Monday, May 21, 2007

Educational Research Center of America, the Student Marketing Group, the College Bound Selection Service and the National Honor Roll: a web of deceit

Nelnet is also a recipient of the Seal of Approval. Never mind that Nelnet is also a company that is under investigation from Congress and being sued by the New York Attorney General for deceptive lending practices, including operating call centers for colleges without stating that they are Nelnet employees who only give out information on Nelnet loans (see 1) below).

Nelnet is also, since 2005, are owners of the Student Marketing Group and the National Honor Roll.

http://digital50.com/news/items/PR/2005/04/01/NYF149/student-marketing-group-and-national-honor-roll-announce-acquisition-by-nelnet.html

The Student Marketing Group gets student names from the Educational Research of America, a group that, like NRCCUA, sends surveys to high school teachers and counselors and also was a party to lawsuits and settlements from the NY Attorney General's Office as well as the Federal Trade Commission. "... named in the settlement were Lynbrook, NY-based SMG president Jan Stumacher and ECRA principal, Marian Sanjana."

http://www.ftc.gov/opa/2003/01/ecra.shtm

http://www.ftc.gov/os/2003/05/ERCAcomplaint.pdf



These organizations similarly use their organizations to gain access to student names through "research" surveys, then in turn sell their information to commercial marketers and other than less savory groups.

One such group is the National Honor Roll, which pretends to be a separate entity from SMG, is actually intimately related to it and, similar to NRCCUA’s relationship to Who's Who, and provides the names to this scam organization. (see 2) below)

SMG also uses front organizations to hide its affiliations. One is the College Bound Selection Service, owned by SMG. Nowhere on the web site for CBSS do they note their affiliation with SMG but they do note that their president, Mr. Barone (no first name) was a former admissions director at Mt. Ida College and "has presented at National Association of College Admissions Counselors conferences and conducted regional seminars on "The Utilization of Direct Mail In Student Recruitment"
http://www.cbssearch.net/cbss_leadership.htm

Nelnet also owns Peterson's, a fellow recipient on the NACAC Seal of Approval and the sponsor of a past NACAC Conference Social (though they do not appear to have the legal and ethical problems of Nelnet's other subsidiaries).

1) From the Chronicle of Higher Education in March of this year: Mr. Cuomo began his investigation last November, when he sent letters to four lenders: EduCap Inc.; Education Finance Partners; the National Education Loan Network, also known as NelNet; and Sallie Mae...The New York attorney general's office later issued a statement saying its investigation of Nelnet had not ended...Nelnet did not agree to give up contracts that allow the company's representatives to answer customer-service calls to colleges' financial-aid offices...

Nelnet Staffs State Non-Profit Counseling Center

In addition to operating call centers at colleges, one student loan company helps staff a state non-profit college counseling center, according to the Chronicle of Higher Education. The College Planning Center of Rhode Island claims to offer free, independent advice on attending college. But the center’s employees work for a subsidiary of Nelnet and do not disclose their affiliation when answering questions on student loans. In fact, students who ask about loans are only given information about Nelnet loans (offered through the state’s student loan authority). Nelnet operates call centers at seven colleges, but had not yet disclosed its partnership with the counseling center in Rhode Island. Nelnet’s voluntary, self-made code of conduct agreement with the Nebraska Attorney General does not include ending its calling centers, in contrast to the code of conduct developed by New York

Attorney General Andrew Cuomo.

