UNITED STATES OF AMERICA CONSUMER FINANCIAL

UNITED STATES OF AMERICA

CONSUMER FINANCIAL PROTECTION BUREAU

ADMINISTRATIVE PROCEEDING

File No. 2024-CFPB-0003

In the Matter of:

CONSENT ORDER

Western Benefits Group, LLC

The Consumer Financial Protection

Bureau (Bureau) has reviewed the

student-loan Debt Relief Services offered and provided by Western Benefits

Group, LLC (WBG) and has identified the following law violations:

(1) Respondent engaged in deceptive acts and practices in the marketing, sale, and

administration of Debt Relief Services (as defined below) in violation of the

Consumer Financial Protection Act of 2010 (CFPA), 12 U.S.C. §§ 5531(a),

5536(a)(1)(B); (2) Respondent engaged in deceptive telemarketing practices in

violation of the Telemarketing Sales Rule (TSR), 16 C.F.R. § 310.3(a)(2)(iii) and

(a)(2)(x); and (3) Respondent received Advance Fees for Debt Relief Services (as

defined below) in vi

olation of the TSR, 16 C.F.R. § 310.4(a)(5)(i). Under §§ 1053

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and 1055 of the CFPA, 12 U.S.C. §§ 5563, 5565, the Bureau issues this Consent

Order.

Jurisdiction

1. The Bureau has jurisdiction over this matter under (a) Sections 1053 and

1055 of the CFPA, 12 U.S.C. §§ 5563 and 5565; and (b) Section 6 of the

Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C.

§ 6105(d).

II.

Stipulation

2. Respondent has executed a “Stipulation and Consent to the Issuance of a

Consent Order,” dated May 13, 2024 (Stipulation), which is incorporated by

reference and is accepted by the Bureau. By this Stipulation, Respondent has

consented to the issuance of this Consent Order by the Bureau under

§§ 1053 and 1055 of the CFPA, 12 U.S.C. §§ 5563, 5565, without admitting

or denying any of the findings of fact or conclusions of law,

except that

Respondent admits the facts necessary to establish the Bureau’s jurisdiction

over Respondent and the subject matter of this action.

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III.

Definitions

3. The following definitions apply to this Consent Order:

a. “Advance Fee” means any fee or consideration requested or received for

any Debt Relief Service before:

1. the seller or telemarketer has renegotiated, settled, reduced, or

otherwise altered the terms of at least one debt under a settlement

agreement, debt-management plan,

or other such valid

contractual agreement executed by the customer;

the customer has made at least one payment under that

settlement agreement, debt-management plan, or other valid

contractual agreement between the customer and the creditor or

debt collector; and

to the extent that debts enrolled in a service are renegotiated,

settled, reduced, or otherwise altered individually, the fee or

consideration either:

bears the same proportional relationship to the total fee

for renegotiating, settling, reducing, or altering the terms

of the entire debt balance as the individual debt amount

bears to the entire debt amount; and the individual debt

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amount and the entire debt amount are those owed at the

time the debt was enrolled in the service; or

ii.

is a percentage of the amount saved as a result of the

renegotiation, settlement, reduction, or alteration. The

percentage charged cannot change from one individual

debt to another. The amount saved is the difference

between the amount owed at the time the debt was

enrolled in the service and the amount actually paid to

satisfy the debt.

b. “Affected Consumers” includes any consumer who paid Advance Fees to

WBG from January 1, 2016, through the Effective Date.

c. “Assisting Others” includes, but is not limited to:

i. consulting in any form whatsoever;

ii. providing paralegal or administrative support services;

iii. performing customer-service functions, including but not

limited to receiving or responding to consumer complaints

or running a call center to enroll consumers;

iv. formulating or providing, or arranging for the formulation or

provision of any advertising or marketing material;

v. providing names of, or assisting in the generation of,

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potential customers;

vi. performing marketing, billing, or payment services of any

kind; and

vii. acting or serving as an owner, officer, director, manager, or

principal of any entity.

