Telemarketing enforcement case where the FTC obtained a temporary restraining order against defendants who deceptively marketed limited benefit health plans as comprehensive health insurance. The scheme caused tens of millions of dollars in harm to consumers seeking health coverage. The court halted operations at the FTC's request.
The court entered a temporary restraining order stopping the defendants' operations, and the FTC is seeking refunds for affected consumers.
In-house legal teams should review vendor agreements with telemarketing firms and customer enrollment contracts for health insurance products. Key clauses to examine include marketing representations, disclosure requirements (especially distinctions between limited benefit and comprehensive plans), compliance with the Telemarketing Sales Rule, audit rights over marketing materials, and termination provisions for deceptive practices. Recommended changes: add clear definitions of plan types and coverage levels, mandate pre-approval of all marketing scripts and materials, include indemnification for misrepresentation claims, require regular compliance certifications from vendors, and strengthen audit rights to monitor telemarketing activities.
Entity
Top Healthcare Options Insurance Agency Inc
Also known as: Top Healthcare Options
Industry
HealthcareOfficial Press Release
https://www.ftc.gov/news-events/news/press-releases/2026/01/ftcs-request-court-halts-operations-deceptive-health-care-telemarketers
TopHealth Complaint
https://www.ftc.gov/system/files/ftc_gov/pdf/TopHealth-Complaint.pdf
Federal Trade Commission Enforcement Page
https://www.ftc.gov/enforcement
"Top Healthcare Options Insurance Agency Inc"
"FTC’s Telemarketing Sales Rule (TSR)"
"the FTC Act"
"deceptive telemarketing scheme that takes advantage of consumers looking for comprehensive health insurance"
$930K
The FTC finalized orders requiring CMG Media Corporation (doing business as Cox Media Group), MindSift LLC, and 1010 Digital Works LLC to pay a total of $930,000 for falsely claiming they offered an AI-powered service that could target ads based on conversations captured from consumers' smart devices, and that consumers had opted into such targeting. The orders also prohibit the companies from making misrepresentations about their advertising services, voice data collection, and consumer consent.
The FTC announced it is seeking public comment on a proposed enforcement policy statement regarding personalized pricing, which is the use of personal data to set prices based on what a company believes an individual consumer is willing to spend. The statement warns that undisclosed collection or use of personal data for personalized pricing could violate the FTC Act's prohibition on unfair or deceptive practices. The Commission voted 2-0 to authorize the Federal Register notice.
$4.0M
The FTC and Connecticut secured a $4 million settlement with Chase Nissan LLC (doing business as Manchester City Nissan) over allegations the dealership charged consumers unauthorized fees, including double-charging for 'certified pre-owned' vehicles and inserting charges like total loss protection into financing agreements without consent. The settlement requires $4 million in consumer redress, prohibits misrepresentations about vehicle certification and warranties, mandates prominent disclosure of the maximum total vehicle price, and requires express informed consent for all charges.
The FTC filed a complaint against Credit Glory LLC and related entities for deceptive credit repair practices, including false promises, impersonating debt collectors, charging illegal upfront fees, and using negative option billing without consent. A federal court temporarily halted the operation.
The FTC issued a policy statement abandoning disparate-impact liability, stating it will no longer bring claims based on this theory. It also modified compliance obligations for several companies based on past decisions.
The FTC, along with Utah and California, filed a complaint against Hims & Hers alleging the telehealth provider shared consumers' sensitive health information with third-party advertising platforms without consent, and deceived consumers about billing and cancellation practices. The complaint alleges violations of the FTC Act and the Restore Online Shoppers' Confidence Act.