2) From College Confidential: Let me share with you what I know about the National Honor Roll. The National Honor Roll is a scam organization. They are targeting high school students all across the nation. Last year my daughter received notification. Don't be fooled. Their letterhead is fancy, and they even claim to be located at a prestigious Pennsylvania Avenue address in Washington, DC . The address they use is 2020 Pennsylvania Avenue. However, that is the address for Mail Boxes Etc. If you have any doubts, go to the Mail Boxes, Etc. web site at http://www.mbe.com/ and click on the icon "locate a store globally." The icon is in the upper right hand corner of their web page. I contacted the Mail Boxes, Etc. store in Washington, DC . Here is the full address and telephone number: 2020 Pennsylvania Ave NW Washington, DC 20006-1811 - USA , phone (202) 457-8166. National Honor Roll claims to be in Suite 8000 . There isn't a Suite number at 2020 Pennsylvania Avenue. The number 8000 stands for the mailbox number for National Honor Roll. A courier picks up mail from this mailbox. It could be a different courier every day. The phone number for "National Honor Roll" is (202)737-0715. It re-routes callers to a New York telephone number. The address in New York is 300 Merrick Road, Suite 206 , Lynbrook , NY 11563 . The phone number is 516-593-0555. This is the same address for Student Marketing Group. The state of New York filed a petition against StudentMarketing Group on July 8, 2002. Please see the .pdf file at http://ww.epic.org/privacy/student/smgpetition.pdf Student Marketing Group collects information on students and sells lists. Unsuspecting teachers pass out information to students. The students do not know their personal information is being fed back to National Honor Roll and Student Marketing Group. You see, the teachers are also being sucked into this scam. The bottom line is that National Honor Roll is a vanity press. A vanity press means anyone can publish anything for a fee. Colleges throw away stuff sent to them from the National Honor Roll because it is considered unsolicited junk. They claim your name and profile can be published free in the book, but why would you want them to do this? You do not want to have your personal information on the streets. Call them right away and have your name taken off their list. And while you are at it, ask them why they are scamming the American people. I encourage all to file a mail fraud complaint against the National Honor Roll. Postal Inspectors base mail fraud investigations on the number, substance and pattern of complaints received from the public. Here is the URL to the Postal Inspector's web page https://www.usps.com/postalinspectors/fraud/welcome.htm In the lower left-hand portion of the screen is the link to 'File a Mail Fraud Complaint' So, how do they get students' personal information? Well, they share the same office and survey information with Student Marketing Group in Lynbrook , New York . But, there is a third element involved in this scheme. Student Marketing Group gets their information from Educational Research Center of America, Inc., otherwise known as ERCA. ERCA is the organization that sends the surveys to teachers all across America . Teachers pass these surveys out to their students. Of course, students think these are "safe" surveys because the teachers are passing them out. Teachers collect the surveys and place them in postage-paid envelopes. They mail them back to 2020 Pennsylvania Avenue, NW , Room 7799, Washington , DC 20006 . Hmmmmmmmmmmm! Does this address sound familiar? Yes! It is the same address as National Honor Roll at Mail Boxes, Etc. on the George Washington University campus. In this case, the 7799 is not a room. It is ERCA's mailbox number. ERCA claims their phone number is (202) 393-7799. The (202) is a Washington , DC area code. E-mail address is info@studentresearch.org I haven't tried the phone number or the e-mail, but I can guess that the phone number re-routes callers to Pittsburgh , Pennsylvania . Please see the Federal Trade Commission report involving Student Marketing Group and Educational Research Center of America at http://www.ftc.gov/os/2003/01/ercaconsent.htm Happy reading! By the way, National Honor Roll claims they give away scholarships. Does anyone know if these scholarships exist? Who receives these scholarships? Does Lynn Romeo, the publisher of National Honor Roll, give these scholarships to her nieces? nephews? herself? Please advise. The people in Lynbrook , New York will tell you that their Headquarters is in Washington , DC . If you ask them anything about the "Headquarters" they will tell you, "well, it is really our processing center." I have talked with Jane, Wendy and Linda in the Lynbrook , NY office. They are all very evasive about the organization. They won't tell you anything about the courier who they hire to pick up the mail. When they get tired of you asking legitimate quesitons, they will transfer you to the voice mail of Lynn Romeo. Of course, Lynn Romeo doesn't return your calls. Let's stop these people. Every educator, librarian, parent, congressman, journalist and anybody else who cares about the safety of our nation's children should be concerned. Please forward this information to everyone you know. Want to learn more? Please visit the Better Business Bureau web site at http://www.dc.bbb.org/report.html?compid=W8000570&national=Y to see the Better Business Bureau Report.

Friday, May 04, 2007

NRCCUA

NRCCUA was subject to a major Federal Trade Commission suit that stated they misrepresented what they did with the data they collected.


http://www.ftc.gov/os/comments/nrccuacomments/

Also (see below) there was an article on the web site of the Transcript, the AACRAO on-line newsletter, that repeated information from a December 3, 2001 article in the Wall Street Journal about NRCCUA. The rebuttal appearing in December 10 on the Transcript web site was written by someone named, you guessed it, Bob McLendon:

http://www.aacrao.org/transcript/index.cfm?fuseaction=show_view&doc_id=551

On October 2, 2002, the NRCCUA agreed to a consent agreement to cease the actions that were listed in the complaint. See

http://www.ftc.gov/opa/2002/10/student1r.shtm for details.

