Subject to Inquiry

Subject to Inquiry


Government Investigations and White Collar Litigation Group

Farnaz Farkish Thompson

Photo of Farnaz Farkish Thompson As leader of the firm’s Education industry team, Farnaz is a skilled litigator with extensive experience in representing employers and institutions of higher education, including academic medical centers, in breach of contract, constitutional, discrimination, and tort litigation. She has conducted investigations, advised clients on employment and education laws, and represented them before federal agencies, including the U.S. Department of Labor and U.S. Department of Education.

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

Enforcement and Prosecution Policy and Trends
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 electronic announcement to clarify its authority over income share agreements at institutions that receive federal aid under the Higher Education Act… Continue Reading

DOJ Title IX Investigation Leads to $1.6M Agreement with San Jose State University

The Department of Justice’s Civil Rights Division, the U.S. Attorney’s Office for the Northern District of California, and San Jose State University (SJSU) settled the government’s Title IX investigation into a decade’s worth of sexual harassment allegations. The June 2020 allegations of “employee-on-student sexual harassment” and retaliation within SJSU’s athletics department prompted the government’s investigation.… Continue Reading

Income Share Agreements – Risks, Rewards, and Regulators

Financial Institution Regulation
An Income Share Agreement (ISA) is a contract in which a lender gives a student money for education, and in return, the student promises to pay the ISA-provider a fixed percentage of the student’s income for a set amount of time after graduation. The student may repay more or less than the amount received, depending… Continue Reading

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