advocates Ted Mermin, Executive Director, Public Good Law Center Makyla Moody, Attorney, Wakefield & Associates Harvey Moore, President, The Moore Law Group
2:30-3:30 p.m.	Panel 3: Credit Reporting Issues Among LEP Latinos This session will address topics such as LEP Latino consumers’ access to credit reports, their options for disputing inaccurate information, and some of the potential barriers in the credit reporting marketplace for these consumers. Moderator: Brenda Muñiz, Senior Advisor, CFPB Panelists: Eric Ellman, Senior Vice President of Public Policy and Legal Affairs, Consumer Data Industry Association Sahara Garcia, HomeOwnership Counselor/Education Advisor, NeighborWorks Orange County Aracely Panameño, Director, Latino Affairs, Center for Responsible Lending Mary Spector, Associate Professor of Law and Co-Director of the SMU Dedman School of Law Civil Clinic
3:30-3:45 p.m.	Break
3:45-4:45 p.m.	Panel 4: Developing Improved Strategies for Educating and Engaging LEP Latinos About Their Debt Collection Rights This session will address topics including what education materials on debt collection exist for Latinos, and how the FTC, CFPB, consumer advocates, and debt collectors can help ensure LEP Latinos have access to the information they need about their debt collection and credit reporting rights. Moderator: Cristina Miranda, Consumer Education Specialist, Division of Consumer and Business Education, FTC Panelists: Robert Foehl, Vice President and General Counsel, ACA International Andrea Luquetta, Policy Advocate, California Reinvestment Coalition Suzanne Martindale, Staff Attorney, Consumers Union Maritza Reyna, Manager of Education, Consumer Credit Counseling Service of Orange County
4:45-5:00 p.m.	Lessons Learned and Next Steps Gail Hillebrand, Associate Director of Consumer Education and Engagement, CFPB Christopher Koegel, Assistant Director, Division of Financial Practices, FTC

The roundtable is free and open to the public. It will be held at California State University, Long Beach, in the Grand Ballroom at the University Student Union. It will not be held at The Pointe, as originally planned. The address for the University is 1250 Bellflower Boulevard, Long Beach, California, 90840. Directions to the Grand Ballroom are available on the roundtable event page.

Additional information, including pre-registration and the agenda, is posted on the event page, www.ftc.gov/LatinoDebtCollection. To register for the event, please send your name, affiliation, and email address to [email protected].

To view the webcast of the roundtable, go to www.ftc.gov on the day of the event, October 23, and you will see a link to the webcast. There is no need to register to watch the webcast.

Send your ideas and comments regarding the roundtable event to the following email address: [email protected] or [email protected].

FTC Chairwoman Edith Ramirez to Join FCC Chairman Tom Wheeler and State Attorneys General to Announce Major Enforcement Action

WHAT:    Press conference followed by press question-and-answer session. WHO: Edith Ramirez, Chairwoman, Federal Trade Commission
Tom Wheeler, Chairman, Federal Communications Commission
Bill Sorrell, Attorney General, State of Vermont
Doug Gansler, Attorney General, State of Maryland
Jessica L. Rich, Director, Bureau of Consumer Protection, Federal Trade Commission
Travis LeBlanc, Enforcement Bureau Chief, Federal Communications Commission WHEN: Wednesday, Oct. 8, 2014
12 p.m. ET WHERE: Press Briefing Room, Wilson Building
1350 Pennsylvania Avenue, NW – Room G-9
Washington, DC 20004          PRESS: Cameras are advised to arrive at 11:15 a.m. for set-up.
For more information, contact the FTC’s Office of Public Affairs at 202-326-2180 WEBCAST: The event will be broadcast live online. DIAL-IN: Reporters interested in dialing into the press conference in listen-only mode may dial (800) 230-1093 and use passcode 338936.

AT&T to Pay $80 Million to FTC for Consumer Refunds in Mobile Cramming Case

As part of a $105 million settlement with federal and state law enforcement officials, AT&T Mobility LLC will pay $80 million to the Federal Trade Commission to provide refunds to consumers the company unlawfully billed for unauthorized third-party charges, a practice known as mobile cramming. The refunds are part of a multi-agency settlement that also includes $20 million in penalties and fees paid to 50 states and the District of Columbia, as well as a $5 million penalty to the Federal Communications Commission.

