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

By John Feliciano-Acosta, 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 John Feliciano-Acosta John Feliciano-Acosta

John advises firm clients on mission-critical compliance questions and risk management as well as state and federal financial regulatory engagement, investigations, and enforcement.

Read more about John Feliciano-AcostaEmail
Photo of Farnaz Farkish Thompson Farnaz Farkish Thompson

As leader of the firm’s Education industry team, Farnaz is a skilled litigator with extensive experience in representing employers and institutions of higher education, including academic medical centers, in breach of contract, constitutional, discrimination, and tort litigation. She has conducted investigations, advised clients…

As leader of the firm’s Education industry team, Farnaz is a skilled litigator with extensive experience in representing employers and institutions of higher education, including academic medical centers, in breach of contract, constitutional, discrimination, and tort litigation. She has conducted investigations, advised clients on employment and education laws, and represented them before federal agencies, including the U.S. Department of Labor and U.S. Department of Education.

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

Drawing on his deep experience in government service, Jeff Ehrlich represents clients in the consumer-finance space, providing advice and counseling to businesses that compete in markets governed by multiple state and federal agencies that enforce complex and often novel statutes and regulations.

Read more about Jeffrey P. EhrlichEmail
  • Posted in:
    Corporate Compliance, International
  • Blog:
    Subject to Inquiry
  • Organization:
    McGuireWoods LLP
  • Article: View Original Source

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