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"
The FTC filed a complaint alleging that GovAssist LLC, Entry LLC, and Scott Zuckerman used deceptive paid search ads, misleading service and pricing claims, and fake reviews to deceive consumers seeking passport services. The complaint alleges violations of the FTC Act, the Impersonation Rule, and the Gramm-Leach-Bliley Act; the case will be decided by the court, and no penalty or remedy is reported as imposed.
The FTC issued its annual report to Congress describing fraud trends affecting older adults and the agency’s enforcement, education, and outreach efforts. The report is not a specific privacy enforcement action and announces no penalty or remedy.
The FTC referred a complaint against REPS & Company Inc. and company executives, alleging they bypassed ticket-issuer security controls and purchasing limits to acquire millions of tickets for resale. The complaint was filed by the Department of Justice, and the case will be decided by the court; the press release does not report a penalty or other remedy imposed.
$106.8M
A federal court entered a $106.8 million default judgment against corporate defendants in an alleged debt-relief scheme that impersonated banks and government entities and targeted seniors and veterans. The judgment permanently bans the defendants from the debt-relief industry and imposes additional prohibitions, including on impersonation, telemarketing, and misrepresentations.
The FTC sued Digital Forensics Corporation LLC and affiliated defendants, alleging they misled sextortion victims with promises of investigative and monitoring services that often were not provided, and used fake positive reviews. A federal court granted the FTC’s request to temporarily halt the defendants’ activities; the complaint remains for the court to decide.
The FTC alleged that Greenway Auto Group advertised vehicle prices thousands of dollars below the amounts consumers actually paid and used mailers falsely suggesting recipients had won cash prizes. Greenway agreed to an order requiring transparent pricing and prohibiting deceptive prize mailers and other misrepresentations; the press release does not state a monetary penalty.