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CFPB: For-Profit School Misrepresented ISAs, Made False Claims About Grads’ Employment Rates

By Farnaz Farkish Thompson & Jeffrey P. Ehrlich on April 22, 2024
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On April 17, 2024, the Consumer Financial Protection Bureau entered an order against a for-profit vocational school and its CEO for mischaracterizing the school’s income-share agreements (ISAs) and misrepresenting its graduates’ employment rates. The CFPB said the school drove students to finance their training programs with promises of high graduate employability. To finance students’ education, the school offered ISAs, under which students received their education in exchange for a percentage of their future earnings. The school falsely told students that its ISAs were not loans, carried no finance charges and were “risk free.” And the school advertised on its website that 71% to 86% of its students were placed in jobs within six months of graduation, when its nonpublic reporting to investors consistently showed placement rates closer to 50%, the CFPB noted. The order marks the CFPB’s second enforcement action targeting ISAs.

Read on for details about how the school’s actions violated federal laws, including the Consumer Financial Protection Act, the Truth in Lending Act and Regulation Z, and the FTC’s Holder Rule.

Photo of Farnaz Farkish Thompson Farnaz Farkish Thompson

Co-leader of McGuireWoods’ Education Industry Team and Higher Education Practice Group, Farnaz has extensive experience representing corporations and institutions of higher education in high-profile litigation and government investigations. She is a trusted advisor with a keen eye for due diligence in education-related transactions…

Co-leader of McGuireWoods’ Education Industry Team and Higher Education Practice Group, Farnaz has extensive experience representing corporations and institutions of higher education in high-profile litigation and government investigations. She is a trusted advisor with a keen eye for due diligence in education-related transactions, including those within the edtech sector.

Read more about Farnaz Farkish ThompsonEmail
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Photo of Jeffrey P. Ehrlich Jeffrey P. Ehrlich

Jeff Ehrlich represents clients before the Consumer Financial Protection Bureau (CFPB) and other federal and state agencies that administer and enforce consumer-financial-protection laws, including the Consumer Financial Protection Act of 2010, the Fair Credit Reporting Act, the Truth in Lending Act, the Electronic…

Jeff Ehrlich represents clients before the Consumer Financial Protection Bureau (CFPB) and other federal and state agencies that administer and enforce consumer-financial-protection laws, including the Consumer Financial Protection Act of 2010, the Fair Credit Reporting Act, the Truth in Lending Act, the Electronic Fund Transfer Act, the Fair Debt Collection Practices Act, the Real Estate Settlement Procedures Act, and their implementing regulations.

Read more about Jeffrey P. EhrlichEmail
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  • Posted in:
    Administrative and Regulatory
  • Blog:
    Subject to Inquiry
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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