Penalty Amount
$140,000,000
Following an FTC investigation, a federal court granted summary judgment against timeshare exit scheme operator Christopher Carroll, ordering him to pay $140 million total ($95 million in consumer redress, $45 million civil penalty) for defrauding consumers out of over $90 million. The scheme used deceptive direct mail and in-person pitches, falsely claimed affiliation with timeshare companies, failed to provide refunds, and violated the FTC’s Cooling-Off Rule by forcing consumers to sign non-cancellable contracts. Carroll is also permanently banned from marketing timeshare exit services or engaging in deceptive door-to-door sales.
The court ordered Christopher Carroll to pay $140 million total, consisting of $95 million in redress to consumers and a $45 million civil penalty. Carroll is permanently banned from advertising, marketing, promoting, or offering any timeshare exit services, engaging in deceptive door-to-door sales, or other deceptive conduct outlined in the complaint. The order also imposes a permanent injunction barring the specified deceptive practices.
In-house legal teams, particularly those in the real estate or timeshare industries, should review customer-facing and consumer contracts to ensure full compliance with the FTC Cooling-Off Rule, including explicit three-business-day cancellation rights for door-to-door sales. Marketing vendor agreements and sales presentation contracts must be audited to prohibit deceptive claims such as false affiliation with third-party timeshare companies, undisclosed exorbitant fees, and unenforceable non-cancellation clauses. Refund policy clauses should be clear, enforceable, and honored in practice, while all consumer contracts should include representations and warranties against deceptive practices and indemnification provisions for FTC rule violations. Companies using direct mail or in-person sales pitches should also review advertising vendor agreements to align with truth-in-advertising standards.
Entity
Christopher Carroll
Industry
Real EstateOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/04/court-orders-operator-timeshare-exit-scheme-pay-140-million-related-ftc-allegations-scheme-took
SquareOne MemorandumandOrder
https://www.ftc.gov/system/files/ftc_gov/pdf/SquareOne-MemorandumandOrder.pdf
SquareOne Permanent Injunction
https://www.ftc.gov/system/files/ftc_gov/pdf/SquareOne-Permanent%20Injunction.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Christopher Carroll"
"$140 million"
"FTC’s Cooling-Off Rule"
"falsely claiming to be associated with timeshare companies; falsely telling consumers that they couldn’t exit a timeshare without paying the defendants’ exorbitant fees; failing to provide promised refunds; and forcing consumers to sign contracts that they were told they couldn’t cancel in violation of the FTC’s Cooling-Off Rule"
"permanently bans Carroll from advertising, marketing, promoting, or offering for sale any timeshare exit service; from engaging in any deceptive door-to-door sales; and from engaging in other deceptive and misleading conduct"
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$868K
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$750K
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