Sapphire Resorts review: Membership fee (refinance) an illusion of inclusion

Executive Summary
Sapphire Resorts, operated through its website https://www.staysapphire.com/home/landing, exploits consumers through a pattern of systemic predatory lending, deceptive marketing, and contractual manipulation. By disguising timeshare agreements as "mortgage-like" investments, the company misleads consumers into financial arrangements that impose excessive burdens without offering equity or ownership benefits. These agreements are structured to maximize profit at the expense of consumer trust and financial well-being.
Tanya Alexandra's experience is emblematic of this exploitation. She was unknowingly committed to a nine-year membership with Sapphire Resorts, financed at a predatory APR of 19.75%. Without the opportunity to explore non-financed membership options, she was pressured into a contract requiring an initial monthly payment of $250. This Payment increased to $350.54 in 2021 after Sapphire Resorts offered her additional "points," falsely marketed as a benefit of refinancing. Over 119 months, Tanya will pay $41,710.26 on a $15,495 principal—a Total Interest Percentage Paid (TIPP) of 169.21%. The unit number on the electronic bill is associated with the Master Promissory Note, which allows the member to think it's an actual unit and not an illusion of inclusion.
During a call with Sapphire Resorts representatives Maly and Liz on January 10, 2025 (call duration: 35 minutes, 11:26 AM EST to 11:45 AM EST), Maly misleadingly claimed, "Membership, think of it as a mortgage." This statement, designed to legitimize the financial terms of the agreement, was a deliberate misrepresentation of the product's true nature. Mortgages provide tangible equity and long-term value, while Sapphire Resorts' timeshare agreement offers neither. Liz further admitted that all consumers are subjected to the 19.75% APR regardless of creditworthiness, raising serious concerns about the fairness and legality of their lending practices. Moreover, financing and refinancing membership fees are a predatory tactic that may violate consumer protection laws.
To further contextualize the harm, Tanya's actual home mortgage, which involves four times the loan principal, carries a significantly lower APR and offers substantial equity benefits. This stark disparity underscores the exploitative nature of Sapphire Resorts' financial terms.
The financial harm Tanya has suffered is not an isolated incident but indicative of systemic consumer abuse. Similar complaints from other consumers—citing high-pressure sales tactics, denial of statutory cancellation rights, and inflated APRs—confirm that Sapphire Resorts' operations represent a broader pattern of exploitation.
This submission seeks urgent regulatory intervention to address these predatory practices, enforce penalties, and ensure restitution for affected consumers. Sapphire Resorts must be held accountable for its actions, and systemic reforms are necessary to prevent future harm.

Crippling Statement
Sapphire Resorts embodies the worst aspects of predatory lending and deceptive marketing, targeting unsuspecting consumers with financial products that are more burdensome than a $300,000 mortgage. By disguising these agreements as "mortgage-like" investments, Sapphire Resorts misleads consumers into believing they are gaining equity and ownership. Instead, they are left with only a 19.75% APR, opaque terms, and an endless cycle of financial obligations.
The actual cost of this predatory practice is staggering: Tanya Alexandra, for a $15,495 timeshare, will pay $41,710.26 over 119 months—a Total Interest Percentage Paid (TIPP) of 169.21%. A $300,000 mortgage at 7% APR over 30 years results in a lower TIPP of 139.64%, even though it provides actual equity, ownership, and long-term value. Sapphire Resorts charges more for far less, exploiting consumers with misleading promises, high-pressure sales tactics, and unclear loan disclosures.
This is not a simple case of unfair business practices; it is a systemic and calculated effort to trap consumers in predatory financial agreements. Sapphire Resorts' operations erode consumer trust, violate federal laws, and perpetuate financial harm. Without swift and decisive intervention, countless other consumers will face similar exploitation.
This submission urges the FTC to take immediate action to protect consumers, enforce penalties, and restore integrity to the marketplace. Sapphire Resorts must be held accountable for its predatory practices, and their systemic abuse must end.

