Mapping an FTC Refund Program
Success in getting refunds to people depends principally on whether the FTC has a reliable list of customers,
including their contact information and the amount of money they spent. Usually, the FTC has this
information, and it mails checks out to a list of known customers. In some cases, there is no list of known
customers or there is insufficient contact information, and the agency must use a claims process to identify
people who should receive a refund. There are at least six steps involved in every refund program:
1. Identify who is eligible for a refund.
2. Determine how the money will be divided.
3. Mail checks.
4. Update names and addresses as needed.
5. Consider whether an additional check mailing is feasible.
6. Send any remaining money to the U.S. Treasury.
Identifying who is eligible for a refund
FTC court orders typically require the company to provide a list of customers, their contact information, and
how much each customer paid. If the agency obtains a reliable list of eligible recipients, then the agency mails
checks directly to them. This year, in cases where the FTC used company data to mail checks, an average of
64% of people on the list got a check and cashed it.
Without a list of customers with contact information, getting refunds out may require a claims process. In such
cases, the people affected must apply for a refund. The agency might conduct a media campaign and use paid
advertisements to let people know that refund money is available and encourage them to visit our website to
apply. In other cases, the agency uses whatever minimal data is available, such as a consumer’s email address,
to tell consumers about the refund process. A claims process typically increases the administrative costs of the
refund program. Generally, the FTC gets claims from 5 to 20 percent of potential claimants. In cases where
there was a claims process, the average check cashing rate was 90%.
If there is no customer list and a claims process is not feasible, the agency’s Consumer Sentinel Database may
be used to find eligible recipients. Consumer Sentinel contains millions of complaints from people who
contacted the FTC, the Better Business Bureau, or other federal, state and local law enforcement offices. The
FTC may search for complaints related to the defendants and use the contact information in those complaints
to create a list of potential refund recipients. This year, the agency used Consumer Sentinel data to send
refunds in five FTC matters: Money Now Funding, Payday Support, Regency Financial, Information
Management Forum, and Vantage Funding. In cases where data from Consumer Sentinel was used to mail
refunds, the average check cashing rate was 70%.
Determining how the money will be divided
In cases where the court order does not specify the parameters of the refund program, the FTC determines
eligibility criteria and the formula for calculating payments to eligible recipients. In cases where the settlement
fund is not large enough to provide full refunds to every customer, the FTC analyzes the data to determine
how much individuals will receive. Key factors that influence these decisions include administrative costs, the
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