TransUnion engaged in deceptive practices by manipulating consumers to sign up for subscription services, violating the Consumer Financial Protection Act (CFPA). They enrolled consumers without consent, failed to offer cancellation mechanisms, misrepresented products as free or $1, falsely portrayed the purpose of collecting payment information, provided misleading information about their credit score, and misrepresented the consequences of product cancellation. Transunion manipulated its consumers to sign up for the subscription services. The follow up examination revealed that the defendant violated the settlement agreed and while it required credit card information for verification purposes, it contained a button for availing a free credit score which if clicked would result in the user being signed up for a recurring monthly subscription. These disclosures were mentioned in fine print and were difficult to locate. Additionally, they violated the Electronic Fund Transfer Act (EFTA) and Regulation E by not obtaining written authorization for recurring charges and failing to provide copies of such authorizations to consumers.