News & Analysis as of

Income Share Agreements Student Loans

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

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

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

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

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

Ballard Spahr LLP

Colorado Private Education Lender Registration Takes Effect September 1, and Schools Using Income Share Agreements Are Covered

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With Colorado’s private education lender registration scheduled to take effect on September 1st, the Colorado Department of Law has just announced that they intend to bring a new group within their jurisdiction: private...more

Manatt, Phelps & Phillips, LLP

Student Lending: Illinois Enacts ‘Know Before You Owe’ Law

Illinois House Bill 2746, also known as the “Know Before You Owe Private Education Loan Act,” was signed into law by Illinois Governor J.B. Pritzker on August 26, 2021, after unanimous passage in both chambers of the Illinois...more

Ballard Spahr LLP

California DFPI announces agreement with program manager of income share agreements

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Last week, the California Department of Financial Protection and Innovation (DFPI) announced that it had entered into “a landmark agreement” with Meratas, Inc., a company that acts as a program manager of Income Share...more

Hudson Cook, LLP

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

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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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