IN THE COURT OF COMMON PLEAS OF ALLEGHENY COUNTY, 

COMNIONWEALTH OF 
BY ATTORNEY GENERAL JOSH SHAPIRO

Petitioner

v.
STUDENT CU CONNECT CUSO, LLC

Respondent

no .-

CIVIL DIVISION

mm. W99

ASSURANCE OF VOLUNTARY
CONIPLIANCE

Filed on Behalf of Petitioner:

COMMONWEALTH OF
OFFICE
OF ATTORNEY GENERAL

Counsel of Record for this Party:

Jesse F. Harvey
Chief Deputy Attorney General
P.A. ID. No. 63435

Of?ce of Attorney General
Bureau of Consumer Protection
1251 Waterfront Place
Mezzanine Level

Pittsburgh, PA 15222

(412) 565?2383

 

COMNIONWEALTH OF 
BY ATTORNEY GENERAL JOSH SHAPIRO CIVIL DIVISION

Petitioner

v. G.D. No.
STUDENT CU CONNECT CUSO, LLC

Respondent

ASSURANCE OF VOLUNTARY COMPLIANCE

 

Pursuant to Section 201?5 of the Unfair Trade Practices and Consumer
Protection Law, 73 PS. 201-5, the parties hereto consent to the ?ling of this Assurance

of Voluntary Compliance in this Court.

REMAINDER OF PAGE INTENTIONALLY BLANK

 

ASSURANCE OF VOLUNTARY COMPLIANCE

This Assurance of Voluntary Compliance/Assurance of Voluntary Discontinuance
(?Settlement? or i?Assurance?) is entered into between the States of Alabama, Arizona,
Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana, Iowa,
Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota,
Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New
York, North Carolina, Ohio, Oklahoma, Oregon, South Carolina, South Dakota,
Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia and Wisconsin, and the
District of Columbia (the ?States? or individually, a tats?), acting through their respective
Attorneys General, Departments of Justice, or Of?ces of Consumer Protection, on the one hand,
and Student CU Connect CUSO, LLC (the on the other hand (the States and the
CUSO, together, the ?Parties?). The Parties hereby agree to this Settlement pursuant to the
States? respective laws to settle the States? concerns that the conduct of the CUSO may have
violated the States? consumer protection laws relating to unfair and deceptive business acts and
practices.1 The States and the CUSO have agreed to execute this Assurance for the purposes of

settlement oniy.

 

1 See, generally Ala. Code 849-1 at seq.; Aria. Rev. Stat. 444521 44-1534; Ark. Code
Ann. 4-88-101 et seq.; Colo. Rev. Stat. 6?1-10l etseq.; Conn. Gen. Stat. 42-110a stseq.;
6 Del. C. {i 2511 at seq., 2531 et seq.; Fiorida Deceptive and Unfair Trade Practices Act,
Chapter 501, Part II, Florida Statutes (2018); Fair Business Practices Act, O.C.G.A. 10?1-390
etsaq.; Idaho Code ?48~601 et seq.; 815 ILCS 505/1 815 505/12; Ind. Code 24?5?05
et seq; Iowa Code 714.16 Kansas Consumer Protection Act, K.S.A. 50-623 et
seq.; Ky. Rev. Stat. 367.110 ct scan; La. Rev. Stat. 51:1401 et seq.; Me. Unfair Trade
Practices Act, 5 MRS. et seq.; Md. Code Ann, Corn. Law 13-101 13?501 (2013
Repl. Vol. and 2016 Supp); Mass. Gen. Laws 0. Mich. MCL 445.901 at seq; Consumer
Fraud Act, Minn. Stat. 325F.69 et seq. and Deceptive Trade Practices Act, Minn. Stat.

325D.44 ct scan; Miss. Code 75-24?1 et seq.; the Missouri Merchandising Practices Act,

 

DEFINITIONS
The following de?nitions, in addition to those set forth above and within, apply to this
Assurance:

i. ?Affected State Consumer? means any student borrower residing in any of the States
who received a Loan (as de?ned below) that was not paid in full as of the Effective
Date (as defined below).

2. ?Bureau? means the federal Bureau of Consumer Financial Protection.

3. ?Bureau Action? means the case entitled Bureau of Consumer Financial Protection v.
Student CU Connect CUSO, LLC in the United States District Court for the Southern
District of Indiana.

