Attorney No. 99000
STATE OF ILLINOIS
IN THE CIRCUIT COURT OF COOK COUNTY
COUNTY DEPARTMENT - CHANCERY DIVISION
THE PEOPLE OF THE STATE OF
ILLINOIS,
Plaintiff,
Case No. 15 CH 07254
Judge Rita Novak
Calendar 09

v.
NATIONWIDE STUDENT AID, LLC, an
Illinois Limited Liability Company not in
good standing;
JUSTIN KRANZLER, individually, and as
a member of NATIONWIDE STUDENT
AID, LLC;
BRIAN MISHOULAM, individually, and
as a member of NATIONWIDE
STUDENT AID, LLC,
Defendants.

FIRST AMENDED COMPLAINT FOR INJUNCTIVE AND OTHER RELIEF
NOW COMES the Plaintiff, THE PEOPLE OF THE STATE OF ILLINOIS, by Lisa
Madigan, Attorney General of the State of Illinois, and brings this action for injunctive and other
relief against Defendant NATIONWIDE STUDENT AID, LLC ("NATIONWIDE"), an Illinois
limited liability company not in good standing, Defendant JUSTIN KRANZLER
("KRANZLER"), individually, and as a principal and member of NATIONWIDE, and
Defendant BRIAN MISHOULAM ("MISHOULAM"), individually, and as a principal and
member of NATIONWIDE, for violations of the Consumer Fraud and Deceptive Business
Practices Act ("Consumer Fraud Act"), 815 ILCS 505/1 et seq., the Credit Services

1

 Organizations Act, 815 ILCS 605/1 et seq., and the Debt Settlement Consumer Protection Act
(“Debt Settlement Act”), 225 ILCS 429/1 et seq.
NATURE OF THE CASE
1. Nationwide Student Aid, LLC is a student loan debt settlement and relief company that
advertises a wide-range of student loan relief services, such as the ability to lower monthly
payments, remove wage garnishments, get loans out of default, and negotiate student loan debt
settlements and adjustments.
2. Yet, in truth and in fact, Nationwide does not have the capability to provide the student
loan relief services advertised, and does little more than complete applications to federal
borrower assistance programs that are already available to consumers for free through the United
States Department of Education.
3. Employing high-pressure sales tactics, Nationwide targets financially vulnerable
consumers with student loan debt in Illinois and throughout the United States.
PUBLIC INTEREST
4. The Illinois Attorney General believes this action to be in the public interest of the citizens
of the State of Illinois and brings this lawsuit pursuant to the Consumer Fraud Act, the Credit
Services Organizations Act, and the Debt Settlement Act. See 815 ILCS 505/7(a); 815 ILCS
605/12; 225 ILCS 429/85.
JURISDICTION AND VENUE
5. This First Amended Complaint for Injunctive and Other Relief (hereinafter “Complaint”)
is brought for and on behalf of THE PEOPLE OF THE STATE OF ILLINOIS, by Lisa Madigan,
Attorney General of the State of Illinois, pursuant to the provisions of the Consumer Fraud Act,
815 ILCS 505/1 et seq., the Credit Services Organizations Act, 815 ILCS 605/1 et seq., and the
Debt Settlement Act, 225 ILCS 429/1 et seq.
2

 6. Venue for this action properly lies in Cook County, Illinois, in that Defendants are
located and do business in Cook County. See 735 ILCS 5/2-101.
PARTIES
7. Plaintiff, the Illinois Attorney General, on behalf of THE PEOPLE OF THE STATE OF
ILLINOIS, is authorized to enforce the Consumer Fraud Act, the Credit Services Organizations
Act, and the Debt Settlement Act. 815 ILCS 505/7(a); 815 ILCS 605/12; 225 ILCS 429/85.
8. NATIONWIDE is an Illinois limited liability company not in good standing that provides
student loan debt settlement and relief services. Its principal place of business is located at 333
North Oakley Boulevard, Suite 308, Chicago, Illinois. NATIONWIDE was formed by
Defendants KRANZLER and MISHOULAM on February 17, 2013.
9. Defendant KRANZLER, of Chicago, Illinois, is being sued individually, and in his
professional capacity as a principal and member of NATIONWIDE. Together with Defendant
MISHOULAM, Defendant KRANZLER formed NATIONWIDE on February 17, 2013. His
principal office or place of business is the same as that of NATIONWIDE, located at 333 North
Oakley Boulevard, Suite 308, Chicago, Illinois.
10. At all times material to this Complaint, Defendant KRANZLER individually, or in
concert with others, formulated, directed, controlled, had the authority to control, or participated
in the acts and practices of NATIONWIDE, including the acts or practices set forth in this
Complaint. Thus, for the purpose of this Complaint, any reference to the acts and practices of
NATIONWIDE or said company’s officers, owners, directors, employees, or their agents, are
attributable as to the individual acts of Defendant KRANZLER.
11. To adhere to the fiction of separate existence between Defendant NATIONWIDE and
Defendant KRANZLER would serve to sanction fraud and to promote injustice.

3

 12. Defendant MISHOULAM, of Chicago, Illinois, is being sued individually, and in his
professional capacity as a principal and member of NATIONWIDE. Together with Defendant
KRANZLER, Defendant MISHOULAM formed NATIONWIDE on February 17, 2013. His
principal office or place of business is the same as that of NATIONWIDE, located at 333 North
Oakley Boulevard, Suite 308, Chicago, Illinois.
13. At all times material to this Complaint, Defendant MISHOULAM individually, or in
concert with others, formulated, directed, controlled, had the authority to control, or participated
in the acts and practices of NATIONWIDE, including the acts or practices set forth in this
Complaint. Thus, for the purpose of this Complaint, any reference to the acts and practices of
NATIONWIDE or said company’s officers, owners, directors, employees, or their agents, are
attributable as to the individual acts of Defendant MISHOULAM.
14. To adhere to the fiction of separate existence between Defendant NATIONWIDE and
Defendant MISHOULAM would serve to sanction fraud and to promote injustice.
15. For purposes of this Complaint, NATIONWIDE and Defendants KRANZLER and
MISHOULAM, their employees, agents, representatives, all persons or entities directly or
indirectly under their control, and all persons or entities acting in concert or in active
participation with NATIONWIDE and Defendants KRANZLER and MISHOULAM, shall be
collectively referred to as “Defendants.”
TRADE AND COMMERCE
16. The Consumer Fraud Act defines “trade” and “commerce” as follows:
The terms ‘trade’ and ‘commerce’ mean the advertising, offering
for sale, sale, or distribution of any services and any property,
tangible or intangible, real, personal, or mixed, and any other
article, commodity, or thing of value wherever situated, and shall
include any trade or commerce directly or indirectly affecting the
people of this State.
4

