The Federal Trade Commission (FTC)  has announced that it has settled its Complaint against operators of the lead generation business Global Media, LLC and its CEO Christopher Kay for $104 million. The judgment has been suspended because the defendants are unable to pay it. It represents the amount the defendants made by selling loan applications.

According to the Complaint, the FTC alleged that Blue Global Media and its CEO operated dozens of websites that enticed consumers to complete loan applications online, but that it would then sell those applications to third party entities willing to buy them—15 million of them.

Unfortunately for consumers, the loan applications contained all of their sensitive personal information, including names, addresses, Social Security numbers, and bank account numbers. The applications were being sold to the first buyer who offered to purchase them, and included no protections for the information when it was sold. The Judgment against Global Media, LLC requires it “to investigate and verify the identity of businesses to which they disclose consumers’ sensitive information, and must obtain consumers’ express, informed consent for such disclosures.” Of course, this is standard protection of data for most companies, and is good guidance by the FTC for all businesses.