In its complaint against AT&T, the FTC alleges that AT&T billed its customers for hundreds of millions of dollars in charges originated by other companies, usually in amounts of $9.99 per month, for subscriptions for ringtones and text messages containing love tips, horoscopes, and “fun facts.” In its complaint, the FTC alleges that AT&T kept at least 35 percent of the charges it imposed on its customers.

“I am very pleased that this settlement will put tens of millions of dollars back in the pockets of consumers harmed by AT&T’s cramming of its mobile customers,” said FTC Chairwoman Edith Ramirez. “This case underscores the important fact that basic consumer protections – including that consumers should not be billed for charges they did not authorize – are fully applicable in the mobile environment.”

Beginning today, consumers who believe they were charged by AT&T without their authorization can visit www.ftc.gov/att to submit a refund claim and find out more about the FTC’s refund program under the settlement. If consumers are unsure about whether they are eligible for a refund, they can visit the claims website or contact the settlement administrator at 1-877-819-9692 for more information.

This case is part of a larger FTC effort to clamp down on mobile cramming. This is the FTC’s seventh mobile cramming case since 2013, and its second against a mobile phone carrier this year. The FTC filed a complaint against T-Mobile in July, and that case is ongoing. The Commission also issued a staff report on mobile cramming in July. The FTC mobile cramming cases build on the FTC’s extensive law enforcement work over the last decade to combat cramming on landline phone bills.

The FTC’s investigation into AT&T showed that the company received very high volumes of consumer complaints related to the unauthorized third-party charges placed on consumer’s phone bills. For some third-party content providers, complaints reached as high as 40 percent of subscriptions charged to AT&T consumers in a given month. In 2011 alone, the FTC’s complaint states, AT&T received more than 1.3 million calls to its customer service department about the charges.

According to the complaint, in October 2011, AT&T altered its refund policy so that customer service representatives could only offer to refund two months’ worth of charges to consumers who sought a refund, no matter how long the company had been billing customers for the unauthorized charges. Prior to that time, AT&T had offered refunds of up to three months’ worth of charges. At that time, AT&T characterized its change in policy as designed to “help lower refunds.”

In February 2012, one AT&T employee said in an e-mail that “Cramming/Spamming has increased to a new level that cannot be tolerated from an AT&T or industry perspective,” but according to the complaint, the company did not act to determine whether third parties had in fact gotten authorization from consumers for the charges placed on their bills. In fact, the company denied refunds to many consumers, and in other cases referred the consumers to third-parties to seek refunds for the money consumers paid to AT&T.

An actual AT&T mobile bill. Page 1 contains a Bill-At-A-Glance section, followed by a Service Summary that includes unauthorized charges for trivia text alerts. Later in the bill, it’s still cryptic. Third party charges show up under an ‘AT&T’ heading, AT&T Monthly Subscriptions. The details say nothing about trivia texts.

Excerpts from an actual AT&T bill showing cramming charges. (click to view full-size)

The structure of AT&T’s consumer bills compounded the problem of the unauthorized charges, according to the complaint, by making it very difficult for customers to know that third-party charges were being placed on their bills. On both the first page of printed bills and the summary of bills viewed online, consumers saw only a total amount due and due date with no indication the amount included charges placed on their bill by a third party. The complaint alleges that within online and printed bills, the fees were listed as “AT&T Monthly Subscriptions,” leaving consumers to believe the charges were part of services provided by AT&T.

Under the terms of its settlement with the FTC, AT&T must notify all of its current customers who were billed for unauthorized third-party charges of the settlement and the refund program by text message, e-mail, paper bill insert and notification on an online bill. Former customers may be contacted by the FTC’s refund administrator.

In addition to the refund requirements, AT&T is also required to obtain consumers’ express, informed consent before placing any third-party charges on a consumer’s mobile phone bill. In addition, the company must clearly indicate any third-party charges on the consumers’ bill and provide consumers with the option to block third-party charges from being placed on their bill.

The Commission vote authorizing the staff to file the complaint and approving the proposed stipulated order was 5-0. The FTC filed the complaint and proposed stipulated order in the U.S. District Court for the Northern District of Georgia. The proposed stipulated order is subject to court approval.

NOTE: The Commission files a complaint when it has “reason to believe” that the law has been or is being violated and it appears to the Commission that a proceeding is in the public interest. Stipulated orders have the force of law when approved and signed by the District Court judge.

Sweepstakes Scammer Banned from Prize Promotion Industry

A sweepstakes operator that took millions of dollars from consumers throughout the United States and dozens of other countries, including Canada, the United Kingdom, France and Japan, is banned from the prize promotion business under a settlement with the Federal Trade Commission.