 815 ILCS 505/1(f).
17. At all times relevant to this Complaint, Defendants engaged in trade and commerce in the
State of Illinois by advertising, soliciting, offering for sale, and selling student loan debt
settlement and relief services to consumers in Illinois and elsewhere.
BACKGROUND
18. Federal student loans, as administered by the United States Department of Education
(“USDOE”), include a consolidation option that allows borrowers to combine multiple
outstanding loans into a single loan—a “Direct Consolidation Loan”—simplifying the repayment
process.
19. Opting for or against consolidating federal student loans requires borrowers to consider
their financial circumstances.
20. Consolidating federal student loans into a Direct Consolidation Loan may, for example,
afford borrowers access to alternative repayment plans, conversion from variable-interest to a
fixed-rate loan, and options to modify monthly repayment amounts.
21. However, borrowers also forfeit the benefits of original loans, such as interest rate
discounts, principal rebates, and loan cancellation benefits, when consolidating. Lower monthly
payments may also lead to longer terms of maturity, causing borrowers to ultimately pay more in
interest.
22. Consolidating federal student loans also require borrowers to carefully choose from five
different repayment plans:
a. a standard repayment plan, where consumers pay a fixed amount until the loan is
paid in full;
b. a graduated repayment plan, where monthly payments increase every two years;
c. an extended payment plan, where consumers have 25 years to pay the loan;
5

 d. an income-contingent repayment plan, where monthly payments are based on
yearly income and other factors; and
e. an income-based repayment plan for borrowers with a financial hardship.
23. Borrowers may apply to consolidate their federal student loans into a Direct
Consolidation Loan, by submitting a Direct Consolidation Loan Application and Promissory
Note (“Direct Consolidation Loan Application”) to the USDOE.
24. The Application, and assistance to complete the process, is available from the USDOE at
no cost.
DEFENDANTS’ DECEPTIVE BUSINESS PRACTICES
Nationwide’s Student Loan Debt Relief Business Model
25. NATIONWIDE is a for-profit student loan debt relief company that, since at least March
2013, has advertised, solicited, offered for sale, and sold student loan debt settlement and relief
services in Illinois and in other states.
26. KRANZLER and MISHOULAM formed NATIONWIDE in or around February 2013,
and both serve as principals and members of NATIONWIDE.
27. KRANZLER and MISHOULAM participate directly in NATIONWIDE’s day-to-day
operations, including managing employees, making sales calls, providing customer service, and
reviewing and responding to consumer complaints.
28. NATIONWIDE targets financially vulnerable consumers with unsecured student loan
debt by advertising the benefits of federal borrower assistance programs as its own.
29. Despite advertising wide-ranging student loan relief services, such as the ability to secure
lower student loan payments, negotiate student loan debt settlements or adjustments, and
improve credit scores, NATIONWIDE does not have such capabilities.
30. Positioning itself between consumers and the USDOE, NATIONWIDE charges high
6

 upfront fees, ranging from $650 to $1,250, to do little more than complete applications to federal
borrower assistance programs that are already available to consumers free of charge from the
USDOE.
31. NATIONWIDE advertises that it negotiates student loan debt settlements and
adjustments, but fail, as a “debt settlement provider” in Illinois, to comply with the requirements
of the Debt Settlement Act, 225 ILCS 429/1 et seq.
32. At all times material to this Complaint, NATIONWIDE has failed to possess a license as
a Debt Settlement Provider in the State of Illinois, as required by the Debt Settlement Act, 225
ILCS 429/15, while advertising that it can secure student loan debt settlements and adjustments.
33. At all times material to this Complaint, NATIONWIDE has failed to register as a “credit
services organization” in Illinois, as required by the Credit Services Organizations Act, 815
ILCS 605/9, while advertising that it can improve consumers’ credit scores.
34. NATIONWIDE has an “F” rating on the Better Business Bureau of Chicago (“BBB”).
Nationwide’s Deceptive Advertising
35. NATIONWIDE advertises wide-ranging student loan relief services, but does little more
than to complete applications to federal borrower assistance programs.
36. To solicit business for its student loan debt settlement and relief services, NATIONWIDE
advertise through television and radio advertisements that air in Illinois; through internet video
advertisements viewable in Illinois; through its website, located at
www.nationwidestudentaid.com; and through its Facebook page.
37. NATIONWIDE advertises on its website the following separate and discrete services:
a. “Get Student Loans Out of Default”;
b. “Stop Wage Garnishment”;

7

 c. “Prevent Tax Liens”;
d. “Reduce Your Monthly Payments!”;
e. “Assist With Federal/Private Program Applications”;
f. “Student Loan Consolidation”;
g. “Negotiate Directly with Loan Holders”; and
h. “Negotiate settlements and or adjustments.”
38. Yet, despite advertising that it can stop wage garnishments, NATIONWIDE does not
negotiate the removal or settlement of wage garnishments, and only performs services to
complete Direct Consolidation Loan Applications.
39. Despite advertising that it can prevent tax liens, NATIONWIDE does not negotiate for an
agreement or settlement that would prevent the Internal Revenue Service from imposing a tax
lien, and only performs services to complete Direct Consolidation Loan Applications.
40. NATIONWIDE advertises that it can reduce student loan payments, without ability to
affect the determination of whether a consumer will get lowered monthly payments when
consumers consolidate their federal student loans, as that determination rests with the USDOE.
41. Despite advertising, on its Facebook page, that it will “Improve your Credit Score,”
NATIONWIDE does no work to repair, modify, or correct a consumer’s credit report.
42. Despite representing in television and internet video advertisements that consumers “may
be eligible for loan forgiveness, for some, or even all of your student loans debt is forgiven
completely,” in practice, NATIONWIDE does no work to negotiate a reduction or settlement in
student loan principal with creditors.
43. NATIONWIDE advertises, in television and internet video advertisements, that it
“stop[s] the harassing phone calls,” “stop[s] the wage garnishments,” and “stop[s] the tax liens,”

8

 when in truth and in fact, NATIONWIDE only performs services to complete Direct
Consolidation Loan Applications.
44. NATIONWIDE advertises, in television and internet video advertisements, that if
consumers do not qualify for its programs, consumers “don’t pay a penny.”
45. However, after requiring consumers to pay high upfront fees for its services,
NATIONWIDE does not provide requested refunds after failing to obtain the student loan debt
relief promised.
46. While holding itself out as offering wide-ranging student relief services on its websites
and advertisements, NATIONWIDE fails to disclose that the only service it will actually provide
is to complete Direct Consolidation Loan Applications.
47. Moreover, NATIONWIDE fails to disclose that USDOE provides the same service at no
cost.
48. On its websites and advertisements, NATIONWIDE fails to disclose its fees, terms and
conditions, and refund policy for its student loan relief services; NATIONWIDE communicates
its terms and conditions only after consumers pay.
Nationwide’s High Pressure Sales Pitch
5. To induce consumers to pay its high upfront fees, NATIONWIDE employ a highpressure sales pitch to create a false sense of urgency to purchase its services.
6. On its website and in its advertisements, NATIONWIDE directs consumers to contact its
salesmen through a toll-free telephone number or to contact NATIONWIDE by email.
7. When consumers call to inquire about its student loan debt settlement and relief services,
NATIONWIDE’s sales representatives, including KRANZLER and MISHOULAM, employ a
high-pressure sales pitch to induce consumers to pay upfront fees.

