Share on LinkedInShare on LinkedIn

ARTICLE · 21 SEPTEMBER 2023

CFPB Details Concerns Over Tuition Payment Plan Practices At Higher Education Institutions

Cooley LLP
Explore more from Cooley LLP

On September 14, 2023, the Consumer Financial Protection Bureau (CFPB) released a report on financial risks to students associated with school-issued tuition payment plans. Although the report acknowledges...

United StatesConsumer Protection
H. Joshua Kotin
H. Joshua Kotin
Katherine Lee Carey
Katherine Lee Carey
Jay Vaughan
Jay Vaughan
Author LinkedIn connections

On September 14, 2023, the Consumer Financial Protection Bureau (CFPB) released a report on financial risks to students associated with school-issued tuition payment plans. Although the report acknowledges that many tuition payment plans are free of interest, the bureau cautions that inadequate disclosures, opaque product terms and collection practices create the potential for harm to students. The report, which draws its findings from the CFPB's review of payment plan terms from nearly 450 higher education institutions, represents one more step in the bureau's initiative to examine and oversee institutional lending and servicing practices.

Using real-life school examples, the bureau identifies a number of origination and servicing practices it believes put students at financial risk

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

New York City’s Click-to-Cancel Rule: What Businesses Need To Know

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t
United StatesConsumer Protection
Skadden, Arps, Slate, Meagher & Flom LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Article

Amway To Pay $225 Million Over Alleged False Earnings Claims And Fabricated Sales

The FTC and Washington state secured a record $225 million settlement from Amway and affiliated groups over allegations they misled recruits about earnings potential while pressuring them to buy products with little retail opportunity. The complaint reveals that over three-quarters of U.S. product volume was sold to IBOs themselves rather than retail customers, with fabricated sales reporting masking the recruitment-driven model. The settlement's injunctive provisions establish new standards for earnings cl
United StatesConsumer Protection
Frankfurt Kurnit Klein & Selz PC
Frankfurt Kurnit Klein & Selz PC
Article

FTC Asks Whether Platform Ad Tools Fuel Impersonation Scams

The Federal Trade Commission is exploring whether digital platforms should bear greater responsibility for preventing impersonation ads that falsely pose as legitimate businesses or government agencies. Through an Advance Notice of Proposed Rulemaking, the agency seeks public input on potential amendments to its existing Impersonation Rule, examining how ad-optimization tools and platform practices...
United StatesConsumer Protection
Greenberg Traurig
Greenberg Traurig
Article

The Coming State-Law Litigation Wave Of 2026-27: “Subscription Trap” Class Actions

State-law class actions targeting automatic renewal and subscription practices are accelerating, creating significant litigation risk for companies that rely on recurring revenue models. Recent settlements demonstrate that even technical compliance failures can lead to seven-figure exposure, with California, Illinois, and Virginia statutes driving the most aggressive litigation.
United StatesConsumer Protection
Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
Article

NCAA Enjoined From Enforcing New Fifth-Year Eligibility Rule

A federal court has issued a nationwide injunction blocking the NCAA from enforcing its new five-year eligibility rule against Division I athletes who graduated high school in 2022. The ruling creates immediate compliance challenges for athletic departments as they navigate roster management, revenue-sharing caps, and potential penalties while the NCAA appeals the decision.
United StatesConsumer Protection
Buchanan Ingersoll & Rooney
Buchanan Ingersoll & Rooney
Article

Virginia’s Initial Draft Of Adult-use Marijuana Regulations – What You Should Know And What Questions Remain

Virginia's Cannabis Control Authority has released its initial draft of adult-use marijuana regulations, outlining application fees, license caps, and the approval process for the state's anticipated July 2027 launch of recreational cannabis sales. While the draft provides crucial details on licensing requirements and ownership restrictions, significant questions remain about the application timeline and evaluation criteria that will determine which entities receive coveted permits.
United StatesConsumer Protection
Foley Hoag LLP
Foley Hoag LLP
Article

Wiley Consumer Protection Download (September 15, 2026)

This comprehensive newsletter covers recent federal and state consumer protection enforcement actions, including FTC settlements with payment processors, state attorney general lawsuits against tech companies, and advertising challenge decisions. The update examines regulatory developments such as the FTC's withdrawal of its 2021 health app breach policy statement and the launch of a new rule guidance program, while highlighting emerging enforcement priorities around AI-powered advertising, personalized
United StatesConsumer Protection
Wiley Rein
Wiley Rein
Article

Personalized Pricing Scrutiny Expands As FTC Previews Activity And Cities Join States In Weighing New Restrictions

Regulators and legislators have been keenly focused on personalized pricing for several years, and the degree of interest has increased significantly in recent weeks. For example, Seattle passed a law banning the use of personalized pricing in certain grocery sales, a key New York City official publicly advocated for adoption of a multi-industry proposal, and the Federal Trade Commission (FTC) Chairman previewed that more agency action is on the way.
United StatesConsumer Protection
Wiley Rein
Wiley Rein