4. ?Bureau Order? means the Stipulated Final Judgment and Order issued in the Bureau
Action.

5. ?Consumer Information? means identifying information obtained by the CUSO about
any individual Affected State Consumer in connection with the Loan Program (as
de?ned beiow), including that Affected State Consumer?s name, address, telephone
number, email address, social security number, or any data that enables access to any
account of that consumer (including a credit card, bank account, or other ?nancial

account). Consumer Information does not include any compilation or summary of

 

Chapter 407, Neb. Rev. Stat. 59-1601 et seq. and 87-301 et seq.; Nev. Rev. Stat.
598.0903 et seq.; NH RSA Chapter N.J.S.A. 56:8-1 et seq.; NMSA 1978, 57-124 
26 (1967, as amended 2009); NY. Gen. Bus. Law 349; NY. Exec. Law 63(12); NC. Gen.
Stat. 75-1.} etseq.; O.R.C. 1345.01 etseqa 15 0.8. 751 etseqa ORS 646.605 et seq.; 73
Pa. Cons. Stat. Ann. 201-1 201?93 (West); 8.0. Code of Laws, 39?5-10 et seq.; SDCL
Chapter 31?24; Tenn. Code Ann. 47-18-101 et seq.; Texas Bus. 85 Com. Code 17.41 et seq.;
Utah Code 13-11~1 etseq.; 9 V.S.A. chapter 63; Va. Code 59.1?196 - 59.1-207; RCW

19.86.020; W. Va. Code atseq.; Wis. Stat. 100.180); Consumer Protection
Procedures Act, DC Code 286901 et seq.

 

10.

ll.

12.

13.

14.

Consumer Information if such compilation or summary does not include identifying
information of individual consumers.

?Consumer Reporting Agency? has the same meaning as set forth in the Fair Credit
Reporting Act, 15 U.S.C. 1681a(f).

?Effective Date? means the later of the date on which the Bureau Order is issued or
(ii) for each of the States, the date on which the Assurance otherwise would become i
effective under the applicable law and procedure of that State. i
means ITT Educational Services, Inc.

?Lead State? means the Of?ce of the Attorney General for the Commonwealth of
Kentucky.

?Loan? means one of the private student loans entered into by or originated to students
of ITT schools by a third party pursuant to the Loan Program (as de?ned below), and
currently owned by the CUSO.

?Loan Program? means the private student loan program established by and the
CUSO together with other parties, pursuant to certain agreements, which provided
funding for students attending ITT schools.

?Redrass Plan? means the comprehensive written plan for the implementation
of the Bureau Order and this Assurance, attached as Exhibit 1 hereto.

?Servicer? means the servicer of one or more of the Loans.

BACKGROUND
Each of the States has enacted a statute relating to unfair and deceptive business acts

and practices as referenced in footnote 1 herein (?Footnote Each State?s Attorney

 

General is responsible for enforcing that statute and other consumer protection laws for
its respective State.

15. The CUSO is a Delaware limited liability company created for the Loan Program. In
connection with the Loan Program, the CUSO owns the Loans and, subject to certain
conditions and limitations contained in certain Loan Program agreements, provides for
the servicing of the Loans by the Servicer.

16. The States initiated an investigation of the CUSO and its relationship with ITT with
respect to the origination and servicing of private student loans, including concerns that
the existence of the Loan Program allowed ITT to perpetrate a scheme wherein ITT
presented a facade of compliance with federal laws requiring that ten percent of
a for-profit school?s revenue come from sources other than federal student aid (20
U.S.C. 1094(a)(24), the ?90/10 Rule?), and in doing so took unreasonable advantage of
ITT student borrowers who were unaware of the scheme associated with this loan

program, and therefore were unable to protect their interests in taking out such loans.

FACTUAL ALLEGATIONS
ITT Engaged in a Private Loan Scheme to Bene?t Itself at the Expense of Students

17. The Loan Program originated approximately $189 million in student loans to ITT
students from March 2009 until December 2011. The Loans were available only to 
students. Proceeds from the Loans were disbursed directly to and were required to
he used only to pay and could not be used by students for any other purposes.

18. Funding for the Loans was provided primarily by the CUSO through an automatic

purchase agreement with a credit union that originated the Loans.