9

 8. NATIONWIDE’s sales representatives begin by asking consumers about the status of
their student loans.
9. KRANZLER and MISHOULAM provide sales representatives with responsive scripts
when consumers report their student loan statuses.
10. If consumers report being in default, or falling behind in payments, NATIONWIDE
instructs its sales representatives to respond as follows:
Wow . . . , are you currently getting garnished yet? Are they
seizing your tax refund? We have to get this taken care of
immediately before they start taking enforced collection activity
against you because a garnishment could be right around the corner
– and prevention is the best cure. I don’t know if you realize . . .
but legally, right now, BECAUSE YOU’RE IN DEFAULT!, the
collection agency appointed by the federal government reserves the
right to immediately SIEZE your tax refund AND garnish you’re
[sic] wages in the amount of 15-25 percent depending on how
many loans you’ve defaulted on. Ok- Now, SECONDLY – and
MORE IMPORTANTLY, they also reserve the right issue
collection fees [sic] in the amount of 18.5 to 25% . . .
11. NATIONWIDE then instructs its sales representatives to close their sales pitch to
consumers who report being in default, by saying: “Now we can negotiate that completely, but
WE HAVE TO MOVE VERY QUICKLY HERE TODAY AND GET YOU SET UP
APPROPRIATELY SO THIS GET’S TAKEN CARE OF IMMDIATLEY [sic] as this is
EXTREMELY time sensitive!”
12. If consumers report a current wage garnishment, NATIONWIDE instructs its sales
representatives to respond as follows:
Wow . . . , how much are they garnishing you each paycheck?
That’s terrible! Had you contacted us sooner, you definitely
wouldn’t be in this situation! But it’s not too late! We have to get
your file started immediately and get you back in good standing so
we can lift the garnishment and potentially negotiate down the
collection fee’s [sic]. If you owe . . . they reserve the right to add
collection fee’s in the amount [sic] of 18.5-25% . . . [a]nd the
amount that they garnish does not actually all go to your principle,
10

 but towards their fee’s so you will hardly ever see your principal
go down.”
13. NATIONWIDE then instructs sales representatives to close their sales pitch to consumers
who report a wage garnishment, by saying: “That being said, we have to get going on this
immediately!! The sooner we start, the sooner we can stop the $ from being garnished every pay
period!!”
14. If consumers report that they are current on their student loan payments, NATIONWIDE
instructs its sales representatives to still “sell with level of urgency to get help immediately!”
15. NATIONWIDE sale representatives then require consumers to disclose their dates-ofbirth, social security numbers, and personal pins to the National Student Loan Data System
(“NSLDS”).
16. The NSLDS is a database maintained by the USDOE that contains personal and financial
information related to a consumer’s federal student loans. Access to the NSLDS, as protected by
the Privacy Act of 1974, 5 U.S.C. § 552a, is only allowed through specific access granted by the
USDOE.
17. NATIONWIDE instructs its sales representatives to access the NSLDS while still
speaking with consumers over the telephone, using consumers’ log-in information, to determine
the level of consumers’ federal student loan debt.
18. NATIONWIDE’s training materials then instruct its sales representatives to tell
consumers that, by purchasing NATIONWIDE’s student loan relief services, NATIONWIDE
will secure for them a lower monthly student loan payment.
19. NATIONWIDE sales representatives then quote consumers a specific monthly payment
they could secure by purchasing NATIONWIDE’s services.
20. To close its sales pitch, NATIONWIDE’s training manual then instructs sales
11

 representatives to tell consumers that “this is EXTREMELY time sensitive,” and by paying an
upfront fee, NATIONWIDE “will have the documents sent out immediately to get this [specific
monthly payment] locked in ASAP . . .”
21. Sales representatives employ NATIONWIDE’s responsive scripts when making their
sales pitch to consumers.
22. After consumers agree to purchase its student loan relief services, NATIONWIDE
requires consumers to pay over the telephone by debit or credit card. NATIONWIDE
immediately charge consumers’ accounts.
23. NATIONWIDE sales representatives fail to give consumers, in oral and written form, a
copy of the “Consumer Notice and Rights Form" provided under Section 115(c) of the Debt
Settlement Act, 225 ILCS 429/115(c), prior to accepting payment.
24. Prior to requiring payment and while advertising that it repairs credit, NATIONWIDE
additionally fails to provide consumers a written statement required under the Credit Services
Organizations Act, 815 ILCS 605/6, providing information such as a complete and detailed
description of the services to be performed, and the total cost to consumers for such services.
25. NATIONWIDE fails to disclose during its telephone sales pitch that, despite advertising
robust student loan relief services, NATIONWIDE only provide services to complete
applications for Direct Consolidation Loans.
26. In some instances, NATIONWIDE’s sales representatives will tell a consumer that they
will consolidate the consumer’s student loans, when they cannot or will not.
27. NATIONWIDE fails to disclose during its telephone sales pitch that Direct Loan
Consolidation Applications are available at no cost from the USDOE.
28. NATIONWIDE represents to consumers that it will begin their so-called student loan

12

 relief services immediately, when in practice, it does not commence work until consumers have
paid a substantial portion of their upfront fee balance.
29. Once a consumer agrees to purchase NATIONWIDE’s student loan relief services,
KRANZLER and MISHOULAM instruct their sales representatives and “underwriters” to
collect documents from consumers to file with the DOE.
30. After the sales representatives and underwriters finish collecting document towards a
consumer’s file, they provide the documents to KRANZLER and MISHOULAM.
31. KRANZLER and MISHOULAM, or employees at their direction, then file consumers’
documents with the DOE towards Direct Consolidation Loans.
Nationwide’s Student Loan Debt Relief Contracts
32. NATIONWIDE sends its student loan relief contracts (“Service Agreement”) to
consumers only after consumers have paid at least some of its required upfront fees. See Service
Agreement attached hereto as Plaintiff's Exhibit 1.
33. NATIONWIDE’s Service Agreement fails to include many of the elements required by
the Debt Settlement Act, 225 ILCS 429/120, such as a statement of the proposed savings goals
for the consumer, a written individualized financial analysis, or contents of the "Consumer
Notice and Rights Form" provided under Section 115(c) of the Act, 225 ILCS 429/115(c).
34. NATIONWIDE’s Service Agreement further fails to include the elements required by the
Credit Services Organization Act, 815 ILCS 605/7, such as:
a. a statement that "You, the buyer, may cancel this contract at any time
before midnight of the third day after the date of the transaction. See the
attached notice of cancellation form for an explanation of this right"; and
b. two easily detachable copies of the “Notice of Cancellation,” as required

