Private Sector Schools and Third-Party Student Recruitment under FTC and CFPB Scrutiny

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The Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB) are intensifying their regulatory and enforcement focus on proprietary schools and third-party marketing companies.

In the fall of 2013, the FTC released revised Vocational School Guides (School Guides), which advise against deceptive marketing practices by businesses that offer vocational training. While only a guide and not directly written for all degree-granting schools, the FTC’s discussion provides a useful roadmap for educational institutions for the type of conduct it may find objectionable.

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