 

19.

20C

21.

22.

23.

24.

25.

The CUSO continues to own all outstanding Loans made to Affected State Consumers,
and directs servicing and collections of those Loans through the Servicer.

was a publicly traded, for-pro?t corporation that, until September 2016, enrolled
consumers in classes at 149 locations throughout the country.

The [owninoome consumers whom ITT targeted could rarely afford to pay its high
tuition out-of-poeket. Therefore, business model relied on these consumers
obtaining federal aid, mostly loans, to payITT.

Federal aid, including federal loans, did not, however, typically provide an ITT student
with enough money to cover entire tuition. Few of students could afford to
cover this tuition gap with their own money.

To close this tuition gap, when it recruited new students, offered them zero-
interest, short-term loans payable in a single payment nominally due nine months later,
at the end of that academic year. ITT referred to these loans as ?Temporary Credit.?
If students were not able to pay off the Temporary Credit at the end of the academic
year?usomething ITT knew few students would be able to down-ITT coerced them into
paying off their Temporary Credit amounts with private loans, including the Loans,
payable over ten years.

At the same time, to cover the tuition gaps for the upcoming year, students were
coerced by into taking out additional private student loans. If students were unable
to pay off the Temporary Credit and pay the secondqear tuition gap, and they refused
the private loans, they were threatened by ITT with expulsion. Thus, through December
2011, Temporary Credit operated merely as an entry point to private student

loans, including the Loans.

 

26. The staff of HTS campus ?nancial aid offices (the ?Financial Aid staff?) engaged in a
variety of aggressive tactics, such as pulling students from class, withholding course
materials or transcripts, and rushing students through ?nancial aid appointments, to get
those students to sign up for private loans, including the Loans. Certain ITT students
did not understand the terms of their private loans, and some students did not realize
they had taken out loans at all.

27. While students were left unaware that the zero-interest Temporary Credit was just an
entry point for additional private loans, consistently told its investors, from the
time the private lending programs were put in place, that it was lTT?s ?plan all along?
that students? Temporary Credit would be paid off through the Loan Program and other
private lending programs. ITT had established the lending programs to ensure that its
income and free cash ?ow would improve, which in turn improved the appearance of
?nancial statements.

28. Default rates for ITT students on all loans have been high. Default rates on the Loan
Program are now, postwiTT school closures and bankruptcy ?ling, projected to exceed
90%. ITT knew that the Loans would impose an unsurmountable burden to many of its
students: itself projected, as far back as May 201 1, prior to the discontinuance of
the Loan Program, that more than 60% of the students who had received the private
loans would default. Simply to enhance its ?nancial statements and appearance to
investors, and to enhance its compliance with the 90/10 Rule and access to funds

provided by the federal government under Title IV of the Higher Education Act of

1965, 20 U.S.C.

 

29.

30.

31.

32.

33.

34.

1070 et seq. (?Title ITT sacri?ced its students? futures by saddling them with
debt on which it knew they would likely default.

was putting students into these private loans in order to convert uncollectible zero
interest Temporary Credits into revenue to make ?nancial statements more
appealing to investors.

revenues came from student tuition and fees. tuition was higher than that of
most other for-pro?t post-secondary institutions. During the period when the Loans
were offered, two?year associate degree programs?the programs in which
approximately 85% of HT students were enrolled?cost a total of approximately
$44,000, based on a charge of $493 per credit hour. By the same measure, 
bachelor?s degree programs cost a total of approximately $88,000.

ITT students generally had poor credit pro?les and low earnings; according to 
former Chief Financial Of?cer during the period when the Loans were
offered, the average ITT student earned around $18,000 per year and had a credit score
under 600 at the time he or she enrolled. Such students could very rarely pay for 
tuition out-of?pocket.

The primary method by which students paid their ITT tuition, and the main source of

cash receipts, was ?nancial aid provided by the federal government under Title

IV.

In 2011, about 89% of cash receipts came from the government, and around 7%

came from private loans, such as the Loans.

Obtaining these federal and private loans required an extensive application process

involving numerous forms and the collection of ?nancial and personal information

 

35.

36.

37.

from students. l?I?T?s Financial Aid staff administered this process from the time
students enrolled in NT schools through to their graduation.