13

 by 815 ILCS 605/7(b).
35. NATIONWIDE represents in its Service Agreement that it “will advise Client in his/her
efforts to negotiate to remove wage garnishment(s) and/or tax offset(s),” while in practice,
NATIONWIDE has no ability to negotiate the removal of wage garnishments obtained by
independent debt collectors or law firms on behalf of private creditors.
36. NATIONWIDE represents in its Service Agreement that it “negotiat[es] arrangements to
resolve the Client’s Federal student loan debt(s)/credit situation,” while in practice,
NATIONWIDE only performs work to complete Direct Consolidation Loan Applications, and in
no way “negotiates” anything.
37. NATIONWIDE also fails to provide consumers with a form containing the elements
required by Section 135 of the Debt Settlement Act, 225 ILCS 429/135, that clearly and
conspicuously discloses how consumers can cancel the contract, including applicable addresses,
telephone numbers, facsimile numbers, and electronic mail addresses consumers can use to
cancel.
Nationwide’s High Upfront Service Fees
38. NATIONWIDE charges $650 to $1,250 in upfront fees for their student loan relief
services.
39. When consumers are unable to immediately pay the full fee, NATIONWIDE requires
consumers to pay by installments. NATIONWIDE still requires consumers who pay by
installments to make their first payment during its telephone sales pitch.
40. When consumers pay NATIONWIDE by installments, it does no work until all or most
of the required fee is paid, in most cases.
41. NATIONWIDE’s refund policy in their Service Agreement provides that “Any amount

14

 paid prior to cancellation is deemed non-refundable,” and that “[a]ny and all refunds will be
made at the sole discretion of Nationwide Student Aid.”
CONSUMER ILLUSTRATIONS
42. Consumers have filed complaints against NATIONWIDE with the Office of the Illinois
Attorney General, the BBB, the Federal Trade Commission (“FTC”), and other government
entities. Therefore, the following example of a consumer experience is simply an illustration and
should not be construed as the only instance in which a consumer was harmed, or could
potentially be harmed by NATIONWIDE. Plaintiff reserves the right to prove that consumers
other than those who have complained to the Office of the Illinois Attorney General, the BBB, of
the FTC have been injured because of NATIONWIDE’s unlawful practices.
Patricia Aden
43. Patricia Aden resides in Rockford, Illinois, located in Winnebago County.
44. In or around November 2013, Patricia learned about NATIONWIDE when she heard a
radio advertisement playing in Illinois, promoting NATIONWIDE’s student loan relief services.
45. Patricia then contacted NATIONWIDE, calling the toll free number in the radio
advertisement to inquire about its student loan debt relief services.
46. During their sales pitch, NATIONWIDE’s telephone sales representative represented to
Patricia that he would lower her monthly student loan debt payments to as low as $50 per month.
47. In reliance upon its representation to lower her monthly student loan payment, Patricia
agreed to purchase NATIONWIDE’s student loan relief services, which Patricia believed would
be the refinancing of her student loans by NATIONWIDE.
48. NATIONWIDE required Patricia to pay $650 in upfront fees—designated by
NATIONWIDE as “closing costs”—for its student loan services.

15

 49. Because Patricia could not pay the full $650 in one payment, NATIONWIDE required
Patricia to pay bi-monthly installments, taken from Patricia’s checking account by
NATIONWIDE through automatic withdrawals.
50. In our around early January 2014, and only after taking several payments from Patricia,
NATIONWIDE sent Patricia the Service Agreement.
51. Patricia signed NATIONWIDE’s Service Agreement on January 8, 2014, and returned it
to the Defendant.
52. In or around February 2014, Patricia completed her payments, totaling $650, to
NATIONWIDE.
53. Only then, after Patricia had paid in full, did NATIONWIDE contact Patricia and request
that she submit her financial records for NATIONWIDE’s review.
54. After reviewing her financial records, NATIONWIDE then informed Patricia that it could
not secure the lower student loan payment rate promised during NATIONWIDE’s sales pitch.
55. On or around March 24, 2014, Patricia then sent NATIONWIDE a letter to cancel its
services, and to request a refund.
56. NATIONWIDE refused to issue Patricia a refund.
57. On or around April 7, 2014, Patricia then filed a complaint against NATIONWIDE with
the BBB to, once again, request a refund.
58. NATIONWIDE still did not give Patricia a refund.
59. As of the date of this Complaint, NATIONWIDE has failed to perform any student loan
debt relief services for Patricia, as promised, and has not given her a refund.
Jean Marriner
60. Jean Marriner resides in Hampton, Virginia.

16

 61. In or around June 2013, Jean sent Defendants an inquiry through NATIONWIDE’s
website, inquiring about Defendants’ student loan debt relief services.
62. Responding to her inquiry, KRANZLER called Jean to advertise NATIONWIDE’s
services.
63. In or around July 2013, Jean agreed to purchase NATIONWIDE’s student loan debt relief
services.
64. To do so, KRANZLER required Jean to pay weekly installments of $100 every two
weeks until she paid Defendants a total of $1,000, before NATIONWIDE would consolidate her
student loans. NATIONWIDE began taking $100 installments from Jean’s checking account at
the time of this call in or around July 2013.
65. Jean then called her student loan servicer to inform them that NATIONWIDE was
working on her behalf to consolidate her student loans.
66. Jean’s student loan servicer, however, informed her that her student loans were already
consolidated, and could not be consolidated further.
67. On or around September 16, 2013, Jean called KRANZLER and informed him that her
loans were already consolidated, and could not be consolidated further.
68. KRANZLER responded by representing that Jean’s student loans were not consolidated,
and that NATIONWIDE could secure consolidation for her.
69. KRANZLER also represented to Jean that her school was trying to scare her.
70. KRANZLER further represented that if Jean’s school subsequently obtained a judgment
against her, NATIONWIDE would “undo” them.

17

 71. Jean then decided to cancel NATIONWIDE’s services and demanded, on numerous
occasions, that Defendants provide her a refund of $600, the amount she had paid them at that
point in time.
72. KRANZLER refused to issue Jean a refund.
73. On or around November 12, 2013, Jean then filed a complaint against NATIONWIDE
with the BBB, demanding a refund.
74. NATIONWIDE responded to Jean’s BBB complaint stating, in part, that “a refund was
denied as services had been rendered.”
75. Yet, as of the date of this Complaint, NATIONWIDE has failed to provide Jean any
services.
76. Only after Jean agreed to “withdraw” her BBB complaint did NATIONWIDE refund her
$600.
Lisa Dumas
77. Lisa Dumas resides in Uxbridge, Massachusetts.
78. In or around early 2013, Lisa learned about NATIONWIDE by visiting Defendants’
website.
79. Lisa then contacted NATIONWIDE, calling the toll free number listed on Defendants’
website and spoke with KRANZLER about Defendants’ student loan relief services.
80. During his sales pitch, KRANZLER represented to Lisa that NATIONWIDE would
lower her monthly student loan debt payments to as low as $184 per month.
81. To do so, KRANZLER represented that NATIONWIDE would consolidate Lisa’s
student loans.