Key Allegations and Violations
Deceptive Marketing Practices
Violation: Section 5 of the Federal Trade Commission Act (15 U.S.C. § 45).
Details:
Misrepresented the timeshare program as equivalent to a mortgage, suggesting equity or ownership benefits that do not exist.
Concealed the actual cost of the financial agreement through unclear or incomplete disclosures.
Case Law:
FTC v. AMG Capital Mgmt., LLC, 910 F.3d 417 (9th Cir. 2018): Affirmed FTC's authority to penalize deceptive marketing practices.
In the Matter of Wyndham Worldwide Corp., FTC File No. 102-3142: FTC imposed penalties for deceptive marketing in the timeshare industry.
Predatory Lending and Non-Disclosure
Violation: Truth in Lending Act (15 U.S.C. § 1601).
Details:
Charged an excessive APR of 19.75% without adequate financial disclosure or explanation of the repayment burden.
Omitted critical details in the contract, violating clear disclosure standards mandated by TILA.
Case Law:
Smith v. Cash Store Mgmt., Inc., 195 F.3d 325 (7th Cir. 1999): Reinforced that failure to disclose loan terms and excessive APRs violate TILA.
Mourning v. Family Publications Service, Inc., 411 U.S. 356 (1973): Affirmed that creditors must comply with TILA's disclosure requirements.
Fraudulent Misrepresentation
Violation: Fraudulent Misrepresentation and Potential RICO Violations.
Details:
Sapphire Resorts misrepresented financial terms and timeshare benefits to induce consumers to sign agreements.
Systemic misrepresentation suggests a potential violation of the Racketeer Influenced and Corrupt Organizations Act (18 U.S.C. § 1961).
Case Law:
Spears v. Chrysler Corp., 744 N.E.2d 1056 (Ind. 2001): Fraudulent misrepresentation invalidates contracts.
Bridge v. Phoenix Bond & Indemnity Co., 553 U.S. 639 (2008): Applied RICO to systemic fraud cases.
Detailed Financial Breakdown
Timeshare Loan Terms
Principal: $15,495
APR: 19.75%
Loan Term: 119 months
Monthly Payment: $350.54
Calculations:
Total Payment (P):
P=350.54×119=41,710.26P = 350.54 times 119 = 41,710.26P=350.54×119=41,710.26
Total Interest Paid (TIP):
TIP=41,710.26−15,495=26,215.26TIP = 41,710.26 - 15,495 = 26,215.26TIP=41,710.26−15,495=26,215.26
Total Interest Percentage Paid (TIPP):
TIPP=(TIPPrincipal)×100=(26,215.2615,495)×100≈169.21%TIPP = left( frac{TIP}{Principal} right) times 100 = left( frac{26,215.26}{15,495} right) times 100 approx 169.21%TIPP=(PrincipalTIP​)×100=(15,49526,215.26​)×100≈169.21%
Mortgage Loan Terms
Principal: $300,000
APR: 7%
Loan Term: 30 years
Monthly Payment: $1,996.97
Calculations:
Total Payment (P):
P=1,996.97×360=718,909.20P = 1,996.97 times 360 = 718,909.20P=1,996.97×360=718,909.20
Total Interest Paid (TIP):
TIP=718,909.20−300,000=418,909.20TIP = 718,909.20 - 300,000 = 418,909.20TIP=718,909.20−300,000=418,909.20
Total Interest Percentage Paid (TIPP):
TIPP=(418,909.20300,000)×100≈139.64%TIPP = left( frac{418,909.20}{300,000} right) times 100 approx 139.64%TIPP=(300,000418,909.20​)×100≈139.64%
Comparative Analysis
Loan TypePrincipalAPRTermMonthly PaymentTotal PaymentTIPTIPP (%)
Timeshare Loan $15,495 19.75% 119 mos $350.54 $41,710.26 $26,215.26 169.21%
Mortgage Loan $300,000 7.0% 30 yrs $1,996.97 $718,909.20 $418,909.20 139.64%
Key Takeaway:
A consumer pays a higher TIPP (169.21%) on a $15,495 timeshare loan than a $300,000 mortgage (139.64%). This disparity is egregious because the timeshare provides no equity, ownership, or long-term value.
