Investigators Training Academy

Text (OCR of the scan at left; may contain errors)

In THE Marrer or INVESTIGATORS TRAINING ACADEMY, ET AL.

CONSENT ORDER, ETC., IN REGARD TO THE ALLEGED VIOLATION OF THE FEDERAL TRADE COMMISSION AND THE TRUTH IN LENDING ACTS Docket C-1800. Complaint, Sept. 24, 1970—Decision, Sept. 24, 1970 Consent order requiring a Washington, D.C., school offering instructions in detective and investigational techniques to cease violating the Truth in Lending Act and Regulation Z issued thereunder by failing to make all disclosures in its consumer credit transactions required by said Act and Regulation.

ComrLAINT Pursuant to the provisions of the Truth in Lending Act and the implementing regulation promulgated thereunder, and the Federal Trade Commission Act and by virtue of the authority vested in it by said Acts, the Federal Trade Commission, having reason to believe that Investigators Training Academy, a corporation, and Jack Ezell, also known as Jack Young and as Thomas A. Ezelle, individually and as an officer of said corporation, hereinafter referred to as respondents, have violated the provisions of said Acts and implementing regulation, and it appearing to the Commission that a proceeding by it in respect thereof would be in the public interest, hereby issues its complaint stating its charges in that respect as follows:

Decision and Order TT ¥.T.C.

Paracrary 1. Respondent Investigators Training Academy is a corporation organized, existing and doing business under and by virtue of the laws of the District of Columbia, with its principal office and place of business located at 1843 H Street, N.W., Washington, D.C.

Respondent Jack Ezell, also known as Jack Young and as Thomas A. Ezelle, is an officer of the corporate respondent. He formulates, directs and controls the policy, acts and practices of the corporation, including the acts and practices hereinafter set forth. His address is the same as that of the corporate respondent. Par. 2. Respondents are now, and for some time last past have been, engaged in the advertising, offering for sale and sale to the public of a course of instruction in detective and investigational techniques.

Par. 3. In the ordinary course of their aforesaid buisness respondents regularly extend consumer credit, as “consumer credit” is defined in Regulation Z, the implementing regulation of the Truth jn Lending Act, duly promulgated by the Board of Governors of the ¥ederal Reserve System.

Par. 4. Subsequent to July 1, 1969, in the ordinary course of their aforesaid business and in connection with their credit sales, as “credit, sale” is defined in Regulation Z, respondents have caused and are causing their customers to enter into contracts for the sale of respondents’ goods and services. On these contracts, respondents fail to disclose credit cost information required by Section 226.8 of Regulation Z, in the manner and form prescribed therein. Respondents do not provide these customers with any consumer credit cost disclosures.

Par. 5. Pursuant to Section 105 of the Truth in Lending Act, respondents’ aforesaid failure to comply with the provisions of Regulation Z constitute a violation of that Act and pursuant to Section 108 thereof, respondents have thereby violated the Federal Trade Commission Act.

Deciston AND Order The Federal Trade Commission having initiated an investigation of certain acts and practices of the respondents named in the caption hereof, and the respondents having been furnished thereaiter with a copy of a draft. of complaint which the Bureau of Consumer Protection proposed to present to the Commission for its consideration and which, if issued by the Commission, would charge respondents with violation of the Federal Trade Commission Act, the Truth in 1287 Decision and Order Lending Act and the implementing Regulation promulgated thereunder; and The respondents and counsel for the Commission having thereafter executed an agreement containing a consent order, an admission by the respondent of all the jurisdictional facts set forth in the aforesaid draft of complaint, a statement that the signing of said agreement is for settlement purposes only and does not constitute an: admission by respondents that the law has been violated as alleged in such complaint, and waivers and other provisions as required by the Commission’s Rules; and The Commission having thereafter considered the matter and. having determined that it had reason to believe that the respondents have violated the said Acts, and that complaint should issue stating” its charges in that respect, and having thereupon accepted the executed consent agreement and placed such agreement on the public record for a period of thirty (30) days, now in further conformity with the procedure prescribed in Section 2.34(b) of its Rules, the Commission hereby issues its complaint, makes the following jurisdictional findings, and enters the following order: 1. Respondent Investigators Training Academy is a corporation organized, existing and doing businéss under and by virtue of the laws of the District of Columbia, with its principal office and place of business located at 1343 H Street, N.W., Washington, D.C. Respondent Jack Ezell, also known as Jack Young and as Thomas A. Ezelle, is an officer of said corporation. He formulates, directs and controls, the policies, acts and practices of said corporation and his address is the same as that of said corporation. 2. The Federal Trade Commission has jurisdiction of the subject matter of this proceeding and of the respondents, and the proceeding is in the public interest.

ORDER It is ordered, That respondents Investigators Training Academy, and its officers, and Jack Ezell, also known as Jack Young and as. Thomas A. Ezelle, individually and as an officer of said corporation, ‘and respondents’ agents, representatives and employees, directly or through any corporate or other device, in connection with any extension of consumer credit, as “consumer credit” is defined in Regulation Z (12 CFR Part 226) of the Truth in Lending Act (Public Law 90-321, 15 U.S.C. 1601 e¢ seg.), do forthwith cease and desist from failing, in any consumer credit transaction or advertisement, to make all disclosures, determined in accordance with Sections 226.4 Decision and Order WT ETC.

and 226.5 of Regulation Z, in the manner, form and amount required by Sections 226.6, 226.8 and 226.10 of Regulation Z, the implementing regulation of the Truth in Lending Act, duly promulgated by the Board of Governors of the Federal Reserve System. It is further ordered, That a copy of this order to cease and desist be delivered to all present and future personnel of respondents engaged in the consummation of any extension of consumer credit and/or in any aspect of preparation, creation, and placing of advertising, and failing to secure from each such person a signed statement acknowledging receipt of said order. It is further ordered, That respondents notify the Commission at least thirty (80) days prior to any proposed change in the corporate respondent, such as dissolution, assignment, or sale resultant in the emergence of a successor corporation, the creation or dissolution of subsidiaries, or any other change in the corporation which may affect compliance obligations arising out of the order. It is further ordered, That respondents shall, within sixty (60) days after service upon them of this order, file with the Commission a report in writing, setting forth in detail the manner and form in which they have complied with the order to cease and desist contained herein.