Privacy & Information Security Law Blog

On September 30, 2025, the Federal Trade Commission announced that Citizens Disability, and its subsidiary CD Media, agreed to pay $1 million to resolve allegations that the companies violated Section 5 of the FTC Act and the Telemarketing Sales Rule in connection with tens of millions of telemarketing calls.

According to the FTC, between January 2019 and July 2022, Citizens Disability and its subsidiary allegedly made over 109 million outbound telemarketing calls, with more than 25 million calls to numbers on the National Do Not Call Registry (“DNC Registry”). The FTC further alleged that the companies contracted with lead generators to obtain call lists that were created via websites that “deceptively induce consumers into providing their information through attractive sweepstakes, coupons, and service offers, but fail to disclose their personal contact information will be used for certain telemarketing calls.” Finally, the FTC alleged that Citizens Disability and its subsidiary then misrepresented that they were calling consumers in response to inquiries about eligibility for Social Security Disability Insurance benefits.

In addition to the $1 million penalty, the proposed consent order:

• Prohibits Citizens Disability and its subsidiary from certain telemarketing using pre-recorded robocalls.
• Prohibits Citizens Disability and its subsidiary from certain telemarketing to telephone numbers on the DNC Registry.
• Prohibits Citizens Disability and its subsidiary from making misrepresentations, including that they are calling in response to a consumer’s inquiry about their eligibility for Social Security disability benefits.
• Requires Citizens Disability and its subsidiary to conduct due diligence and monitoring of their lead generators to ensure that their lead generators do not make misrepresentations when soliciting consumers.

The proposed order also includes a $2 million civil penalty that will be partially suspended upon paying $1 million within the year after the order is entered.