The ?nancial aid process was complicated and dif?cult to understand. Rather than
helping students better understand the borrowing process and make informed decisions
in their best financial interests, ITT made a practice of having its Financial Aid staff
take control of the students? loan applications and rush them through the process of
signing up for loans, leaving many unsure what they were signing.

The ?nancial aid process was structured so that Financial Aid sta? were
essentially holding the students? hands while they reviewed and signed federal and
private loans. Part of the way that Financial Aid staff did this ?hand holding? was
through the automated ?nancial aid platform set up by ITT. ITT provided its Financial
Aid staff with software called ?SmartForms,? which automatically populated and
submitted ?nancial aid applications for its students to the federal government or other
lenders, requiring only e~signatures from students.

The ?nancial aid appointments for continuing students with Financial Aid staff
were called ?repackaging? or ?repac appointments. In order to ensure that continuing
students (including graduating students) came to the repack appointments, which often
occurred months in advance of the applicable academic term, instructed and
incentivized its Financial Aid staff to use aggressive tactics (the ?repackaging tactics?)
such as calling students at home, finding them in the bookstore or the library or the
student lounge, pulling them from class, barring them from class, enlisting the aid of
other ITT staff (including professors), and withholding course materials, diplomas, and

transcripts. repacking tactics were so ingrained into the company?s operations

 

that even its former Chief Executive Of?cer personally encouraged 
Financial Aid staff to pull students from class and take them to the ?nancial aid
of?ce to complete ?nancial aid applications.

ITT Coerced Students to Take Out the Loans for Own Financial Gain, through a
Private Student Loan Financing Scheme Involving ?Temporary Credit?

38. Using the tactics described above and others, Financial Aid staff coerced students
into Loans that they did not want, did not understand, or did not even realize they were
getting. Financial Aid staff coerced students into taking out private student loans,
including the Loans, to cover the tuition gap between what federal loans and grants
would cover and the high cost of attending ITT.

39. Through December 2011, ITT sought to have its students pay for the tuition gap with
private loans, including the Loans, because outside sources of payment couid be
booked as income to the company, improving its free cash flow and the appearance of
its ?nancial statements, and because outside sources of revenue helped ITT meet a
requirement by the Department of Education that at least 10% of its revenue be derived
from sources outside Title iV loans and grants and the 90/10 Rule.

Temporary Credit
40. Prior to February 2008, ITT relied on a large third-party lender to provide private loans 2'

to its students to cover their tuition gap. In or about 2008, after the third?party funding
source dried up, ITT began offering its students loans that it called Temporary Credit to
cover their tuition gaps, Temporary Credit was a no-interest loan payable in a
single lump sum payment, with a due date typicaily nine months after enrollment at the

end of the academic year for which it was offered.

 



42.

43.

44.

45.

46'

47.

ITT had minimal credit criteria that students had to meet to be eligible for Temporary
Credit. Even if a student did not meet these minimal criteria, staff at ITT headquarters

couldmand, when asked, often didmgrant exceptions.

A ..


Before provided Temporary Credit to students, it performed credit checks to
determine if they met the limited credit criteria. Thus, at the time ITT provided
Temporary Credit to students, it knew their credit scores.

Temporary Credit was offered and granted during rushed ?nancial aid appointments 2
controlled by Financial Aid staff. Thus, some students who had a Temporary
Credit loan obligation did not even know they had received Temporary Credit or did
not know that it was a loan that would have to be repaid.

Financial Aid staff also led some students to believe that Temporary Credit
would be available to cover their tuition gaps for their entire educational program, and
that it would only be due to be repaid after the students graduated from ITT.

records show students reported that its Financial Aid staff told them that
Temporary Credit would be available throughout their entire ITT education, and would
not have to be repaid until after graduation. Moreover, ?nancial aid training
materials noted that students were not a ?reliable source? as to whether they had ever
received Temporary Credit.

knew that the vast majority of students who received Temporary Credit did not,
and would not, have the resources or access to credit, to make the entire lump sum
payment with in nine months.

From 2009 through 2011, ITT was leading students approximately 3 100 million to

$150 million per year in Temporary Credit. ITT did not intend to continue offering

10

 

Temporary Credit to students throughout their entire ITT education. ITT believed most
students were unlikely to repay the Temporary Credit loans and deeply discounted them
on its balance sheet, calling them ?doubt?? accounts.?

