Subject to Inquiry

Subject to Inquiry

THE LATEST ON GOVERNMENT INQUIRIES AND ENFORCEMENT ACTIONS

Government Investigations and White Collar Litigation Group

Jeffrey P. Ehrlich

Photo of Jeffrey P. Ehrlich Drawing on his deep experience in government service, Jeff Ehrlich represents clients in the consumer-finance space, providing advice and counseling to businesses that compete in markets governed by multiple state and federal agencies that enforce complex and often novel statutes and regulations.

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CFPB: For-Profit School Misrepresented ISAs, Made False Claims About Grads’ Employment Rates

By John Feliciano-Acosta, Farnaz Farkish Thompson and Jeffrey P. Ehrlich on Enforcement and Prosecution Policy and Trends, Financial Institution Regulation
On April 17, 2024, the Consumer Financial Protection Bureau entered an order against a for-profit vocational school and its CEO for mischaracterizing the school’s income-share agreements (ISAs) and misrepresenting its graduates’ employment rates. The CFPB said the school drove students to finance their training programs with promises of high graduate employability. To finance students’ education,… Continue Reading

Massachusetts Attorney General Increasing Enforcement in Car Repossession Space

By Kevin B. Frankel, Jeffrey P. Ehrlich, Erin Ashwell and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
The Massachusetts Attorney General (AG) is increasing its enforcement in the motor-vehicle-repossession space. In a January 17, 2023 Assurance of Discontinuance (AOD), the AG stated that it is “conducting an investigation” into “entities collecting, servicing and/or funding” motor-vehicle-secured retail-installment contracts. The AG is focused on two primary areas of compliance:… Continue Reading

U.S. Department of Education Launches Secret Shoppers Program to Investigate Colleges and Universities

By Farnaz Farkish Thompson, Jeffrey P. Ehrlich, John S. Moran, Meredith Pinson, Jack White and McGuireWoods LLP on Enforcement and Prosecution Policy and Trends
Federal Student Aid’s Office of Enforcement announced a “secret shoppers” program to evaluate a college or university’s recruitment, enrollment, financial aid and other practices. The secret shoppers program will focus on student recruitment and enrollment practices, which may include the practices of online program managers. Read on for details about this initiative, including types of… Continue Reading

CFPB’s New Interest in Examining Fintechs is Likely to Mean More Naming and Shaming by the Agency

By Jeffrey P. Ehrlich, Kristin Lee and McGuireWoods LLP on Financial Institution Regulation
On April 25, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it will begin examining nonbank “covered persons” that it has determined pose risks to consumers. The CFPB has had this authority since its inception. The Dodd-Frank Act empowered the CFPB to examine this category of nonbanks, which might include fintech firms that are… Continue Reading

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