18

 82. Lisa then informed KRANZLER that her loans were previously consolidated with her
husband’s student loans, and could not be consolidated again.
83. KRANZLER represented that NATIONWIDE could consolidate her loans despite its past
consolidation.
84. In reliance upon KRANZLER’s representation that NATIONWIDE could consolidate
Lisa’s previously consolidated loans, and lower her monthly student loan payment, Lisa agreed
to purchase NATIONWIDE’s student loan debt relief services.
85. NATIONWIDE, before it would consolidate her loans, required Lisa to pay weekly
installments of $25, until she paid Defendants $750.
86. In or around July 2013, Lisa contacted NATIONWIDE to cancel Defendants services and
demand a refund of $300, the amount she had paid so far.
87. NATIONWIDE failed to issue Lisa a refund.
NATIONWIDE failed to consolidate Lisa’s student loans or otherwise lower her monthly
student loan debt payments or provide any other service to Lisa.
88. On or around August 6, 2013, Lisa filed a complaint against NATIONWIDE with the
BBB, demanding a refund.
89. In response to Lisa’ BBB complaint, MISHOULAM responded that “[t]his complaint has
been resolved and closed directly with the client.” However, Lisa’s complaint had not been
resolved in any way.
90. MISHOULAM further responded that a “refund will be issued upon the withdrawal of
this invalid claim by the client.”
91. As of the date of this Complaint, NATIONWIDE has failed to perform any services for
Patricia, as promised, and has not given her a refund.

19

 VIOLATIONS OF LAW
COUNT I: CONSUMER FRAUD ACT
92. The People re-allege and incorporate by reference the allegations of Paragraphs 1 to 91.
93. While engaged in trade or commerce, Defendants engaged in the following unfair and/or
deceptive practices, or made the following material misrepresentations or omissions with the
intent that consumers would rely upon them, in violation of Section 2 of the Consumer Fraud
Act, 815 ILCS 505/2, by:
a. misrepresenting that Defendants will stop or negotiate the removal of wage
garnishments, without the ability to do so;
b. misrepresenting that Defendants will prevent tax liens, without the ability to do
so;
c. misrepresenting that Defendants will reduce a consumer’s student loan payment
and then failing to do so;
d. misrepresenting that Defendants will immediately perform work after a consumer
pays upfront fees, when in fact Defendants do not commence any work until they
have collected a substantial portion of the upfront fees;
e. engaging in the unfair and/or deceptive practice of failing to perform the work
promised and then failing to provide refunds;
f. misrepresenting that Defendants engage in the “negotiation” of student loan relief,
when in fact Defendants perform no such work;
g. misrepresenting that Defendants can secure lower student loan payments, while
failing to disclose to consumers that lower monthly student loan payments may
lead consumers to pay more in interest due to a longer loan maturity term;

20

 h. engaging in the unfair and/or deceptive practice of offering “Debt settlement”
services, as defined by the Debt Settlement Act, 225 ILCS 429/10, but then failing
to obtain the authority to do so;
i. misrepresenting that Defendants will improve credit scores, when in fact they
have no ability to do so;
j. engaging in the unfair and/or deceptive practice of representing that Defendants
can improve credit scores, but fail to register NATIONWIDE as a “credit services
organization,” as required by the Credit Services Organizations Act, 815 ILCS
605/9; and
k. misrepresenting that Defendants can secure student loan forgiveness without
ability to do so.
REMEDIES: COUNT 1
94. When the Office of the Illinois Attorney General files an action under the Consumer
Fraud Act, the following remedies are available to the Court:
(a) Whenever the Attorney General or a State's Attorney has
reason to believe that any person is using, has used, or is about to
use any method, act or practice declared by this Act to be unlawful,
and that proceedings would be in the public interest, he or she may
bring an action in the name of the People of the State against such
person to restrain by preliminary or permanent injunction the use
of such method, act or practice. The Court, in its discretion, may
exercise all powers necessary, including but not limited to:
injunction; revocation, forfeiture or suspension of any license,
charter, franchise, certificate or other evidence of authority of any
person to do business in this State; appointment of a receiver;
dissolution of domestic corporations or association suspension or
termination of the right of foreign corporations or associations to
do business in this State; and restitution.
(b) In addition to the remedies provided herein, the Attorney
General or State's Attorney may request and the Court may impose
a civil penalty in a sum not to exceed $50,000 against any person
found by the Court to have engaged in any method, act or practice
21

 declared unlawful under this Act. In the event the court finds the
method, act or practice to have been entered into with the intent to
defraud, the court has the authority to impose a civil penalty in a
sum not to exceed $50,000 per violation.
(c) In addition to any other civil penalty provided in this Section, if
a person is found by the court to have engaged in any method, act,
or practice declared unlawful under this Act, and the violation was
committed against a person 65 years of age or older, the court may
impose an additional civil penalty not to exceed $10,000 for each
violation.
815 ILCS 505/7.
95. Section 10 of the Consumer Fraud Act, 815 ILCS 505/10, provides that “[i]n any action
brought under the provisions of this Act, the Attorney General is entitled to recover costs of the
use of this State.”
PRAYER FOR RELIEF: COUNT 1
WHEREFORE, the Plaintiff prays that this Honorable Court enter an Order:
A. Finding that Defendants engaged in trade or commerce within the meaning of Section
1(f) of the Consumer Fraud Act;
B. Finding that, in the conduct of trade or commerce, Defendants engaged in unfair and/or
deceptive acts or practices within the meaning of Section 2 of the Consumer Fraud Act, 815
ILCS 5050/2, by the unlawful acts and practices alleged herein;
C. Preliminarily and permanently enjoining Defendants from engaging in the deceptive and
unfair acts and practices alleged herein in the State of Illinois, or enjoining Defendants from
operating in the State of Illinois;
D. Revoking, forfeiting or suspending any and all licenses, charters, franchises, certificates
or other evidence of authority of Defendants to do business in the State of Illinois;

22

 E. Declaring that all contracts entered into between Defendants and consumers by the use of
methods and practices described herein are unlawful and rescinded, and requiring that full
restitution be made to all affected consumers;
F. Ordering Defendants to pay a civil penalty of $50,000 if the Court finds that Defendants
engaged in methods, acts or practices declared unlawful by the Act without the intent to defraud;
G. Ordering Defendants to pay an additional civil penalty of $50,000 for each violation of
the Consumer Fraud Act found to have been committed with the intent to defraud;
H. Ordering Defendants to pay an additional civil penalty of $10,000 for each violation of
the Consumer Fraud Act found to have been committed against a senior citizen;
I. Requiring Defendants to pay all costs for the prosecution and investigation of this action;
and
J. Providing such equitable and other relief as justice may require.
COUNT II: CREDIT SERVICES ORGANIZATIONS ACT
96. The People re-allege and incorporate by reference the allegations of Paragraphs 1 to 91.
97. The Credit Services Organizations Act defines a "Credit Services Organization" as a
“person who, with respect to the extension of credit by others and in return for the payment of
money or other valuable consideration, provides, or represents that the person can or will provide
. . . services . . . [to] improv[e] a buyer's credit record, history, or rating.” 815 ILCS 605/3(i).
98. Defendants, at all times relevant hereto, operated as a “Credit Services Organization” in
Illinois in that they advertised that, under Defendants’ student loan debt relief services, they can
“Improve your credit score.”
99. In the course of advertising that they can improve consumers’ credit scores, Defendants
have violated the Credit Services Organizations Act by:

