Scenario 3.4 The Consumer Financial Protection Bureau settled a claim with the Bank of America for deceiving customers and unfairly billing them for services such as credit monitoring and identity theft protection. Bank of America agreed to provide refunds to 2.9 million people and pay $45 million in fines for their illegal credit card practices. Their deceptive practices dated to 2000 where they had billed customers for products such as "Privacy Guard" or "Privacy Assist" without first obtaining authorization for the products. The $45 million in fines includes $25 million as a civil penalty that will be paid to the Office of the Comptroller of the Currency and $20 million to the Consumer Financial Protection Bureau. The Bureau also claims that Bank of America deceived about 1.4 million

customers into making about $268 million in payments by, among other things, improperly telling them the first 30 days of coverage were free or the benefits were greater than existed. ? Refer to Scenario 3.4. If the Consumer Financial Protection Bureau decides to contact the Federal Trade Commission (FTC) to investigate Bank of America and its practices regarding deceptive billing practices, and if the FTC believes that Bank of America has violated a law, the FTC would first

A. issue a cease-and-desist order.
B. order Bank of America to stop engaging in deceptive practices to avoid prosecution.
C. order Bank of America to refund consumers in order to settle or resolve the complaint.
D. order Bank of America to pay up to $10,000 per day for violating the law.


Answer: A

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