“Debt Relief Service” means any program or service represented,

directly or by implication, to renegotiate, settle, or in any way alter

the terms of payment or other terms of the debt between a person and

one or more unsecured creditors or debt collectors, including, but not

limited to, a reduction in the balance, interest rate, or fees owed by a

person to an unsecured creditor or debt collector.

e. “Effective Date” means the date on which the Consent Order is entered

on the administrative docket.

f. “Enforcement Director” means the Assistant Director of the Office of

Enforcement for the Consumer Financial Protection Bureau, or his or her

delegate.

g. “Related Consumer Action” means a private action by or on behalf of

one or more consumers or an enforcement action by another

governmental agency brought against Respondent based on substantially

the same facts as described in Section IV of this Consent Order.

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h. “Relevant Period” includes from January 1, 2016 through the Effective

Date.

i. “Respondent”

means Western Benefits Group, LLC (WBG) and its

successors and assigns.

IV.

Bureau Findings and Conclusions

The Bureau finds the following:

4. Respondent is headquartered in Pleasanton, California and offered Debt

Relief Services.

5. Respondent is a “covered person” as that term is defined by 12 U.S.C.

§ 5481(6) because it engaged in the offering and sale of financial advisory

services. 12 U.S.C. § 5481(15)(A)(viii).

6. Respondent is a telemarketer and seller within the meaning of the TSR.

7. In January 2016, Respondent began to market, sell, and administer student-

loan Debt Relief Services to consumers.

8. During the Relevant Period, Respondent marketed its Debt Relief Services

through inbound interstate telemarketing.

9. Respondent employed lead generators to generate its inbound telemarketing

calls. Those lead generators marketed student-loan Debt Relief Services to

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consumers through email marketing campaigns and web campaigns using

the website “https://www.studentdebtrelief.us”.

10. During the Relevant Period, consumers who agreed to enroll in

Respondent’s Debt Relief Services were charged what Respondent called

“First Work Fees” of $99.95 to $159.95 as well as a $35 per month fee.

11. Respondent’s unlawful marketing and selling of Debt Relief Services during

the Relevant Period caused 5,970 Affected Consumers harm in the amount

of the total fees they paid, less any refunds, totaling $974,590.

Findings and Conclusions as to Respondent’s

Misrepresentations about its Debt Relief Services

12. Respondent’s marketing during the Relevant Period implied that it was

endorsed, sponsored, or affiliated with the United States Department of

Education. For example, one consumer complained that Respondent’s sales

agent “claimed the company had been contracted to help assist and educate

folks about the new Obama programs for student loan forgiveness and

payment reduction.”

Another consumer complained “this company is the

most unscrupulous and dishonest I have ever deal with . . . they pretend to be

associated with the student loan program and with [ED] but neither is true.”

13. Respondent was not, and is not, endorsed, sponsored, or affiliated with the

Department of Education.

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14. During the Relevant Period, Respondent represented to consumers that fees

paid by consumers to Respondent for its Debt Relief Services would be

applied towards paying off the consumers’ student loans.

15. In fact, fees paid by consumers to Respondent for its Debt Relief Services

were not used to pay off the consumers’ student loans.

16. During the Relevant Period, Respondent represented to consumers that it

would help consumers consolidate their loans, would help lower consumers’

monthly student-loan payments, or would help consumers achieve loan

forgiveness.

17. In many instances, however, Respondent did not help consumers consolidate

their loans and did not help consumers lower their monthly student-loan

payments or achieve loan forgiveness.

18. Respondent’s representations described in Paragraphs 12-17 were likely to

mislead consumers acting reasonably and were material. Thus, Respondent’s

representations constitute deceptive acts or practices in violation of sections

1031(a) and 1036(a)(1)(B) of the CFPA, 12 U.S.C. §§ 5531(a),

5536(a)(1)(B).

19.