23

 a. failing to register as a Credit Services Organization as required by 815 ILCS
605/9, before acting as a Credit Services Organization in Illinois;
b. representing that Defendants can improve consumers’ credit scores without ability
to do so, in violation of 815 ILCS 605/5(4);
c. failing to provide to Illinois consumers, in writing and prior to accepting payment,
the statements required by 815 ILCS 605/6:
i. a complete and accurate statement of the consumer's right to review any
file on the consumer maintained by a consumer reporting agency, as
provided under the Fair Credit Reporting Act (15 U.S.C. Section 1681 et
seq.);
ii. a statement that the consumer may review his or her consumer reporting
agency file at no charge if a request therefor is made to such agency within
30 days after receipt by the consumer of notice that credit has been denied
and if such request is not made within the allotted time, the approximate
charge to the consumer for such review;
iii. a complete and accurate statement of the consumer’s right to dispute the
completeness or accuracy of any item contained in any file on the buyer
maintained by a consumer reporting agency;
iv. a complete and detailed description of the services to be performed by
Defendants and the total cost to the consumer for such services;
v. a statement notifying the consumer that: (i) credit reporting agencies have
no obligation to remove information from credit reports unless the
information is erroneous, cannot be verified or is more than 7 years old;

24

 and (ii) credit reporting agencies have no obligation to remove information
concerning bankruptcies unless such information is more than 10 years
old;
vi. a statement asserting the consumer’s right to proceed against the surety
bond required under Section 10 of the Credit Services Organizations Act,
815 ILCS 605/10;
vii. the name and business address of any such surety company together with
the name and the number of the account.
d. failing to incorporate in their Service Agreement to Illinois consumers the
elements required by 815 ILCS 605/7:
i.

a complete and accurate statement of the consumer's right to review any
file on the consumer maintained by a consumer reporting agency, as
provided under the Fair Credit Reporting Act (15 U.S.C. Section 1681 et
seq.);

ii.

a statement that the consumer may review his or her consumer reporting
agency file at no charge if a request therefor is made to such agency
within 30 days after receipt by the consumer of notice that credit has
been denied and if such request is not made within the allotted time, the
approximate charge to the consumer for such review;

iii.

a complete and accurate statement of the consumer’s right to dispute the
completeness or accuracy of any item contained in any file on the buyer
maintained by a consumer reporting agency;

iv.

a complete and detailed description of the services to be performed by

25

 Defendants and the total cost to the consumer for such services;
v.

a statement notifying the consumer that: (i) credit reporting agencies
have no obligation to remove information from credit reports unless the
information is erroneous, cannot be verified or is more than 7 years old;
and (ii) credit reporting agencies have no obligation to remove
information concerning bankruptcies unless such information is more
than 10 years old;

vi.

a statement asserting the consumer’s right to proceed against the surety
bond required under Section 10 of the Credit Services Organizations
Act, 815 ILCS 605/10;

vii.

the name and business address of any such surety company together with
the name and the number of the account.
REMEDIES: COUNT 2

100.

The Credit Services Organizations Act provides that:
The Attorney General, the State's Attorney of any county, or a
buyer may bring an action in a circuit court to enjoin a violation of
this Act. In addition to any injunction, the Attorney General or any
State's Attorney or any county, in the name of the People of the
State of Illinois, may seek to recover damages pursuant to this Act.
815 ILCS 605/12.

101.

The Credits Services Organizations Act provides that a “violation of this Act shall

also constitute a violation of the Consumer Fraud and Deceptive Business Practices Act.” 815
ILCS 605/15.

26

 102.

Section 8 of the Credit Services Organizations Act provides that “Any contract for

services which does not comply with applicable provisions of this article shall be void and
unenforceable as contrary to public policy.” 815 ILCS 605/8.
PRAYER FOR RELIEF: COUNT 2
Wherefore, the Plaintiff prays that this Honorable Court enter an Order:
A. Finding that Defendants operated as a “Credit Services Organization” within the meaning
of Section 3 of the Credit Services Organizations Act;
B. Finding that Defendants violated the Credit Services Organizations Act, 815 ILCS 605,
by the unlawful acts and practices alleged herein;
C. Finding that Defendants violated Section 2 of the Consumer Fraud Act, 815 ILCS 505/2,
by virtue of Defendants’ violations of the Credit Services Organizations Act;
D. Preliminarily and permanently enjoining Defendants from engaging in the deceptive and
unfair acts and practices alleged herein within the State of Illinois, or enjoining Defendants from
operating in the State of Illinois;
K. Declaring that all contracts entered into between Defendants and consumers by the use of
methods and practices described herein are void and unenforceable, and requiring that full
restitution be made to all affected consumers;
L. Revoking, forfeiting or suspending any and all licenses, charters, franchises, certificates
or other evidence of authority of Defendants to do business in the State of Illinois;
E. Ordering Defendants to pay a civil penalty of $50,000 if the Court finds that Defendants
have engaged in methods, acts or practices declared unlawful by the Act without the intent to
defraud;
F. Ordering Defendants to pay an additional civil penalty of $50,000 for each violation
found to have been committed with the intent to defraud;
27

 G. Ordering Defendants to pay an additional civil penalty of $10,000 for each violation
found to have been committed against a senior citizen;
H. Requiring Defendants to pay all costs for the prosecution and investigation of this action;
I. Requiring Defendants to pay the statutory damages provided under the Credit Services
Organizations Act, 815 ILCS 605/12; and
J. Providing such equitable and other relief as justice may require.
COUNT III: DEBT SETTLEMENT ACT
103.

The People re-allege and incorporate by reference the allegations of Paragraphs 1

to 91.
104.

The Debt Settlement Act defines “debt settlement service[s],” in part, to mean

“offering to provide advice or service, or acting as an intermediary between or on behalf of a
consumer and one or more of a consumer's creditors, where the primary purpose of the advice,
service, or action is to obtain a settlement, adjustment, or satisfaction of the consumer's
unsecured debt to a creditor in an amount less than the full amount of the principal amount of the
debt or in an amount less than the current outstanding balance of the debt.” 225 ILCS 429/10.
105.

Defendants, at all times relevant hereto, offered “debt settlement service[s]” in

Illinois, in that Defendants, while acting as intermediaries between consumers and the USDOE,
advertised that they could secure student loan debt settlements and adjustments.
106.

In the course of advertising, soliciting, offering for sale, and selling student loan

debt settlement and adjustment services to Illinois consumers, Defendants have violated the Debt
Settlement Act by:
a. failing to obtain a licenses as a Debt Settlement Providers as required by 225
ILCS 429/15, and acting as Debt Settlement Providers in Illinois;

28

 b. charging and requiring consumers to pay over $50 in upfront fees prohibited by
225 ILCS 429/125(b);
c. failing to make, on its website and advertisements, the disclosure statement
required by 225 ILCS 429/105(c);
d. failing to provide an individualized financial analysis to consumers as required by
225 ILCS 429/110, in writing, that states the following:
i. an individualized financial analysis, including consumers’ income,
expenses, and debts;
ii. a statement containing a good faith estimate of the length of time it will
take to complete Defendants’ student loan debt settlement program;
iii. the total amount of debt owed to each creditor included in Defendants’
student loan debt settlement program;
iv. the total savings estimated to be necessary to complete the debt settlement
program;
v. and the monthly targeted savings amount estimated to be necessary to
complete the debt settlement program;
vi. the consumer can reasonably meet the requirements of the proposed debt
settlement program, including the fees and the periodic savings amounts
set forth in the savings goals;
vii. Defendants’ student loan debt settlement program is suitable for the
consumer at the time the contract is to be signed.