I have gotten packages from NRCCUA that I promply filed in our circular file (i.e. recycling bin) in our office. All our sophomores and juniors take the PSAT (paid for by the district) and they have the option of stating that they want to share their information with colleges through the College Search Service. I see no particular obligation to enrich the College Board, but this seems to work well and there have not been lawsuits against the College Board (or at least FTC complaints) that the College Board is sharing student information to other marketing groups.

School Officials Upset to Learn that Information From High School Survey is Sold to Commercial Marketers

The National Research Center for College and University Admissions, which was started in 1972 to help small midwestern colleges recruit students, collects names, addresses, GPAs, races, religions, and social views in a classroom survey of high school students each year. National Research tells the schools it will distribute names and profiles to colleges and universities across the country. However, as reported in The Wall Street Journal, it does not tell them that it also sells the personal information to American Student List LLC, a leading supplier of names to such commercial marketers as Gillette Co.; American Express Co. and Capital One Financial Corp.; Kaplan Inc.; the Washington Post Co. unit that is an admissions test coaching chain; Primedia Inc.’s Seventeen Magazine; and Columbia House Record Club, owned by AOL Time Warner Inc. and Sony Corp.

School officials believe the information obtained in the survey is available only to educational institutions. The College Board and ACT Inc. also gather information collected from students who take the SAT and ACT tests, respectively—and sell this to colleges; however, they do not sell it to commercial markets.

Many school officials expressed anger when discovering the commercial sales of the information they felt they had been led to believe was sent only to educational institutions. According to The Wall Street Journal, National Research president Don M. Munce explained that the survey has a “privacy statement” that tells students the responses are “used by colleges, universities and other organizations to assist students and their families.” “Other organizations,” in this case, covers the commercial contacts.

A few of the contacts to which American Student List sells are college aid consultants targeted by the Federal Trade Commission since they began to buy the information. For example, Christopher Nwaigwe of Maryland was convicted on federal mail fraud charges in 1999 for offering phony scholarships. College Resource Management Inc. of Texas paid $40,000 this year to settle civil FTC charges it misrepresented its ability to obtain financial aid for students. A third company, College Financial Aid, has received an “unsatisfactory” rating from the Better Business Bureau of upstate New York for the many consumer complaints it has received.

National Research is opposing a bill now before a congressional conference committee, which would require parental consent to collect information from students for commercial purposes. However, a National Research official states that this opposition reflects concern for recruitment and fundraising for high school proms, not for the right to sell to commercial marketers.

E-mail to Liz Farrell of the Chronicle of Higher Education:

Mr. Munce, who you interviewed in the Chronicle on-line, was the subject of a FTC suit and settlement where the company admitted to selling their information to companies without telling students, including a number of financial aid scams.

Liz Farrell's response:
Hi Scott- Good to hear from you! Thanks for your note -- Yes, I have
interviewed Mr. Munce many times for many stories and have found him to
be very helpful. I plan on continuing to use him as a source. Strangely
enough, no-one sent me an email mentioning that we have used Marilee
Jones as a source as well. Perhaps it is because NRCCUA is viewed as
"business" and Ms. Jones is not. I find that even more strange
considering that she wrote a book which ostensibly made money. Speaking
of which, do you know if she kept the profits of it? Or has any plans
to give them back? I'm curious about those things. No-one else on the
NACAC listserv seems to be. I'm not saying either Mr. Munce or Ms. Jones are
criminals or
mercenaries, because I don't think either of them are ... I'm just saying that
after reading the NACAC listserv for the past five years,
I'm constantly vexed by the arbitrary treatment wrongdoers get depending
on whether they work in admissions for a college or a company. While many of the
posts for Ms. Jones were sympathetic, or expressed
disappointment ("it's sad, she's still a great lady," etc.), the ones
about the College Board or NRCCUA have a "gotcha" tone, like they were
under suspect anyway ("the latest in a long string of offenses! I'm not
surprised!"). Because they run things "Like a business" - whatever that
means. Businesses, in my experience, come in all shapes and sizes and
moral proclivities.
Perhaps this will come across as having a devil's advocate tone. I
don't mean any offense by that, it's just that it's my job to treat everyone
fairly, and to not assume that any high school counselor or college
admissions officer is inherently more moral than the people who work for the
companies that also focus on admissions.
I will watch with interest to see how NACAC handles the NRCCUA issue. I will
also watch with interest to see how many more admissions deans
have lied about their own educational backgrounds.
cheers,
liz.