Section 310.3(a)(2)(x) of the TSR states that it is a deceptive

telemarketing practice for any seller or telemarketer to misrepresent,

directly or by implication, any material aspect of any Debt Relief

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Service, including but not limited to, the amount of money or the

percentage of the debt amount that a consumer may save by using such

service. Section 310.3(a)(2)(iii) of the TSR prohibits sellers or

telemarketers from mispresenting, directly or by implication, “[a]ny

material aspect of the performance, efficacy, nature, or central

characteristics of goods or services that are the subject of a sales offer.”

20.

Respondent’s representations described in Paragraphs 12-17

misrepresented material aspects of a Debt Relief Service, namely that

Respondent

was endorsed, sponsored, or affiliated with the Department of

Education and that its services would help consumers consolidate their

student loans, would help lower consumers’ monthly student-loan payments,

or would help consumers achieve loan forgiveness,

and therefore violate

the TSR, 16 C.F.R.

§ 310.3(a)(2)(vii) and (x).

21.

Respondent’s representations described in Paragraphs 12-17

misrepresented material aspects of the performance, efficacy and nature of

its services, namely that it

was endorsed, sponsored, or affiliated with the

Department of Education and that its services would help consumers

consolidate their student loans, would help lower consumers’ monthly

student-loan payments, or would help consumers achieve loan forgiveness,

and therefore violate the TSR, 16 C.F.R.

§ 310.3(a)(2)(iii).

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Findings and Conclusions as to Respondent’s Charging of Advance Fees

22. Consumers who enrolled with Respondent were required to sign a contract

that required them to pay its fees in four installments.

23. Consumers were required to pay these fees regardless of whether

Respondent had achieved any results on their behalf.

24. For example, Respondent charged $99 to $199 for preparing and submitting

a forbearance application to the Department of Education (ED) on a

consumer’s behalf and collected monthly fees from consumers who enrolled

for its services.

25. Respondent collected these fees before renegotiating, settling, reducing, or

otherwise altering the terms of at least one of the consumer’s debts and

before a consumer had made at least one payment on such altered debt.

26.

Section 310.4(a)(5) of the TSR prohibits telemarketers or sellers of Debt

Relief Services from requesting or receiving payment of Advance Fees.

27.

As described in Paragraphs 22-26, Respondent violated the TSR during

the Relevant Period by requesting or receiving unlawful Advance Fees, 16

C.F.R. § 310.4(a)(5).

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ORDER

CONDUCT PROVISIONS

IT IS ORDERED, under §§ 1053 and 1055 of the CFPA, that:

28. Respondent and its officers, agents, servants, employees, and attorneys

who have actual notice of this Consent Order, whether acting directly or

indirectly, may not violate

sections 1031 and 1036 of the CFPA, 12

U.S.C. §§ 5531 and 5536 or the TSR, 16 C.F.R. pt. 310.

29.

All agreements related to Respondent’s student-loan Debt Relief

Services entered into through the Effective Date of this Consent

Order between any consumer and Respondent are rescinded and

shall be null and void effective immediately.

30.

Respondent and its officers, agents, directors, and employees,

whether acting directly or indirectly, shall immediately cease

assessing any fees and collecting or attempting to collect any fees from

consumers under the agreements described in the preceding

Paragraph.

31.

Within 45 days of the Effective Date, Respondent shall permanently

cease all operations, including all operations by which Respondent

markets, offers, provides, administers, or sells Debt Relief Services.

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32.

Respondent, whether acting directly or indirectly, is permanently

restrained from:

advertising, marketing, promoting, offering for sale, or

selling Debt Relief Services, or Assisting Others in the

advertising, marketing, promoting, offering for sale, or

selling of Debt Relief Services; or

receiving any remuneration or other consideration from,

holding any ownership interest in, providing services to, or

working in any capacity for any person engaged in or

Assisting Others in the advertising, marketing, promoting,

offering for sale, or selling Debt Relief Services.

Nothing in this Consent Order shall be read as an exception to this Paragraph.

VI.

