News & Analysis as of

Income Share Agreements Regulation Z

Ballard Spahr LLP

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

Ballard Spahr LLP on

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

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

Troutman Pepper on

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

Shipkevich PLLC on

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

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

Ballard Spahr LLP

CFPB Alleges Income Share Agreements are Extensions of Credit in Results-Oriented Enforcement Action against ISA Originator

Ballard Spahr LLP on

The CFPB issued a consent order against an income share agreement (ISA) provider, Better Future Forward (BFF), in which it concluded that BFF’s ISAs are extensions of credit under the Consumer Financial Protection Act and...more

Hudson Cook, LLP

Income Share Agreements - Operating Under Current Regulations and Preparing for the Future

Hudson Cook, LLP on

The Income Share Agreement ("ISA") market is rapidly developing with more providers offering ISA programs to students and outside money moving into the space. However, the legal environment remains uncertain, and providers...more

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