According to the FTC, consumers received personalized mail that falsely claimed they had won a cash prize, typically more than $2 million, and that to collect it they had to pay a fee, usually from $20 to $30. Those who paid got nothing of value in return. The vast majority of the victims appeared to be seniors over the age of 65.

Last year, the FTC charged Universal Information Services defendants with violating federal law in connection with their deceptive prize promotion letters. The court subsequently halted the operation, froze the defendants’ assets, and appointed a receiver over the corporate defendants pending resolution of the case.

The defendants are Liam O. Moran of Ventura, California, and his companies, Applied Marketing Sciences LLC; Standard Registration Corporation, also doing business as Consolidated Research Authority and CRA; and Worldwide Information Systems Incorporated, also d/b/a Specific Monitoring Service, SMS, Specific Reporting Service, SRS, Universal Information Services, UIS, Compendium Sampler Services, and CSS.

Under the settlement order, in addition to being banned from any conduct involving prize promotions, the defendants are permanently prohibited from misrepresenting any good or service, selling or otherwise benefitting from consumers’ personal information, and failing to properly dispose of customer information. The order imposes a judgment of more than $11 million, which represents the amount of money consumers lost. The judgment will be suspended when Moran turns over the proceeds of the sale of his home. The full judgment will become due immediately if the defendants are found to have misrepresented their financial condition.

The FTC would like to thank the United States Postal Inspection Service, Los Angeles Division, the Vancouver Police Department, the Metropolitan Police in the United Kingdom, the National Fraud Intelligence Bureau, and the Australian Competition & Consumer Commission for their assistance in this case.

The Commission vote authorizing the staff to file the proposed stipulated order was 5-0. The order was entered by the U.S. District Court for the Central District of California on October 3, 2014.

NOTE: Stipulated orders have the force of law when signed by the District Court judge.

To learn how to avoid these kinds of scams, read the FTC’s Prize Scams.

FTC Extends Deadline for Submitting Public Comments on Review of the Telemarketing Sales Rule Through November 13, 2014

The Federal Trade Commission has extended the deadline for consumers to submit comments regarding the agency’s Telemarketing Sales Rule (TSR) through November 13, 2014. On July 31, 2014, the FTC announced that it had begun a review of the TSR, as part of its systematic review of the Commission’s rules and regulations.

As detailed in the Federal Register notice announcing the rule review, the TSR has been updated regularly since 2000, leading to amendments in 2003 to create the national Do Not Call (DNC) Registry for telemarketers, as well as in 2008 and 2010, when the rule was amended to more specifically address pre-recorded telemarketing calls and debt relief services, respectively. In addition, last year, the Commission proposed amendments to the TSR to ban telemarketers from using certain payment methods often used in defrauding consumers.

The Commission’s notice requesting public comment posed an extensive list of questions on the costs, benefits and efficacy of the TSR in the marketplace, and whether the FTC should retain, modify, or rescind it. The Commission also specifically requested comment on three issues: 1) whether the pre-acquired account information provisions of the TSR should be modified in view of current credit card association rules and the Restore Online Shoppers’ Confidence Act, 15 U.S.C. 8401 (2010); 2) what impact, if any, the increasing use of general media to solicit inbound calls from consumers to purchase a variety of goods or services, including those involving a negative option or free trial, is having; and 3) the costs and burdens of modifying the recordkeeping requirements of the TSR to require telemarketers to retain their own call records. The regulatory review comment period was to end on October 14, 2014.

The Commission vote approving the Federal Register notice announcing the extension of the public comment period was 5-0. (FTC File No. R411001; the staff contact is Craig Tregillus, Bureau of Consumer Protection, 202-326-2970) Comments can be submitted electronically. Information about how to submit written comments can be found in the Request for Comments section of the Supplementary Information in the Federal Register notice.

Proposed FinCEN Rule Should Help FTC Track Down Perpetrators of Fraud

Federal Trade Commission staff filed a comment on a Notice of Proposed Rulemaking published by the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury, in which FinCEN proposed a rule to clarify and strengthen existing customer due diligence requirements for financial institutions under the Bank Secrecy Act. Among other requirements, the proposed Customer Due Diligence Rule would require financial institutions to collect information on the individuals who are the beneficial owners of a legal entity when the entity opens an account.

