Citizens Disability SSDI Impersonation/Robocall Scheme

What happened

Citizens Disability, LLC, a Massachusetts-based company that helps consumers apply for Social Security Disability Insurance (SSDI) benefits, and its subsidiary CD Media, LLC contracted with third-party lead generators and call centers to sell their paid benefits-application-assistance services. Per the DOJ complaint (filed upon FTC referral) in the District of Massachusetts (Case No. 1:25-cv-12826), between January 2019 and July 2022 the defendants allegedly caused more than 109 million outbound telemarketing calls to be placed, including more than 25.7 million calls to telephone numbers listed on the National Do Not Call (DNC) Registry. The leads for these calls were allegedly harvested through deceptive "consent farm" websites that offered consumers sweepstakes entries, coupons, or other services in exchange for contact information, without adequately disclosing that the information would be used for telemarketing solicitation. Many recipients were lower-income or disabled consumers. A subset of the calls allegedly used prerecorded robocalls in which a voice identifying itself as "Amber" or "Audrey" falsely told the consumer "it show[s] here that you recently inquired about your eligibility for Social Security Disability benefits," creating the false impression the call was a personalized follow-up to the consumer's own prior outreach, when in fact the consumer's data had simply been scraped from an unrelated coupon/sweepstakes site. Defendants neither admitted nor denied these allegations in resolving the matter via stipulated order.

How it worked

The complaint alleges that lead-generation websites used sweepstakes, coupons and service offers to collect contact information without adequately disclosing its telemarketing use. The companies then allegedly used robocalls and calls to DNC-listed numbers to sell SSDI application-assistance services. The deceptive hook was a claim that the consumer had recently inquired about eligibility, presenting an unsolicited sales pitch as follow-up to prior contact. The allegation does not establish a measured increase in pickup or engagement caused by that script.

The lure and the tell

The tell was the specific script line quoted in the FTC complaint: a prerecorded voice identifying itself only as "Amber" or "Audrey" stating "it show[s] here that you recently inquired about your eligibility for Social Security Disability benefits," a claim the recipient had never actually made. Consumers who had never visited any SSDI-related site (and in many cases were on the DNC Registry) had no way to have "inquired," which is the giveaway that the call originated from purchased consent-farm data rather than a genuine prior contact; legitimate SSA-related outreach would not come from a third-party disability-services telemarketer referencing an inquiry the consumer never made.

Outcome

The United States filed the complaint and proposed stipulated order in the District of Massachusetts on September 30, 2025, in case 1:25-cv-12826. PacerMonitor lists the consent judgment under October 14 with an October 15 entry timestamp, rather than September 30. The proposed terms specify a $2 million civil penalty, two $500,000 payments measured from entry, and conditional suspension of the remaining $1 million. The FTC described restrictions on prerecorded robocalls, DNC-listed calls and misrepresentations, plus lead-generator due diligence and monitoring. Defendants neither admitted nor denied the complaint allegations. The docket chronology establishes later approval; the payment schedule does not establish actual collection.

Why it matters

This case documents an alleged prior-inquiry pretext in a large telemarketing operation. The FTC tied the leads to unrelated sweepstakes, coupons and service offers, while the calls claimed the recipients had asked about SSDI eligibility. The civil penalty and injunction terms address that conduct; they should not be presented as a measured consumer-loss total.

Defenses

FTC/DOJ enforcement resulted in a permanent injunction barring: (1) prerecorded/robocall telemarketing except under a narrow statutory safe harbor; (2) calls to numbers on the National Do Not Call Registry absent a valid exception; (3) misrepresentations that a call is in response to a consumer's own SSDI-eligibility inquiry or implies SSA affiliation; and required due diligence/monitoring of third-party lead generators, recordkeeping, and restrictions on use/retention of consumer data harvested via consent-farm sites. For consumers, the case illustrates standard robocall defenses: numbers on the DNC Registry are not fully protected against sweepstakes/coupon-site data harvesting; a caller claiming "you recently inquired" should be independently verified by contacting SSA (ssa.gov or 1-800-772-1213) directly rather than trusting the inbound caller; legitimate SSA communications do not originate from third-party disability-benefits marketing firms.