The FTC’s Law Enforcement Cases

The five complaints announced today were filed against the following companies and their principals: 1) Treasure Your Success, 2) Ambrosia Web Design, 3) A+ Financial Center, LLC, 4) The Green Savers, and 5) Key One Solutions, LLC. Each complaint alleges, among other things, that the defendants violated the FTC Act by misrepresenting that consumers who buy their services:

will have their credit card interest rates reduced substantially; and
will save thousands of dollars as a result of lowered credit card interest rates.
Four of the five complaints announced today also charge that the defendants violated the FTC Act by making other misrepresentations, such as claiming that consumers who buy their services will be able to pay off their debts much faster as a result of lowered credit card interest rates and making false claims about their refund policies.

The complaints also charge the defendants with multiple violations of the Telemarketing Sales Rule (TSR), for misrepresenting their services, calling numbers on the Do Not Call Registry, and collecting up-front fees. The TSR also specifically prohibits charging or receiving a fee in advance of providing debt relief services and misrepresenting the terms and conditions of debt relief services.

Finally, the complaints charge that the defendants are responsible for making illegal robocalls, in violation of the TSR. Nearly all pre-recorded telemarketing calls have been prohibited since September 1, 2009. In the FTC’s experience, companies such as these often hire others to make calls on their behalf. The FTC alleges in each case that the defendants themselves are legally responsible for making the robocalls.

The Commission votes authorizing the staff to file each complaint were 5-0. The complaints were filed in the U.S. district courts listed below. In filing the complaints, the FTC seeks to permanently stop the defendants’ allegedly illegal conduct. In each case, the court granted the FTC’s request for a temporary restraining order, which halts the operations pending further court proceedings.

The case against Treasure Your Success was filed in the U.S. District Court for the Middle District of Florida against the following defendants: WV Universal Management, LLC, also doing business as Treasure Your Success; Global Financial Assist, LLC; Leading Production, LLC; Willy Plancher, individually and as a member of WV Universal Management, LLC; and Valbona Toska, individually and as a member of WV Universal Management, LLC.

The case against Ambrosia Web Design was filed in the U.S. District Court for the District of Arizona against the following defendants: Ambrosia Web Design LLC, also doing business as AWD; Concord Financial Advisors LLC; CAM Services Direct LLC; AFB LLC; Western GPS LLC; Chris Ambrosia, individually and as a manager of Ambrosia Web Design LLC, AFB LLC, and CAM Services Direct LLC; and LeRoy Castine, a/k/a Lee Castine, individually and as a manager of Ambrosia Web Design LLC, Concord Financial Advisors LLC, AFB LLC, and Western GPS LLC.

The case against A+ Financial Center, LLC was filed in the U.S. District Court for the Southern District of Florida against the following defendants: A+ Financial Center, LLC, also doing business as Accelerated Financial Centers, LLC; Accelerated Accounting Services LLC; Christopher L. Miano, individually and as the managing member of Accelerated Accounting Services LLC; and Dana M. Miano, individually and as the managing member of A+ Financial Center, LLC.

The case against The Green Savers, LLC was filed in the U.S. District Court for the Middle District of Florida against the following defendants: The Greens Savers, LLC, also doing business as Elite Services and Advanced Data Solutions; Christopher Adams, individually and as a member of The Green Savers, LLC; and Vikash Jawalapersad, also d/b/a Pavac, Inc., individually and as a member of The Green Savers, LLC.

The case against Key One Solutions, LLC was filed in the U.S. District Court for the District of Arizona against the following defendants: ELH Consulting, LLC, also doing business as Proactive Planning Solutions; Purchase Power Solutions, LLC; Allied Corporate Connection, LLC; Complete Financial Strategies, LLC; 3Point14 Consulting, LLC, also d/b/a Elite Planning Group; Key Tech Software Solutions, LLC, also d/b/a Key One Solutions; Emory L. Holley IV, a/k/a Jack Holley, individually and as the sole member of ELH Consulting, LLC; Lisa Miller, individually and as the sole member of Allied Corporate Connection, LLC, Complete Financial Strategies, LLC, and Purchase Power Solutions, LLC; Rares Stelea, individually and as the sole member of 3Point14 Consulting, LLC; and Justin Journay, individually and as the sole member of Key Tech Software Solutions, LLC.

Civil action by the FTC against such criminals is totally ineffective. All of those involved know that they are violating FTC regulations. The FTC prohibits unsolicited calls for any kind of debt / interest rate reductions which require up front fees, period, and that is what these robo calls are about. The FTC civil actions have been nothing more than whack-a-mole interference. Which is why numerous individuals are the subject of repeated actions, despite signing prior agreements that prohibit future involvement. The FTC levies huge fines, then rescinds them based on inability to pay. The FTC settles for the minimal cash on hand, and enjoins them from future "telemarketing". The criminals sign off, then go right back to business. The entire operations are clearly criminal, intent to defraud, etc, and should be dealt with in criminal court and not by civil actions.