The comment of the FTC’s Bureau of Consumer Protection and Bureau of Economics notes that the proposed Rule should improve the FTC’s ability to track down those perpetrating fraud against consumers. FTC staff provided examples from FTC enforcement actions in which individuals used legal entities or “shell” companies to disguise their involvement with fraudulent operations and transfer the proceeds of fraud – instances in which information about the individuals behind a legal entity would have helped the FTC’s law enforcement, including its efforts to quickly shut down fraudulent operations.

The Commission vote to issue the staff comment was 5-0. It was sent to FinCEN Director Jennifer Shasky Calvery on October 3, 2014. (FTC File No. P124402; the staff contact is Karen S. Hobbs, Bureau of Consumer Protection, 202-326-3587).

FTC Approves Modified Consent Order for Graco Inc.

The Federal Trade Commission has approved a modified final order settling charges that equipment manufacturer Graco Inc.’s $650 million acquisition of certain finishing equipment businesses of Illinois Tool Works was anticompetitive.

Under the proposed settlement reached in 2012, the Commission allowed Graco to complete its acquisition but required it to hold separate several ITW businesses until those assets are divested. After the end of the public comment period, additional information led the Commission to require Graco to agree to certain modifications to the proposed consent order.

The Commission has now issued its modified final order, adding provisions that address two issues:

an existing supply agreement for disposable paint cups and lids, which, if terminated, could have undermined the effectiveness of the divestiture in preserving competition in the market relating to the manufacture and sale of industrial liquid finishing equipment; and
the allocation of intellectual property assets for certain powder finishing products.

The Commission vote to approve the modified final order was 2-0-1-2, with Chairwoman Edith Ramirez and Commissioner Julie Brill voting yes, Commissioner Maureen K. Ohlhausen abstaining, and Commissioners Joshua D. Wright and Terrell McSweeny not participating. (FTC File No. 111-0169; Docket No. 9350; the staff contacts are Peter Richman, Bureau of Competition, 202-326-2563; and Elizabeth Piotrowski, Bureau of Competition, 202-326-2623.)

The FTC’s Bureau of Competition works with the Bureau of Economics to investigate alleged anticompetitive business practices and, when appropriate, recommends that the Commission take law enforcement action. To inform the Bureau about particular business practices, call 202-326-3300, send an e-mail to antitrust{at}ftc{dot}gov, or write to the Office of Policy and Coordination, Bureau of Competition, Federal Trade Commission, 600 Pennsylvania Ave., NW, Room CC-5422, Washington, DC 20580. To learn more about the Bureau of Competition, read Competition Counts. Like the FTC on Facebook, follow us on Twitter, and subscribe to press releases for the latest FTC news and resources.

FTC Halts Fake Medicare Scheme that Took Money from Seniors’ Bank Accounts

At the Federal Trade Commission’s request, a federal court halted a telemarketing scheme that tricked senior citizens by pretending to be part of Medicare, and took millions of dollars from consumers’ bank accounts without their consent. As part of its ongoing work to protect every community from fraud, the FTC seeks to permanently end the operation and return victims’ money.

According to a complaint filed by the FTC, the defendants called consumers – including many whose numbers were listed on the National Do Not Call Registry – and said they were providing a new Medicare card or information about Medicare benefits.

The defendants allegedly misrepresented that they were working on behalf of Medicare, and said they needed to verify consumers’ identities using personal information that included their bank account numbers. The defendants allegedly assured consumers that the information would not be used to debit their bank accounts, and that there was no charge for the new Medicare card or information about Medicare benefits.

However, within a few weeks, consumers learned their bank accounts had been debited either $399 or $448 via remotely created checks (RCCs), the complaint alleges. Despite these charges, consumers did not receive any kind of product or service from the defendants. In some instances, the defendants debited the accounts of consumers they had not even contacted.

The FTC charged the defendants with violating the FTC Act and the FTC’s Telemarketing Sales Rule. The defendants are Sun Bright Ventures LLC, Citadel ID Pro LLC, and Benjamin Todd Workman. The FTC named Trident Consulting Partners LLC and Glenn Erickson as relief defendants who profited from the scheme.

The Commission vote authorizing the staff to file the complaint was 5-0. The FTC filed the complaint, under seal, in the U.S. District Court for the Middle District of Florida. On September 4, 2014, the court entered a temporary restraining order halting the defendants’ deceptive scheme and freezing the defendants’ and relief defendants’ assets. The defendants and relief defendants agreed to preliminary injunctions, which the court entered on September 18, 2014. The preliminary injunctions continue the conduct prohibitions and asset freezes set forth in the temporary restraining order.

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