CFPB Enters Into Consent Order with Student Lender Resolving Allegations of Deceptive Advertising

​​On December 5, 2024, the CFPB announced that it had entered into a proposed stipulated final judgment​ and order with a student lender and its investors, resolving allegations that the student lender had violated the Consumer Financial Protection Act​ (CFPA)​, the Truth in Lending Act (TILA), and Regulation Z through deceptive advertising and disclosures.

In its complaint filed back in October, the CFPB alleged that the student lender made claims that it had vetted its partners’ schools for “outcomes and value” but instead offered loans for programs that had failed its own return-on-investment analysis, or which it had not analyzed at all. The CFPB also asserted that the student lender failed to properly disclose annual percentage rates in online marketing materials and illegally hid loan origination fees in disclosures. ​​​

As part of the stipulated final judgment and order​, the student lender ​​is prohibited from making false representations concerning its loans or the programs offered by its partners, and must pay a $950,000 civil money penalty to the CFPB.  The order also includes a $6,618,000 monetary judgment that has been suspended due to an inability to pay. ​