Here are the key points:
Order Effective Dates: The order is final and effective upon publication on the Commission's website (ftc.gov) as a final order.
Compliance Monitoring: Respondents must permit representatives of the Commission to interview anyone affiliated with them who has agreed to an interview. The Commission may also use other lawful means, including posing as consumers or suppliers, to monitor compliance.
Recordkeeping: Respondents must create and retain certain records for 15 years after the issuance date of the order, including accounting records, personnel records, consumer complaints, refund requests, and all documents related to the order.
Compliance Reports: Respondents must submit periodic compliance reports to the Commission, which must be sworn under penalty of perjury.
Order Termination: The order will terminate 20 years from the date of its issuance or upon the filing of a complaint (with or without an accompanying settlement) in federal court alleging any violation of the order, whichever comes later.
Other Provisions: The order includes other provisions related to consumer protection, including requirements for disclosure and truthfulness in advertising and sales practices.
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