29

 e. failing to incorporate in their Service Agreement to Illinois consumers the
elements required in a "debt settlement" contract required under 225 ILCS
429/120, as follows:
i. a complete list of the consumer’s accounts, debts, and obligations, listing
the name of each creditor and principal amount of each debt;
ii. a description of the services to be provided by Defendants, including the
expected time frame for settlement for each account, debt, or obligation;
iii. a statement of the proposed savings goals for the consumer, stating the
amount to be saved per month or other period, time period over which
savings goal extends, and the total amount of the savings expected to be
paid by the consumer pursuant to the terms of Defendants’ contract;
iv. the amount of money or the percentage of debt the consumer must
accumulate before a settlement offer will be made to each of the
consumer's creditors;
v. a written individualized financial analysis;
vi. contents of the "Consumer Notice and Rights Form" provided under the
Section 115(c) of the Debt Settlement Act, 225 ILCS 429/115(c);
vii. a written notice to the consumer that the consumer may cancel the contract
at any time until after Defendants have fully performed each service they
contracted to perform or represented they would perform, and upon that
event the consumer shall be entitled to a full refund of all unearned fees
and compensation paid by the consumer to Defendants.
REMEDIES: COUNT 3

30

 107.

The Debt Settlement Act provides for enforcement by the Illinois Attorney

General, and further provides that all remedies available under the Consumer Fraud Act are
likewise available for any violation of the Debt Settlement Act:
A violation of Section 105, 110, 115, 120, 125, 130, 135, 140, 145,
or 150 of this Act constitutes an unlawful practice under the
Consumer Fraud and Deceptive Business Practices Act. All
remedies, penalties, and authority granted to the Attorney General
or State's Attorney by the Consumer Fraud and Deceptive Business
Practices Act shall be available to him or her for the enforcement
of this Act.
225 ILCS 429/155(a).
108.

Section 80(b) of the Debt Settlement Act provides that “[a]ny contract of debt

settlement service as defined in this Act made by an unlicensed person shall be null and void and
of no legal effect.” 225 ILCS 429/80(b).
PRAYER FOR RELIEF: COUNT 3
Wherefore, the Plaintiff prays that this Honorable Court enter an Order:
A. Finding that Defendants engaged in student loan “debt settlement service[s]” within the
meaning of Section 10 of the Debt Settlement Act;
B. Finding that Defendants violated Sections 15, 105, 110, 120, 125, 135(c), and 145 of the
Debt Settlement Act, 225 ILCS 429, by the unlawful acts and practices alleged herein;
C. Finding that Defendants violated Section 2 of the Consumer Fraud Act, 815 ILCS 505/2,
by virtue of Defendants’ violations of the Debt Settlement Act;
D. Preliminarily and permanently enjoining Defendants from engaging in the deceptive and
unfair acts and practices alleged herein within the State of Illinois, or enjoining Defendants from
operating in the State of Illinois;

31

 M. Declaring that all contracts entered into between Defendants and consumers by the use of
methods and practices described herein are null and void and of no legal effect, and requiring
that full restitution be made to all affected consumers;
N. Revoking, forfeiting or suspending any and all licenses, charters, franchises, certificates
or other evidence of authority of Defendants to do business in the State of Illinois;
E. Ordering Defendants to pay a civil penalty of $50,000 if the Court finds that Defendants
has engaged in methods, acts or practices declared unlawful by the Act without the intent to
defraud;
F. Ordering Defendants to pay an additional civil penalty of $50,000 for each violation
found to have been committed with the intent to defraud;
G. Ordering Defendants to pay an additional civil penalty of $10,000 for each violation
found to have been committed against a senior citizen;
H. Requiring Defendants to pay all costs for the prosecution and investigation of this action;
and
I. Providing such equitable and other relief as justice may require.

Respectfully Submitted,
THE PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN
ATTORNEY GENERAL OF ILLINOIS

By: Zed(
san Ellis, Bureau Chief
Consumer Fraud Bureau

By:
32

 Joseph Pham
Assistant Attorney General

Attorney No. 99000
LISA MADIGAN
ILLINOIS ATTORNEY GENERAL
Susan Ellis, Bureau Chief
Consumer Fraud Bureau
Andy Dougherty
Supervising Attorney
Joseph Pham
Assistant Attorney General
Consumer Fraud Bureau
100 West Randolph Street, 12th floor
Chicago, Illinois 60601
312/814-3740

33

 NATIONWIDE

Plaintiffs Exhibit 1

STUDENT AID
The Client Service Agreement ("Agreement “) is between you,
("Client") and Nationwide Student Aid, LLC to
provide the services for the fees set forth on Schedule A. Client authorizes The Company and its employees, representatives, or agents
the right to communicate on the Client's behalf with Federal student loan creditor(s) for the purpose of negotiating arrangements to
resolve the Client's Federal student loan debt situation.
1. Degree of Service Agreement
1.1 Client has initiated the services of Nationwide Student Aid. Nationwide Student Aid has explained the
services to be performed by Nationwide Student Aid for Client.
1.2 Nationwide Student Aid will assist Client to complete forms necessary to obtain a new Federal
consolidation loan, and/or explore the possibilities of refunds if applicable and reasonable and affordable
payment plans for Federal student loans in a seriously delinquent or defaulted status. In addition,
Nationwide Student Aid will gather relevant information regarding the Client's Federal student loan(s) that
will include the holder, loan origination, and schedule of outstanding balances.
1.3 Nationwide Student Aid will seek to explore affordable repayment options for loans held by Client. In
addition, Nationwide Student Aid will advise Client in his/her efforts to negotiate to remove wage
gamishment(s) and/or tax offset(s).
1.4 Client authorizes Nationwide Student Aid and its employees, representatives, or agents the right to
communicate on the Client's behalf with Federal student loan creditor(s) for the purpose of negotiating
arrangements to resolve the Client's Federal student loan debts)/credit situation.
2. Client Responsibilities
2.1 Client will be responsible for providing complete and accurate information as well as timely responses to
communication in five (5) business days.
2.2 Client agrees to be cooperative and truthful. Client may be asked to provide documentation and/or send
documentation to Nationwide Student Aid, which will aid in the consolidation process. Client has provided
Nationwide Student Aid with his/her FAFSA Personal Identification number.
2.3 Once Client begins working with Nationwide Student Aid, Client agrees not to work on his/her own
Federal student loan accounts without first notifying Nationwide Student Aid. Client must allow
Nationwide Student Aid the opportunity to negotiate and work his/her Federal student loan obligations.
3. Privacy,
3.1 Nationwide Student Aid is dedicated to protecting your privacy and providing you with the highest level of
service.
4. Guarantee Disclaimer
4.1 Nationwide Student Aid may give opinions of possible results based on past experiences and results. By
signing this agreement, Client acknowledges each case is different and unique and individual results may
vary.
4.2
Client also understands that Client's loans will continue to accrue interest until repaid. Client also
understands that lender(s) may and can impose other penalties as a result of delinquent payments, including
but not limited to, the reporting to credit bureaus, garnishment of wages, personal tax offsets, default
penalties, and/or filing for a lawsuit to collect the student loan debt(s).