My response:
This is one argument I'm happy to engage in. Let's look at NRCCUA. They mislead those to whom they send surverys, now, (and only under a consent agreement from the FTC) stating in small print that they use this information for other than college searches. And it turns out, that they sell this information, yes, to legitemate businesses like teen magazines and Kaplan and Gillette, but also to some pretty shady characters, including some under indictment for financial aid scams. I am sorry, but there is some limit on the intersection between education and private enterprise. One might say that they cannot be held responsible for how the information is being used, but I don't buy that.
These are just a few that were discovered:
"A few of the contacts to which American Student List sells are college aid consultants targeted by the Federal Trade Commission since they began to buy the information. For example, Christopher Nwaigwe of Maryland was convicted on federal mail fraud charges in 1999 for offering phony scholarships. College Resource Management Inc. of Texas paid $40,000 this year to settle civil FTC charges it misrepresented its ability to obtain financial aid for students. A third company, College Financial Aid, has received an unsatisfactory” rating from the Better Business Bureau of upstate New York for the many consumer complaints it has received.
And the issue with Marilee was about her message, not her as the messager. I do not know of one person who has excused her lying but there is quite a bit of shock and more than a small sense of sadness at her voice being silenced.
Do me a favor, google Munce and NRCCUA and see how many FTC complaints have been lodged against the company.
There are some quasi-legitimate things this organization does, but if you were barraged by the deceptive stuff they send to high schools as I and thousands of others are, or by the high pressure techniques they use, I do not think you would feel as sanguine about Mr. Munce. Mr. Munce many not be a criminal (though I have no good reason to doubt this) and, contrary to your assertion, I believe he is an mercenary.
Throwing together Marilee Jones and Munce is just absurd. Marilee lied about her credentials. She illegitimately held her position but did not abuse her position or harm students. Actually her affect on education despite her personal issues was quite positive. I do not think that you could say the same things about Munce. There are numerous instances where he sold his lists to people who sought to deceive or cheat students and parents. He could state that he did not know or care, that his job is to make money not serve students. Then he and McLendon should get off their high horses and stop pretending to be legitimate educational research enterprises and let people know that the names that are being collected go to the highest bidder without any thought being given to their legitimate educational merit or, for that matter, educational, personal and financial harm.

I also feel that comparing NRCCUA to the College Board is a huge stretch. If you have read my postings on the College Board, I generally say the same thing over and over in different ways: they do a good job a producing a test that has merit and in administering this test. I am all for them cracking down on extended time kids and, as an SAT test administrator for 25 years, think that they do a far far better job than state testing agencies. I do think they are slow to consider things that are not in their economic interest, like having a modular SAT. But they are a business so this is understandable. College Board does what it says it does, NRCCUA does not, and that is not a minor matter. I do think College Board pretends to be more of an educational service than it is but they are at least on the right side. They at least try to be responsive to the educational community.
NRCCUA does produce some admissions training materials that are used by some, but on balance does not promote educational interests. Yes, there are those on the e-list who are reflexively anti-College Board, but I think you are painting with a pretty big brush there, in my (less than humble) opinion. Maybe you can convince me that Munce is providing a service to the educational community on balance or that the methods of NRCCUA are legitimate, but you would have to refute some pretty strong evidence to the contrary.
Giving him and his organization the voice in the Chronicle that you did in your interview I felt lent your paper's legitimacy to someone of questionable integrity. Just my two bits. Just as the Chronicle promotes educational interests while still having business interests. I think you should expect the same of those you promote in your publication.

