National Collegiate Student Loan Trusts
On September 18, 2017, the Bureau filed a complaint and proposed consent judgment against the National Collegiate Student Loan Trusts (Trusts). On the same day, the Bureau issued a consent order against Transworld Systems (TSI), the Trusts’ debt collection subservicer. The Bureau’s complaint, amended in April 2021, alleges that the Trusts engaged in deceptive and unfair acts and practices in violation of the Consumer Financial Protection Act of 2010 (CFPA) by bringing debt collection lawsuits for private student loan debt that they could not prove was owed or was too old to sue over; filing false and misleading affidavits or providing false and misleading testimony; and falsely claiming that affidavits were sworn before a notary. Soon after the Bureau’s filing, several entities moved to intervene to object to the proposed consent judgment. The court granted the intervention motions, and on May 31, 2020, the court denied the Bureau’s motion to approve the proposed consent judgment filed with the original complaint. On December 13, 2021, the court denied defendants' motion to dismiss the Bureau’s amended complaint, and on February 11, 2022, the court certified two holdings in its opinion for interlocutory appeal to the Third Circuit and stayed the matter. On April 29, 2022, the Third Circuit granted the petition to appeal. On March 19, 2024, the Third Circuit held that the Trusts are covered persons subject to the CFPA’s enforcement authority and the Bureau did not need to ratify its action before the statute of limitations had run. On January 16, 2025, the Bureau filed a proposed stipulated final judgment which, if entered by the court, would bring the Trusts into compliance with the law, bar the Trusts from collecting on certain debt that is the subject of the lawsuit, and require the Trusts to pay $2,250,000 to the Bureau for redress to affected consumers.
Related documents
Opinion on Interlocutory Appeal
Proposed Stipulated Final Judgment and Order