Order to Pay Civil Money Penalty

IT IS FURTHER ORDERED that:

33. Under § 1055(c) of the CFPA, 12 U.S.C. § 5565(c), by reason of the

violations of law described in Section IV of this Consent Order, and taking

into account the factors in 12 U.S.C. § 5565(c)(3), Respondent must pay a

civil money penalty of $400,000 to the Bureau.

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34. Within 10 days of the Effective Date, Respondent must pay the civil

money penalty by wire transfer to the Bureau or to the Bureau’s agent in

compliance with the Bureau’s wiring instructions.

35. The civil money penalty paid under this Consent Order will be deposited

in the Civil Penalty Fund of the Bureau as required by § 1017(d) of the

CFPA, 12 U.S.C. § 5497(d).

36. Respondent must treat the civil money penalty paid under this Consent

Order as a penalty paid to the government. Regardless of how the Bureau

ultimately uses those funds, Respondent may not:

a. claim, assert, or apply for a tax deduction, tax credit, or

any other tax benefit for any civil money penalty paid under this Consent

Order; or

b. seek or accept, directly or indirectly, reimbursement or

indemnification from any source, including but not limited to payment

made under any insurance policy, with regard to any civil money penalty

paid under this Consent Order.

37. To preserve the deterrent effect of the civil money penalty in any Related

Consumer Action, Respondent may not argue that Respondent is entitled

to, nor may Respondent benefit by, any offset or reduction of any

compensatory monetary remedies imposed in the Related Consumer

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Action because of the civil money penalty paid in this action or because of

any payment that the Bureau makes from the Civil Penalty Fund. If the

court in any Related Consumer Action offsets or otherwise reduces the

amount of compensatory monetary remedies imposed against Respondent

based on the civil money penalty paid in this action or based on any

payment that the Bureau makes from the Civil Penalty Fund, Respondent

must, within 30 days after entry of a final order granting such offset or

reduction, notify the Bureau, and pay the amount of the offset or reduction

to the U.S. Treasury. Such a payment will not be considered an additional

civil money penalty and will not change the amount of the civil money

penalty imposed in this action.

VII.

Effect of Misrepresentation or Omission Regarding Financial Condition

IT IS FURTHER ORDERED that:

38. The Bureau’s agreement to issue this Consent Order and the civil money

penalty imposed in Section VI is expressly premised on the truthfulness,

accuracy, and completeness of Respondent’s sworn financial statement

submitted to the Bureau on October 21, 2020, and a sworn declaration

submitted to the Bureau on March 26, 2024. According to the declaration,

Western Benefits Group, LLC ceased all operations in March 2023.

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Respondent asserts its sworn statements are truthful, accurate, and

complete.

39. If Respondent has failed to disclose any material asset or if its sworn

statements contain any material misrepresentation or omission, then, by

reason of the violations of law described in Section IV of this Consent

Order, and taking into account the factors in 12 U.S.C. § 5565(c)(3),

Respondent will be required to pay an additional civil money penalty of

$5,000,000, which is the amount of the discount provided to account for

Respondent’s inability to pay a greater amount in determining the civil

money penalty imposed in Section VI. The Bureau can seek to enforce this

order for an additional civil money penalty as immediately due and

payable in any Federal district court for a district in which Respondent is

located or resides or is doing business this order.

VIII.

Additional Monetary Provisions

IT IS FURTHER ORDERED that:

40. In the event of any default on Respondent’s obligations to make payment

under this Consent Order, interest, computed under 28 U.S.C. § 1961, as

amended, will accrue on any outstanding amounts not paid from the date

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of default to the date of payment, and will immediately become due and

payable.

41. Respondent must relinquish all dominion, control, and title to the funds

paid to the fullest extent permitted by law and no part of the funds may be

returned to Respondent.

42. Under 31 U.S.C. § 7701, Respondent, unless it has already have done so,

must furnish to the Bureau its taxpayer-identification numbers, which may

be used for purposes of collecting and reporting on any delinquent amount

arising out of this Consent Order.

