News & Analysis as of

Income Share Agreements

Ballard Spahr LLP

CFPB Takes Action Against BloomTech, Inc. for ISAs that Violate TILA, UDAAP, and the FTC’s Holder Rule

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On April 17th, the CFPB issued a consent order to a for-profit training school alleging numerous violations of law related to its use if income share agreements (“ISAs”). According to the Bureau, BloomTech, Inc. (“BloomTech”)...more

Troutman Pepper

CFPB Enters Consent Order Against BloomTech Over Misleading Income-Share Agreements

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On April 17, the Consumer Financial Protection Bureau (CFPB or Bureau) entered a consent order against BloomTech, a for-profit vocational school, and its CEO, Austen Allred, for deceptive marketing practices related to...more

Goodwin

CFPB Enters Into Consent Order with For-Profit Coding School

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​On April 17, 2024, the Consumer Finance Protection Bureau (CFPB) announced ​that it had entered into a consent order​ with BloomTech Inc., d/b/a Bloom Institute of Technology (BloomTech), and BloomTech’s CEO, Austen Allred,...more

Sheppard Mullin Richter & Hampton LLP

CFPB Fines and Bans Coding Bootcamp over Deceptive Student Lending Practices

On April 17, the CFPB issued a consent order against a San Francisco-based for-profit coding school and its and CEO, banning it from lending to consumers, after it found that the company inflated its job placement rates to...more

Ballard Spahr LLP

CFPB settles claims against operator of training program arising out of income share agreements

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The CFPB recently announced the settlement of a bankruptcy court adversary proceeding filed jointly with the Attorneys General of 11 states against Prehired, LLC (Prehired) and two affiliated companies (Prehired Affiliates)...more

Cozen O'Connor

Vocational Training Program Prehired to Pay Back $4.2 Million, Cancel Outstanding Loans

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A bipartisan coalition of 11 AGs, in conjunction with the CFPB, reached a settlement with the bankruptcy trustee for Prehired, LLC and affiliated entities (collectively, “Prehired”) to resolve allegations that the company...more

Troutman Pepper

Delaware Bankruptcy Court Enters $30M Stipulated Judgment Over Deceptive Student Loan Practices

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On November 20, Delaware Attorney General (AG) Kathy Jennings, along with the Consumer Financial Protection Bureau (CFPB) and 11 other states, announced a settlement in excess of $30 million with Prehired LLC and affiliated...more

Shipkevich PLLC

End of the Year for the CFPB? Not Yet! Another Order Obtained Against a Student Loan Service Provider

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On November 20, 2023, the Consumer Financial Protection Bureau (“CFPB”) announced that it had partnered with the 11 States of California, Delaware, Illinois, Massachusetts, Minnesota, North Carolina, Oregon, South Carolina,...more

Ballard Spahr LLP

NJAG and FTC announce $4.605 million settlement with for-profit college over job placement rate claims and income share...

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The New Jersey Attorney General (NJAG) and the Federal Trade Commission (FTC) recently announced settlements in concurrent actions against Sollers College, a for-profit college, its parent company, Sollers, Inc., and, in the...more

Ballard Spahr LLP

California DFPI Finalizes Regulations Governing Student Loan Servicers

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On October 13, 2023, the California Department of Financial Innovation (DFPI) published final regulations implementing the Student Loan Servicing Act (“SLSA”) and the Student Loans: Borrower Rights Law. The final regulations...more

Troutman Pepper

California Finalizes Amendments to Student Loan Servicing Act

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On October 12, in its monthly bulletin the California Department of Financial Protection and Innovation (CA DFPI) announced that final regulations to implement the Student Loan Servicing Act and the Student Loans Borrower...more

Cozen O'Connor

Vocational Training Program Allegedly Landed Consumers Debt Instead of Jobs

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Ten AGs teamed with the CFPB to file a complaint against Prehired, LLC and affiliated entities (collectively, “Prehired”) alleging that the company violated the Consumer Financial Protection Act of 2010 and the Fair Debt...more

Ballard Spahr LLP

CFPB and 11 states file lawsuit against companies engaged in origination and collection of income share agreements

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The Consumer Financial Protection Bureau, the California Department of Financial Protection and Innovation (CA DFPI), and ten state Attorneys General have filed a lawsuit against Prehired, LLC (Prehired) and two related...more

Troutman Pepper

Connecticut Banking Statutes Amendments Take Effect October 1

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On June 29, Connecticut Governor Ned Lamont signed SB 1033, An Act Concerning Various Revisions to the Banking Statutes, into law. As discussed here, with this bill, Connecticut joins several other states that have set strict...more

Troutman Pepper

California Publishes Notice of Second Modifications to Proposed Rulemaking Regulating Student Loan Servicing

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As reported here, on September 9, 2022, the California Department of Financial Protection and Innovation (CA DFPI) published a notice of rulemaking action, proposing amendments to the Student Loan Servicing Act....more

Orrick, Herrington & Sutcliffe LLP

Bipartisan Senate legislation would offer stronger ISA protections

On January 31, Senators Mark Warner (D-VA), Todd Young (R-IN), Marco Rubio (R-FL), and Chris Coons (D-DE) reintroduced legislation to strengthen protections for students who enter into income share agreements (ISAs). ...more

Bradley Arant Boult Cummings LLP

California Prepares to Add New Student Loan Servicing Regulations

The California Department of Financial Protection and Innovation (DFPI) recently issued a Notice of Modification to Proposed Regulations and published the newly modified proposed regulations to amend its student loan...more

Orrick, Herrington & Sutcliffe LLP

DFPI modifies Student Loan Servicing Act proposal

On January 6, the California Department of Financial Protection and Innovation issued modified proposed regulations under the Student Loan Servicing Act (Act)...more

Manatt, Phelps & Phillips, LLP

Student Loan News: California Proposes Updated Licensing and Servicing Regulations

In an effort to clarify the regulatory framework applicable to new education financing methods such as Income Share Agreements (“ISAs”), installment payment plans and other alternative financing methods, the California...more

Alston & Bird

Structured Finance Spectrum – July 2022

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Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. Guest edited by our London team, this edition focuses on the opportunities that come from stressed...more

McGuireWoods LLP

U.S. Department of Education Officially Asserts Authority over Income Share Agreements

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On March 2, 2022, the U.S. Department of Education’s Office of Federal Student Aid (FSA) for the first time asserted regulatory authority over income share agreements (ISAs) as private education loans. FSA issued an...more

Bradley Arant Boult Cummings LLP

CFPB Action Against Student Loan Originator Sends Message to Income Share Agreement Industry

On September 7, 2021, the CFPB issued a consent order against Better Future Forward, Inc., and related entities (collectively, BFF), companies that provide financing for postsecondary education to students via income share...more

Eversheds Sutherland (US) LLP

CFPB Enforcement Actions Zero in on Income Share Agreements and “Payday Alternative” Loans

In September 2021, the CFPB took action against Better Future Forward, Inc. (BFF), a provider of student income share arrangements, and LendUp, an online, subprime consumer lender. In both cases, the CFPB alleged that the...more

Cozen O'Connor

CFPB: Income Share Agreements Are Student Loans And Must Follow Student Loan Rules

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The Consumer Financial Protection Bureau (“CFPB”) reached a settlement with private student loan company Better Future Forward Inc. and related companies (collectively, “Better Future”) over allegedly deceptive practices in...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - September 2021 #2

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Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

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