48. in 2009, Financial Aid staff began coercing students into repaying their
Temporary Credit with private loans, including the Loans. After implementing the
private loan programs, ITT no longer had to maintain those deep discounts on its
balance sheet because it expected students would be forced to repay the Temporary
Credit with private loans.

The ITT Private Loan Programs

49. In 2008, ITT began to build two separate, unrelated private loan programs from
scratch, later to be referred to from time to time as the CUSO Loan Program and the
PEAKS Loan Program (together, the Private Loan Programs? or the 
Private Loans"). The ITT Private Loan Programs were intended by ITT to be the
vehicle for students to pay off their Temporary Credit, enabling to convert
Temporary Credit into immediate income and oash?on?hand. The private loans also
financed students? second year tuition gap.

50. HT disclosed to its auditors and its investors that the ITT Private Loan Programs were
speci?cally intended, and Would be used, to reduce the amount of Temporary Credit
outstanding and to help ITT avoid lending students any further amounts from its own
books after their first year.

51. Indeed, Temporary Credit program operated as a tool to pre~qualify students for
the HT Private Loans, often regardless of their credit pro?le. Pursuant to the written
underwriting criteria for the IT Private Loans, a continuing ITT student who had

received Temporary Credit could be automatically eligible for ITT Private Loans

11

 

 

52.

53.

54.

55.

56.

57.

notwithstanding his or her failure to satisfy the remaining loan underwriting orlteria so
long as he or she had not declared bankruptcy within 24 months (?Temporary Credit
Exception?).

Approximately $149 million, or 79%, of the entire Loan portfolio went to 
quali?ed under the Temporary Credit Exception.

ITT students did not know this, nor were they made aware that would coerce them
into using the ITT Private Loans to repay Temporary Credit, until the point that 
Financial Aid staff gave them no choice other than to take the ITT Private Loans or be
expelled from ITT schools.

111? instructed its Financial Aid staff to identify students to repackage into the ITT
Private Loans as soon as possible in order to further its scheme and remove the
Temporary Credits from its corporate ?nancial reports.

Financial Aid staff used all of the ?tepackaging tactics" described above to get
students to repackage.

Some students objected to the ITT Private Loans, but they were told by Financial
Aid staff that if they refused to use them, they either had to pay any outstanding
Temporary Credit and the next year?s tuition gapmwhich most could not dew?or leave
the school in the middle of their program and forfeit the investment they had made so
far.

Some ITT students did not even realize that they took out the ITT Private Loans. For
some students, this lack of awareness was due to the rushed and automated manner in

which ITT Financial Aid staff processed their paperwork. For other students, it was due

12

 

53.

59.

60.

to ?aws in the SmartForms system that allowed Financial Aid staff unauthorized
access to student loan documents.

The interest rate for the Loans, which carried a ten-year term, was based on a student?s
credit score. For borrowers with credit scores under 600, the interest rate initially Went
as high as the prime rate plus 10.5%, with an origination fee as high as 10%. Starting in
or around April 2011, borrowers with credit scores under 600 were charged an interest
rate of prime plus 13%, in addition to the 10% origination fee.

For most of the period since 2009, the prime rate has been 3.25%; thus the effective
interest rate for the Loans has been 13.75% for some borrowers with credit scores under
600; for borrowers taking out Loans after April 2011 with credit scores under 600, the
interest rate has been 16.25%. Approximately 46% of the borrowers of the Loans had
credit scores under 600, and thus were subject to interest rates of 13.75% or 16.25%
and origination fees of 10%. Recent increases in the prime rate have increased the
interest rates of the Loans, further impacting borrowers.

In May 2011, consultant for loan default analysis projected a gross default rate of
61.3% for the existing Loans. Despite this clear indication that the vast majority of
students would be unable to afford the Loans, ITT continued the ITT Private Loans. In
a January 24, 2017 Proof of Claim filed by the CUSO in bankruptcy case, 16--
07207 (SD. TN), after ITT shut down all its campuses, the CUSO predicted a 75%
default rate for $32,304,893.87 in Loans that are ?Active? and ?Current (to 29 days
[delinquent])? and a default rate of between 94 and 99.5% for approximately

$127,000,000 in Loans in forbearance or more than 30 days? delinquent.