43. Within 30 days of the entry of a final judgment, consent order, or

settlement in a Related Consumer Action, Respondent must notify the

Enforcement Director of the final judgment, consent order, or settlement in

writing. That notification must indicate the amount of redress, if any, that

Respondent paid or is required to pay to consumers and describe the

consumers or classes of consumers to whom that redress has been or will

be paid.

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COMPLIANCE PROVISIONS

IX.

Reporting Requirements

IT IS FURTHER ORDERED that:

44. Respondent must notify the Bureau of any development that may affect

compliance obligations arising under this Consent Order, including but not

limited to a dissolution, assignment, sale, merger, or other action that

would result in the emergence of a successor company; the creation or

dissolution of a subsidiary, parent, or affiliate that engages in any acts or

practices subject to this Consent Order; the filing of any bankruptcy or

insolvency proceeding by or against Respondent; or a change in

Respondent’s name or address. Respondent must provide this notice, if

practicable, at least 30 days before the development, but in any case no

later than 14 days after the development.

45. Within 7 days of the Effective Date, Respondent must:

a. designate at least one telephone number and email,

physical, and postal addresses as points of contact that the Bureau may

use to communicate with Respondent;

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b. identify all businesses for which Respondent is the

majority owner, or that Respondent directly or indirectly controls, by all

of their names, telephone numbers, and physical, postal, email, and

Internet addresses; and

c. describe the activities of each such business, including

the products and services offered, and the means of advertising,

marketing, and sales.

46. Respondent must report any change in the information required to be

submitted under Paragraph 45 at least 30 days before the change or as soon

as practicable after the learning about the change, whichever is sooner.

Order Distribution and Acknowledgment

IT IS FURTHER ORDERED that:

47. Within 7 days of the Effective Date, Respondent must submit to the

Enforcement Director an acknowledgment of receipt of this Consent

Order, sworn under penalty of perjury.

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XI.

Recordkeeping

IT IS FURTHER ORDERED that:

48. Respondent must create and retain the following business records:

a. all documents and records necessary to demonstrate full

compliance with each provision of this Consent Order, including all

submissions to the Bureau.

XII.

Notices

IT IS FURTHER ORDERED that:

49. Unless otherwise directed in writing by the Bureau, Respondent must

provide all submissions, requests, communications, or other documents

relating to this Consent Order in writing, with the subject line, “In re

Western Benefits Group, LLC, File No. 2024-CFPB-0003,” and send

them by overnight courier or first-cla

ss mail to the below address and

contemporaneously by email to [email protected]:

Assistant Director for Enforcement

Consumer Financial Protection Bureau

ATTENTION: Office of Enforcement

1700 G Street, N.W.

Washington D.C. 20552

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XIII.

Cooperation with the Bureau

IT IS FURTHER ORDERED that:

50. Respondent must cooperate fully to help the Bureau determine the identity

and location of, and the amount of injury sustained by, each Affected

Consumer. Respondent must provide such information in its or its agents’

possession or control within 14 days of receiving a written request from

the Bureau.

51. Respondent must cooperate fully with the Bureau in this matter and in any

investigation related to or associated with the conduct described in Section

IV. Respondent must provide truthful and complete information, evidence,

and testimony.

XIV.

Compliance Monitoring

IT IS FURTHER ORDERED that:

52. Within 14 days of receipt of a written request from the Bureau,

Respondent must produce any requested information, which must be made

under penalty of perjury; provide sworn testimony; or produce documents.

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53. For purposes of this Section, the Bureau may communicate directly with

Respondent, unless Respondent retains counsel related to these

communications.

54. Respondent must permit Bureau representatives to interview any employee

or other person affiliated with Respondent who has agreed to such an

interview regarding: (a) this matter; (b) anything related to or associated

with the conduct described in Section IV; or (c) compliance with the

Consent Order. The person interviewed may have counsel present.

55. Nothing in this Consent Order will limit the Bureau’s lawful use of civil

investigative demands under 12 C.F.R. § 1080.6 or other compulsory

process.