And a follow-up posting to the NACAC e-list:

Mr. McClendon is President of the Board of Advisors for NRCCUA.

http://www.collegeoptionsfoundation.net/mclendon.html

Mr. McLendon is also one of three Members of the Board of Directors of the College Options Foundation. This organization helps students in Junior AF ROTC to navigate the college process. And what tool do you think these students use for this kind of self-discovery? You guessed it, the on-line version of the NRCCUA survey.

http://www.collegeoptionsfoundation.net/JPACtools.html#

Well, that seems harmless enough. Except that there is no restraint on where information collected from NRCCUA data goes. As you might remember from yesterday's post, (if you read to the end of my post from yesterday), these are just a few of the shady characters who they have shared their data with: Christopher Nwaigwe of Maryland was convicted on federal mail fraud charges in 1999 for offering phony scholarships. College Resource Management Inc. of Texas paid $40,000 this year to settle civil FTC charges it misrepresented its ability to obtain financial aid for students. A third company, College Financial Aid, has received an “unsatisfactory” rating from the Better Business Bureau of upstate New York for the many consumer complaints it has received.

Surely the consent agreement with the FTC prevented this from happening in the future. No, the consent decree only states that they must say they are sharing their information with other groups than just educational entities. And they do that on their web site, listing the following on their web site:

1. financial aid planning, student loans, and scholarships;
2. enrichment opportunities such as travel programs, camps, extra-curricular activities and conferences;
3. curriculum materials, books, Internet-based educational programs, magazines and low-cost literary products; and
4. academic assistance, remedial help, and preparation for college-entrance examinations.

And what scholarship services, student loan programs or financial aid planning services are paying money to buy lists from NRCCUA? Maybe Mr. Munce or Mr. Mclendon would like to post on the e-list the list of these organizations that receive names from NRCCUA.

And not only does NACAC give their seal of approval to NRCCUA but so, apparently does the Chronicle of Higher Education. In an interview in the Chronicle (http://chronicle.com/live/2006/10/munce/), Liz Farrell moderates a discussion with Don Munce, stating that he was once admission director for ten years of an unnamed Midwestern college. There is no mention of the well documented complaints against NRCCUA. She stated in response to my query:
"Yes, I have interviewed Mr. Munce many times for many stories and have found him to be very helpful. I plan on continuing to use him as a source."
(For the full discussion, go to whitesworld.blogspot.com In it, she wonders why we would give greater criticism to Don Munce than Marilee Jones).

In a greater view, I would like the membership to think about what the biggest story in the news is in relation to education. No, the Marilee Jones incident is not even a blip. Newsweek even referred to her as Marilee Dean. No, it is the misuse and abuse of financial aid practices and student privacy. We are not only being told about the cozy relationships between financial aid offices and lenders, but that there was widespread abuse in the use of student data. In the May 3rd NY Times there is an article (p. A17) that the Education Department had restricted access to student data because "of concern that student lenders or other marketers were improperly obtaining private information about potential borrowers." And in today's NT Times (p. A19), there was a report that alumni associations "are taking payments form loan companies and providing names and addresses of graduates that the companies can use for marketing purposes."

I just wonder why there is not similar outrage about the use of student names and private information, including, according to their published information,
names, addresses, GPAs, races, religions, and social views, of secondary school students. Instead we are seemingly endorsing this practice through the NACAC seal of approval and prime placement through the Chronicle of Higher Education.
A Follow-up posting on the NACAC e-list


Checking the internet to find who is on the Board of this organization (something which is curiously nowhere to be found on their web site), I did come accross the following document:

http://www.nacacnet.org/NR/rdonlyres/2216EF8D-97B1-4446-915E-3DD3C0CB2059/0/CEOReportforCouncil.pdf

Which, on the final page, notes about Joyce Smith, the Executive Director of NACAC:

NRCCUA Advisory Board
Joyce continues to serve on the NRCCUA Advisory Board as they expand their array of program and research focused on student preparation, college transition and diversity. Shanda Ivory attended their December meeting and reported back on activities underway at NRCCUA for the postsecondary and secondary community.

Maybe Ms. Smith can, in this role, find the answer to a few questions for us:

1) Does NRCCUA still sell their lists to any organzations or groups which have had criminal or civil judgements against them from the FTC or other governmental groups for fraud of misrepresentation? What about organizations that are presently under investigation or receive unsatisfactory ratings from the Better Business Bureau?

2) What is the financial compensation for the member of the Board of Directors?

3) Is it policy for members of the Board of Directors, particularly its president, to defend the organization without stating his affiliation to it.

4) Is there a reason that the members of the Board of Directors or the Board of Advisors are not publicly made available?

5) What was the process for choosing NRCCUA for the seal of approval. Was Ms. Smith or those who reported to her involved in the decision? Would that be considered a conflict of interest?