13

 

61. Neither prospective students not current students were told by ITT the default rates on
the Loans.
62. As private student loans, the Loans are dif?cult to discharge in bankruptcy, requiring
the student-borrower to make a special showing of ?undue hardship.?
Plan Behind the ITT Private Loan Programs
63. While failing to disclose to students that the ITT Private Loans were intended from the
start to be vehicles to pay off its students? Temporary Credit, did share this fact
with investors.
64. From 2009 through 2011, CEO and CFO participated in quarterly earnings calls
with and investors. In these calls, the ITT executives repeatedly discussed the
ITT Private Loan Programs as vehicles for taking Temporary Credit off of 
balance sheet.
65. In the January 21, 2010 earnings call for Fourth Quarter 2009, HT talked about the
PEAKS program, which had just begun. In response to a question from 
CFO said: ?the way the program works is, that it is eligible for second year students. So
therefore, these students who have had some internal borrowings in year one, would
have effectively re?nanced through the PEAKS program in year two.? The CEO
reinforced thispoint:
We still anticipate offering internal ?nancing to ?rst-year students
. . . . Second year students then would be eligible for ?nancing
through the PEAKS program, to have ?nancing for their forward-
looking studies, as well as re?nancing any institutional funding
provided to them during the ?rst year. . . . But it works that way,

second-year students are in the PBAKS program, and ?rst year will
continue to be on the balance sheet.

66. Later in that same call, the CFO clari?ed further:

14

 

Basically the way the program is set up, if you think about the balance
sheet aspects of this, obviously positive cash flow elements there. And
some of that will come from AR [accounts receivable, including
Temporary Credit] that is going to be converted into the PEAKS program,
which was our plan all along.

(Emphasis added.)
67. This ?plan all along? applied to both ITT Private Loan Programs, which served the

same purpose for ITT. Even as ITT discussed the expiration of the PEAKS program in 
a July 21, 2011 earnings call, CEO reminded tweeters that ?we acnrally have 
other third party lending programs, typically I think referred to as the credit union

programs,? that is, the Loan Program. The CEO went on to say that the Loan Program

was ?substantially similar for us relative to the PEAKS program so that it?s structurally

similar and the economies are very, very similar.?

ITT Files for Bankruptcy and Closes Its Campuses

68. In August 2016, the (1.8. Department of Education took a series of actions against 111?
to protect students and taxpayers by banning ITT from enrolling new students using
federal ?nancial aid funds, and stepping up ?nancial oversight of the for-pro?t
educational provider.

69. One month later, in September 2016, ITT abruptly closed its more than 100 campuses
leaving more than 35,000 of its students without a degree and saddled with student
debt, including Loans they needed to repay.

Borrowers, Left with Unaffordable Loan Payments, Default in Large Numbers

70. Former ITT students, having been coerced by ITT into the Loans, face a high likelihood
of defaulting.

71. The Loans carry a high payment, with higher interest rates, more rigid

conditions, and fewer options to reduce payments than federal loans offer. For

15

 

72.

'73.

74.

75.

76.

77.

most former ITT students, this payment, on top of all other loan obligations, is
unaffordable.

The CUSO, post?ITT school closures and bankruptcy filing, projected a gross
cumulative default rate of 94% for the Loans.

The CUSO facilitated the operation of the Loan Program by taking on the management
and oversight of Loan servicing activities, and by distributing portions of Loan i
payments.

According to models constructed prior to the beginning of the Loan Program, the

portfolio was projected to have a 30% default rate. For average ITT students, those with

credit scores below 600, the projected rate was 58.9%.

ITT, through a risk share agreement, in essence guaranteed the portfolio?s performance

above a 35% default threshold. The guarantee required ITT to make a series of

payments to the CUSO based on the percentage of the amount oharged~off with respect

to the Loans.

During the period when ITT referred students to the Loan Program, numerous students 
lodged complaints with the Loan origination agent and the Servicer claiming that they

did not realize they had taken out loans, were not aware of the terms of the Loans, were

not aware that the Loans were not federal loans, and that the ITT Financial Aid staff

had used high pressure and allegedly fraudulent tactics during their ?nanciai aid

appointments.

ITT and the CUSO facilitated access to capital for the Loans, and monitored the

progress of Loan originations within the Loan Program.

