[author: Barbara S. Mishkin]

The investigation that led to the settlement announced last week among 20 State Attorneys General and QuinStreet, Inc., the owner of a website that markets educational institutions to military servicemembers and their families, was launched as result of the CFPB’s examination of the website, according to news reports. The Attorneys General alleged that the websites, including one named “GIBill.com,” made false, misleading and deceptive misrepresentations such as creating the impression that that the sites were operated, owned or endorsed by the federal government and the predominately for-profit schools listed as “eligible GI Bill Schools” were the only schools at which veterans’ benefits could be used.   

In addition to requiring QuinStreet to make a $2.5 million payment to be divided among certain of the states as determined by the Attorneys General and relinquish ownership of the domain “GIBill.com” to the Department of Veterans Affairs, the settlement agreement includes other relief such as requirements for new disclosures on QuinStreet’s remaining military-related websites. Earlier this year, we reported that the CFPB, the Department of Defense and State Attorneys General had jointly created the “Repeat Offenders Against Military Database” (ROAM) to collect information on enforcement actions taken by federal and state officials against perpetrators of financial scams against the military community.  

We found it interesting that Holly Petraeus, the CFPB’s Assistant Director for the Office of Servicemember Affairs, did not mention the CFPB’s role in the QuinStreet investigation in her prepared remarks on the settlement. Nevertheless, collaboration with State Attorneys General has been a centerpiece of the CFPB since it opened its door for business and, in the coming months, we expect to see an increased level of enforcement activity resulting from CFPB/State AG “teamwork” both inside and outside the military arena.