Systemic Consumer Complaints
Better Business Bureau (BBB): Over 100 complaints about Sapphire Resorts cite deceptive marketing, denial of cancellation rights, and exploitative financing.
Trustpilot Reviews: Consistent grievances regarding unclear terms, high-pressure sales tactics, and predatory interest rates corroborate Tanya Alexandra's experience.
Request for Regulatory Action
Investigate and Audit:
Conduct an extensive review of Sapphire Resorts' marketing practices, lending terms, and consumer contracts.
Impose Penalties:
Enforce penalties for violations of the FTC Act, TILA, and other applicable laws.
Mandate Consumer Restitution:
Cancel predatory contracts.
Provide refunds for interest paid under misleading agreements.
Advocate for Reform:
Limit APRs on non-mortgage products.
Enhance disclosure requirements for timeshare agreements.
Closing Statement:
Sapphire Resorts' actions illustrate a blatant disregard for consumer protection laws and ethical business practices. Tanya Alexandra was unknowingly lured into a nine-year membership contract with Sapphire Resorts, financed at an exorbitant APR of 19.75%. The agreement, disguised as a "mortgage-like" commitment, falsely implied equity or ownership benefits while burying the actual cost and financial burden in opaque terms.
Without being allowed to consider a non-financed membership option, Tanya was subjected to a predatory financing scheme. Initially paying $250 per month, she was pressured into refinancing in 2021 to gain more points, which increased her payments to $350.54 monthly. Over 119 months, she will pay $41,710.26—an astounding Total Interest Percentage Paid (TIPP) of 169.21% for a $15,495 principal loan.
During a call on January 10, 2025, with Sapphire Resorts representatives Maly and Liz (call duration: 35 minutes, 11:26 AM EST to 11:45 AM EST), Maly claimed, "Membership, think of it as a mortgage." This statement underscores the deceptive marketing that misleads consumers into believing that timeshares offer similar benefits to traditional mortgages, such as equity and ownership. Liz further stated that all consumers are subjected to the 19.75% APR regardless of their creditworthiness—raising the question: why was credit approval run if it bore no impact on the terms? Additionally, financing and refinancing membership fees are inherently questionable and may constitute illegal practices.
This is compounded by the fact that Tanya's actual home mortgage, with four times the loan principal of the Sapphire Resorts membership, carries a much lower APR and provides accurate equity and long-term value. This disparity highlights the financial exploitation inherent in Sapphire Resorts' lending practices.
The financial burden imposed on Tanya is not an isolated case but a systemic issue that has likely affected countless consumers. Sapphire Resorts has weaponized high-pressure sales tactics, misrepresentation, and unfair lending to trap individuals in oppressive financial agreements that provide no tangible value.
The Federal Trade Commission (FTC) can hold companies accountable for predatory practices. I respectfully urge the FTC to:
Investigate Sapphire Resorts for deceptive marketing, fraudulent misrepresentation, and predatory lending practices.
Audit their operations to identify systemic violations and uncover the scope of harm caused to consumers.
Enforce significant penalties for their disregard of federal consumer protection laws, including the Federal Trade Commission Act and Truth in Lending Act.
Mandate restitution for affected consumers like Tanya Alexandra, including cancellation of contracts and refunds for undue financial harm.
Sapphire Resorts' predatory practices undermine the principles of fairness and transparency upon which consumer trust is built. By decisively addressing these violations, the FTC can set a powerful precedent that such exploitation will not be tolerated. Tanya's case is not just a matter of financial harm but a call to restore justice and prevent future abuses in the marketplace.
I am prepared to provide further documentation, evidence, or testimony to support this investigation and ensure that other consumers are protected from predatory practices.