Specifically, the improper sales practices included:
- Misleading statements that the debt protection product would cancel the consumers' entire minimum payment, when in reality the benefit was capped at $500.
- Erroneously indicating that the debt protection benefit periods were up to 24 months when only 2 of 13 benefits had 24 month periods and the majority of benefits had benefit period of 1 to 3 months.
- Claiming that there would be no fee for the debt protection product if the balance in the account was paid off every month, without disclosing that the account balance had to be paid off before the end of the billing cycle.
- Conducting telemarketing in Spanish yet providing written terms and conditions in English.
- Billing consumers for credit report monitoring when the company did not actually monitor all of the consumers' credit reports.
- Unfairly charging consumers for interest and fees.
- Failing to inform consumers about their right to a free credit report.