The Federal Trade Commission is skilled at public relations and “protecting consumers” is a newsworthy event. This means that a trial or a consent order isn’t the end of your ordeal.
Instead, a FTC press release will be issued and perhaps a press conference held that will spin what happened in a very favorable light for the FTC at your expense.
Your legal counsel can sometimes mitigate the damages but that depends in part on whether the Federal Trade Commission is using you to send a warning to others in your industry. Your public relations consultant can counter-spin the media but some of the mud thrown your way will probably stick.
What you have done by accident may make you look like Scrooge preying upon the poor, the sick, and the elderly by the time you read the stories online or in a newspaper.
If restitution or other monetary payments are required as part of the Federal Trade Commission settlement, that amount may be inflated in the press coverage.
This can cause a “blood in the water” reaction.
