Citizens Disability, LLC and its subsidiary will pay a $1 million penalty to resolve Federal Trade Commission allegations that they made tens of millions of illegal calls to consumers nationwide, including to numbers on the Do Not Call Registry.
The Massachusetts-based company, which assists consumers in applying for Social Security Disability Insurance benefits, allegedly violated federal telemarketing rules through a sophisticated scheme that collected consumer information through deceptive websites and used that data to make illegal sales calls.
"Consumers often wonder how telemarketers get their phone numbers, even if they're on the Do Not Call Registry," said Christopher Mufarrige, Director of the FTC's Bureau of Consumer Protection. "In this case, Citizens Disability used websites offering prizes, coupons, and other services to collect consumers' personal information and then used that information to make tens of millions of illegal sales calls. The FTC will not tolerate such deceptive conduct."
According to the complaint filed by the Department of Justice upon notification and referral from the FTC, Citizens Disability and its subsidiary CD Media made more than 109 million outbound telemarketing calls between January 2019 and July 2022. Of those calls, more than 25.7 million were made to numbers listed on the Do Not Call Registry, violating federal protections designed to shield consumers from unwanted solicitations.
The FTC alleged that the companies' actions violated both the Telemarketing Sales Rule and the FTC Act through their use of illegal robocalls and calls to protected numbers.
The complaint details how Citizens Disability operated its telemarketing scheme through third-party lead generators and call centers. The companies contracted with lead generators to obtain lists of consumers for their telemarketers to contact. These lists were created through websites that deceptively induced consumers to provide their personal information through attractive sweepstakes, coupons, and service offers.
Crucially, these websites failed to disclose that consumers' personal contact information would be used for telemarketing calls, leaving consumers unaware that signing up for prizes or coupons would result in unwanted sales calls about disability benefits.
The complaint further alleges that Citizens Disability targeted vulnerable populations, including many lower-income and disabled consumers, with false representations about the nature of their calls. The company allegedly told consumers that they were calling in response to inquiries about SSDI benefits, even when consumers had made no such inquiries.
Some of these deceptive calls were made through robocalls that identified the caller as "Amber" or "Audrey," with scripts stating that "it show[s] here that you recently inquired about your eligibility for Social Security Disability benefits." This misrepresentation was designed to make consumers believe they had previously expressed interest in the company's services when they had not.
The case highlights ongoing concerns about telemarketing abuse in industries that serve vulnerable populations. Social Security Disability applicants often face financial hardship and may be particularly susceptible to misleading claims about assistance with their benefits applications.
The settlement includes a proposed consent order that will impose restrictions on Citizens Disability's future telemarketing practices. While specific details of the order were not fully provided in the announcement, such agreements typically include prohibitions on the deceptive practices alleged in the complaint and requirements for compliance monitoring.
The $1 million penalty reflects the FTC's continued focus on enforcing telemarketing rules, particularly violations of the Do Not Call Registry protections. The registry, established to give consumers control over the marketing calls they receive, covers more than 245 million phone numbers nationwide.
This enforcement action demonstrates the FTC's commitment to protecting consumers from illegal telemarketing practices, especially those that target vulnerable populations. The agency has made telemarketing enforcement a priority, recognizing that illegal robocalls and unwanted sales calls remain one of consumers' top complaints.
For consumers, the case serves as a reminder to be cautious when providing personal information on websites, particularly those offering prizes, sweepstakes, or free services. Reading privacy policies and terms of service can help consumers understand how their information may be used for marketing purposes.
The settlement also underscores the importance of the Do Not Call Registry as a consumer protection tool. Consumers who receive unwanted telemarketing calls, especially to numbers registered on the Do Not Call list, can file complaints with the FTC to help the agency identify and investigate potential violations.
The case against Citizens Disability represents part of the FTC's broader effort to combat illegal telemarketing practices and protect consumers from deceptive business practices in the disability services industry.