The FTC collects complaints about companies that allegedly violate the data privacy, data security, advertising, and marketing laws. The result is a massive database of consumer complaints known as “Consumer Sentinel” that is used by the FTC and other consumer protection regulators to identify and investigate enforcement targets.

Regulators can use Consumer Sentinel to search for complaints on any company. They can also request that the database alert them to new complaints about an organization, or connect them with other law enforcement agencies that might have an interest in investigating the same organization. In addition to these functionalities, the FTC also creates a “Top Violator” report and a “Surge” report that track those organizations that the FTC believes may have a suspicious pattern of consumer complaints.1 The end result is that the vast majority of FTC enforcement actions target companies identified within the FTC’s database. The following provides a snapshot of information concerning the FTC’s Consumer Sentinel.

28 million

Number of consumer complaints maintained in Consumer Sentinel.2

93.8%

Percentage of FTC enforcement actions that target a company found in Consumer Sentinel.3

35

Number of government agencies that contribute complaints to the FTC’s Consumer Sentinel.4

195

Number of distinct “law violations” tracked by the FTC.5

394 – 2,795

Range of complaints filed per month against the top 50 organizations tracked.6

What to think about when considering the records that the FTC maintains about your organization:

  1. Has your organization been identified as a potential enforcement target on the FTC’s Top Violator or Surge reports?
  2. Does your organization routinely track the quantity of complaints that the FTC maintains about it?
  3. Is the volume of complaints filed about your organization above, or below, those of others in your industry?
  4. If the FTC, or another regulator, searched for the complaints about your organization what potential compliance issues would they identify?
  5. If your organization were investigated by the FTC, is the volume of complaints filed about it easily explained?
  6. Is the volume of your complaints trending up, or trending down?
  7. Have plaintiffs’ law firms investigated your complaint volume?