5. Refund Policy
If
Nationwide
Student
Aid
is
unable
to
assist
the Client in reaching a new Federal consolidation loan, the
5.1
Client will not be charged for the remainder of his/her Service Fee. Any and all refunds will be made at the
sole discretion of Nationwide Student Aid. All payments received by Nationwide Student Aid as per the
Payment Schedule will be retained by Nationwide Student Aid whether or not the Client completes the
payment.
5.2 Nationwide Student Aid and its officers, employees, agents, and affiliates make no representations or
warranties of any kind as to the services to be provided herein.
Case II: 2160)

Page 1

 Plaintiffs Exhibit 1

6. Not Included in Representation
6.1 Client understands that by virtue of this Agreement, Client is contracting Nationwide Student Aid to
prepare an application for a Federal student loan consolidation. Client expressly acknowledges that
Nationwide Student Aid does not provide student loan financing of any kind.
6.2 Client acknowledges that this Agreement does not include any representation for any claim or cause of
action brought against Client including cross-complaints. Client agrees and acknowledges that Nationwide
Student Aid has not represented that it will advise or assist Client in the modification, improvement, or
correction of credit entries on Client's credit reports or that Nationwide Student Aid can stop collection
phone calls or correspondence.
6.3 Client agrees and acknowledges that Nationwide Student Aid does not represent itself as a Lender.
6.4 Client agrees and acknowledges that Nationwide Student Aid did not represent itself to be affiliated in any
way with any governmental agency.
7. Arbitration of Dispute
7.1 The Company and Client Agree that any dispute concerning the service should be resolved first by The
Company and Client. If The Company and Client shall fail to resolve dispute, Client agrees to enter into a
non-binding mediation. All mediation conferences shall occur in Chicago, Illinois. If any dispute remains
unresolved between the parties after the mediation process has been completed, either party may then
submit any such unresolved dispute to final and binding arbitration. The exclusive venue of any arbitration
proceeding shall be in Chicago, Illinois at a neutral site selected by the arbitrator.
7.2 The Client AGREES TO LIMIT NATIONWIDE STUDENT AID LIABILTY OF DAMAGES TO
CLIENT TO THE FEE TIIAT NATIONWIDE STUDENT AID CHARGED CLIENT FOR
SERVICES, WHICHEVER IS GREATER. THIS LIMITATION SHALL APPLY REGARDLESS
OF CAUSE OF ACTION OR LEGAL THEORY PLEAD OR ASSERTED BY CLIENT.
8. Discharge, Withdrawal or Cancellation
8.1 Either party may discharge the other by written notice, effective when received by the discharged party.
Upon termination, Nationwide Student Aid shall be entitled to keep all fees that have been deemed earned
pursuant to the Service Fee below. Our uncollected fees at time of withdrawal that are earned and
uncollected shall survive this Agreement.
8.2 Nationwide Student Aid reserves the right to terminate this Agreement for any reason with five days'
notice, which may be written or electronic and without any further obligation. Any and all refunds will be
made at the sole discretion of Nationwide Student Aid.
8.3 Client may cancel this Agreement at any time and for any reason. Client understands that Nationwide
Student Aid earns their fees as described in the Payment Agreement. Any and all refunds will be made at
the sole discretion of Nationwide Student Aid.
9. No Legal Representation
9.1 CLIENT EXPRESSLY UNDERSTANDS, WAIVES, AND RELEASES NATIONWIDE STUDENT AID
FROM ANY AND ALL LIABILITY WHETHER KNOWN OR UNKNOWN, NOW AND IN THE
FUTURE, RELATING TO OR RESULTING FROM ANY ALLEGATION OR ACTION OF
NATIONWIDE STUDENT AID OR CLIENT THAT MAY BE CONSTRUED TO CONSTITUTE
LEGAL ADVICE OR REPRESENTATION.
10. Agreement to Do. Business Electronically
WA Client agrees, unless specifically requested otherwise, that Nationwide Student Aid may send and Client
will receive, in an electronic format, all information, copies of Agreements and correspondences from
Nationwide Student Aid. Client consents and agrees that Nationwide Student Aid may provide all
disclosures, periodic statements, notices, receipts, modifications, amendments and all other evidence of
transactions electronically.
10.2A11 electronic communications will be deemed to be valid and authentic, and Client intends and agrees that
those electronic communications will be given the same legal affect as written and signed paper
communications.
10.3Client acknowledges and agrees that the Internet is considered inherently insecure. Therefore, Client agrees
that Nationwide Student Aid has no liability to Client whatsoever for any loss, claim, and/or damages rising
Case 4: 21609

Page 2

 Plaintiffs Exhibit 1

or in any way related to Nationwide Student Aid's responses to any electronic communication, upon which
Nationwide Student Aid has in good faith relied. At all times, Client maintains the sole obligation to insure
they can receive Nationwide Student Aid's electronic communications and access them on a regular and
diligent basis.
11. Governing Law and Venture/Cancellation Policy
11.1The interpretation and enforcement of this Agreement shall be construed in accordance with the laws of the
state of Illinois. Client has the right to cancel this Agreement at any time in accordance with Section XIII of
this Agreement. All payments received by Nationwide Student Aid as per the Payment Schedule will be
retained by Nationwide Student Aid whether or not Client completes the program. In the event of Client
wishing to cancel/terminate services with Nationwide Student Aid, it is mandatory that the Client submit a
written, signed, and dated document of request to cancel services. Services will be terminated upon date of
receipt. From that date forth, scheduled draft of tiiture payments will be cancelled. Any amount paid prior
to cancellation is deemed non-refundable. In return, Nationwide Student Aid, LLC and its affiliates,
agents, and representatives agree to not pursue collection on unpaid balance.

12. Service Fee

Nationwide Student Aid reserves the right to terminate this Agreement or adjust the Service Fee should it determine
the information you provided was inaccurate or fraudulent. This Agreement is the only agreement between the
parties. No oral or written communications between the parties shall amend or modify the terms of this Agreement
unless signed by both parties.
This Agreement constitutes the full and complete agreement between Client and Nationwide Student Aid. This
Agreement supersedes any and all other agreements or understandings, whether written or oral, between Client and
1 verify at 1 have read, understand, and agree with the above agreement and have been
Nationwide Student.
provided a co • f6r m p • nal cor

SIGNA

OF C ► E T

DATE

PRINT NAME

C:asc # 21609

Page 3