6) Did anyone at NACAC know that this outfit had been forced to sign a consent degree with the FTC? Did Joyce even know this when she joined their Board of Advisors? Did she know until you revealed it on the listserve the other day? Does she know today? Does she think it matters?

7) Does having a subsidiary approved mean that the overall organization can use the Seal of Approval as part of its marketing? (I think this constitutes fraud. What does Joyce think?)

8) Is there any written policy at NRCCUA about the sharing of personal student data, including such issues as social and religious views, with what they call "education related organizations?"

9) Is there any attempt from NRCCUA to gain parental permission from minors for the collection and dissemination of this personal information?

There seems to be a national outrage of the sharing of college student and alumni financial data but a benign acceptance of this sharing of personal information of high school students, the far majority of whom are minors. Aren't we supposed to be in the business of protecting them. Inquiring minds want to know.
From Jim Montague of Boston Latin to Don Munce:

From: Jim Montague
To: don@nrccua.org
Cc: jsmith@nacac.com
Sent: Thursday, May 10, 2007 6:46 AM
Subject: your iresponse to the NACAC elist

Since you have invited members of the NACAC list to reply directly with questions, would you please help me understand this press release from the Connecticut Attorney General's Office in January 2005. There were similar press releases from the other states involved. These public statements seem to call into question your assertion that:

"NRCCUA does not currently nor has it ever provided access to its lists to the scholarship companies mentioned in some of the comments, and has never to its knowledge had a relationship with organizations or groups with records such as those cited. In fact, we do not provide access to our list to any organization that charges a fee for financial aid advice."

January 13, 2005
Attorney General Richard Blumenthal and Department of Consumer Protection (DCP) Commissioner Edwin R. Rodriguez today announced that Connecticut has reached a settlement with National Research Center for College and University Admissions ( NRCCUA) for improperly selling personal information that the company collected from prospective college students.
The settlement, including 41 other states, as well as Connecticut, is with NRCCUA of Lee's Summit, Mo., a company that sends surveys each year to millions of high school students nationwide promising to share the information only with colleges or universities that might want to them to attend their institutions.
For at least a decade, however, NRCCUA sold students' confidential information to American Student List, LLC, which in turn sold the data to credit card, music, media and other companies that market to college students. In at least one instance, a company that scams students by falsely claiming that it can secure scholarships for a fee bought and used information collected by NRCCUA.
Personal student information sold without permission to marketers included address, grade point average, birthday, academic and occupational interests, racial and ethnic background, and, in some cases, religious affiliation.
"NRCCUA trashed the privacy rights of millions of college students by hawking their personal information for higher profit," Blumenthal said. "Students filled out surveys expecting to receive useful information from colleges, not useless pitches from advertisers. NRCCUA's actions constitute an outrageous and unconscionable breach of trust that must cease immediately. The company's practice of selling personal information is especially egregious and reckless given the growing problem of identity theft. My office will continue to closely scrutinize data collection companies to ensure that they protect consumers' privacy rights."
"We have to hold companies and organizations that collect personal information accountable for protecting privacy rights," Rodriguez said. "If the company intends to use the collected data for reasons other than its stated purpose, consumers should be given clear notice and the opportunity to opt out."
The agreement requires NRCCUA to clearly disclose how it uses student information and give students and their parents the opportunity to request that the company share information only with colleges and universities, including information that it already possesses. The company will also pay $300,000 to cover the legal expenses of Connecticut and other states taking part in the settlement.
Other states taking part in the settlement are: Arkansas, Alabama, Arizona, California, Colorado, Connecticut, Delaware, Florida, Hawaii, Idaho, Illinois, Iowa, Kentucky, Louisiana, Maryland, Maine, Michigan, Minnesota, Mississippi, Missouri, Montana, New Jersey, New York, Nevada, North Carolina, North Dakota, New Mexico, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Dakota, Tennessee, Texas, Utah, Virginia, Vermont, Washington, Wisconsin, West Virginia, and Wyoming.
I am also concerned that you have never clarified your relationship with American Student List, LLC, the organization named with you in the FTC complaint that was brought in 2001. By the way, the public record would not suggest that you "approached the FTC and offered to provide them with information." Instead, it appears in the FTC complaint that you were accused of violating the provisions of the Federal Trade Commission Act and were required to respond.