XV.

Modifications to Non-Material Requirements

IT IS FURTHER ORDERED that:

56. Respondent may seek a modification to non-material requirements of this

Consent Order (e.g., reasonable extensions of time and changes to

reporting requirements) by submitting a written request to the Enforcement

Director.

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57. The Enforcement Director may, in his or her discretion, modify any non-

material requirements of this Consent Order (e.g., reasonable extensions of

time and changes to reporting requirements) if he or she determines good

cause justifies the modification. Any such modification by the

Enforcement Director must be in writing.

ADMINISTRATIVE PROVISIONS

XVI.

IT IS FURTHER ORDERED that:

58. The provisions of this Consent Order do not bar, estop, or otherwise

prevent the Bureau from taking any other action against Respondent,

except as described in Paragraph 59. Further, for the avoidance of doubt,

the provisions of this Consent Order do not bar, estop, or otherwise

prevent any other person or governmental agency from taking any action

against Respondent.

59. The Bureau releases and discharges Respondent from all potential liability

for law violations that the Bureau has or might have asserted based on the

practices described in Section IV of this Consent Order, to the extent such

practices occurred before the Effective Date and the Bureau knows about

them as of the Effective Date. The Bureau may use the practices described

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in this Consent Order in future enforcement actions against Respondent

and its affiliates, including, without limitation, to establish a pattern or

practice of violations or the continuation of a pattern or practice of

violations or to calculate the amount of any penalty. This release does not

preclude or affect any right of the Bureau to determine and ensure

compliance with the Consent Order, or to seek penalties for any violations

of the Consent Order.

60. This Consent Order is intended to be, and will be construed as, a final

Consent Order issued under § 1053 of the CFPA, 12 U.S.C. § 5563, and

expressly does not form, and may not be construed to form, a contract

binding the Bureau or the United States.

61. Except where this Consent Order expressly provides that its requirements

are permanent, all other provisions of this Consent Order will terminate on

the later of 5 years from the Effective Date or 5 years from the most recent

date that the Bureau initiates an action alleging any violation of the

Consent Order by Respondent, if such action is initiated within 5 years of

the Effective Date. If such action is dismissed or the relevant adjudicative

body rules that Respondent did not violate any provision of the Consent

Order, and the dismissal or ruling is either not appealed or upheld on

appeal, then the Consent Order will terminate as though the action had

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never been filed. The Consent Order will remain effective and enforceable

until such time, except to the extent that any provisions of this Consent

Order have been amended, suspended, waived, or terminated in writing by

the Bureau or its designated agent.

62. Calculation of time limitations will run from the Effective Date and be

based on calendar days, unless otherwise noted.

63. Should Respondent seek to transfer or assign all or part of its operations

that are subject to this Consent Order, Respondent must, as a condition of

sale, obtain the written agreement of the transferee or assignee to comply

with all applicable provisions of this Consent Order.

64. The provisions of this Consent Order will be enforceable by the Bureau.

For any violation of this Consent Order, the Bureau may impose the

maximum amount of civil money penalties allowed under §1055(c) of the

CFPA, 12 U.S.C. § 5565(c). In connection with any attempt by the Bureau

to enforce this Consent Order in federal district court, the Bureau may

serve Respondent wherever Respondent may be found and Respondent

may not contest that court’s personal jurisdiction over Respondent.

65. This Consent Order and the accompanying Stipulation contain the

complete agreement between the parties. The parties have made no

promises, representations, or warranties other than what is contained in

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this Consent Order and the accompanying Stipulation. This Consent Order

and the accompanying Stipulation supersede any prior oral or written

communications, discussions, or understandings.

66. Nothing in this Consent Order or the accompanying Stipulation may be

construed as allowing Respondent, its officers, or employees to violate any

law, rule, or regulation.

IT IS SO ORDERED, this 20th day of May, 2024.

____________________________

Rohit Chopra

Director

Consumer Financial Protection Bureau

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