"permanently bans BloomTech from all consumer-lending activities and bans Allred from any student-lending activities for ten years"
"ordering BloomTech and Allred to cease collecting payments on income share loans for graduates who did not have a qualifying job, eliminate finance changes for certain agreements, and allow students the option to withdraw without penalty"
This order seems like a death sentence. If ISAs are defined as consumer-lending, which the CFPB clearly says they are, BloomTech cannot recruit new customers. And they cannot collect on 50% of their outstanding loans (if the quoted internal placement rate is true).
The CFPB, like every federal regulatory agency, has only direct civil enforcement powers.
They refer criminal matters to the Department of Justice, which usually takes significantly longer before handing down charges, and does not usually disclose the existence of an open investigation until and unless it issues an indictment.
The CEO should go to prison. Obviously. This is what's wrong with our society -- too much upside to being dishonest, very little downside. People with integrity are practically punished for it.