16

 

78.

79.

80.

81.

82.

Students were not able to protect their interests in selecting or using Loans because few
students had the resources, particularly in the time permitted, to repay the Temporary
Creditor pay the tuition gap out of pocket, or to obtain private loans elsewhere. Given
the virtual non~transferability of credits, most students were forced to either take
the Loans or forfeit their entire investment.
ITT took unreasonable advantage of ITT students? inability to protect their interests in
selecting or using the ITT Private Loans. knew about these vulnerabilities and
exploited them by taking control of the complex ?nancial aid process, using aggressive
?nancial aid packaging tactics, and pushing students into expensive, high?risk loans
that ITT knew were likely to default.
The above?described conduct was unfair, abusive, deceptive, or otherwise unlawful
in violation of the State consumer protection laws cited in Footnote 1, as well as the
Consumer Financial Protection Act 12 U.S.C. 5531, enforceable by the
States pursuant to 12 U.S.C. 5552.
The Federal Trade Commission?s Rule on the Preservation of Consumers?
Claims and Defenses, better known as the ?Holder in Due Course Rule,? or ?Holder
Rule,? 16 C.F.R. 433, states that ?it is an unfair or deceptive actor practice . . . for a
seller, directly or indirectly, to . . . [?ake or receive a consumer credit contract which
fails to contain? speci?c language, prescribed in the rule, that any holder is subject to
all claims and defenses that the debtor could enforce against the seller.
The loan agreements utilized by the CUSO contained the following clause:
NOTICE: IF THE PROCEEDS OF THE LOAN MADE UNDER
THIS PROMISSORY NOTE ARE USED TO PAY TUITION AN 

CHARGES OF A FOR-PROFIT SCHOOL THAT REFERS LOAN
APPLICANTS TO THE LENDER, OR THAT IS AFFILIATED

17

 

83.

84.

35.

86.

WITH THE LENDER BY COMMON CONTROL, CONTRACT, OR
BUSINESS ARRANGEMENT, ANY HOLDER OF THIS
CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES
WHICH THE DEBTOR COULD ASSERT AGAINST THE
SCHOOL WITH RESPECT TO THE LOAN. RECOVERY UNDER
THIS PROVISION SHALL NOT EXCEED AMOUNTS PAID BY
THE DEBTOR ON THE LOAN.

The States allege that ITT Private Loans are subject to all claims and defenses which
borrowers could enforce against ITT, including but not limited to fraud,
unconscionability and violations of the States? consumer protection laws referenced in
Footnote 1, as well as the failure to deliver promised degrees and educational services
following the closure of HTS schools, each of which would void the ITT Private
Loans.

The States assert that enforcement claims based upon fraud at the origination of the

Loans are available against a holder of the loan under the Holder Rule.

APPLICATION

The provisions of this Assurance will apply to the CUSO and any of its of?cers,
employees, agents, successors, assignees, merged or acquired entities, wholly owned
subsidiaries, and all other persons or entities acting in concert or participation with any
of them, who receive actual notice of this Assurance, regarding the treatment
of the Loans pursuant to the terms of this Assurance.

The States and the CUSO acknowledge that this Assurance is being similarly entered
into between the CUSO and each of the States. The States and the CUSO intend to
coordinate implementation of the terms of this Assurance. Where reasonably possible,

the States will attempt to coordinate communication with CUSO through the Lead

State.

18

 

87.

88.

TERMS
I.

FINANCIAL RELIEF
The CUSO has not acquired and will not acquire loans other than the Loans, does not a
and will not conduct business other than Loan Program business, and will cease
conducting all business upon the completion of its obligations as set out in this 
Assurance. It is currently anticipated that the CUSO will begin the process of 
dissolution, winding up and termination after completion of its obligations
under the Redress Plan, the Bureau Order, and this Assurance.
As of the Effective Date, the CUSO will:

a. Cease all collections activities and cease accepting payments ?rorn Affected
State Consumers related to any Loan;

b. Take no further action to enforce or to collect any Loan of an Affected State
Consumer; and

c. Refrain from selling, transferring, or assigning any Loan.

d. Notwithstanding the requirements of subparagraphs and of this
Paragraph, the CUSO will not be regarded as in violation of this Assurance if
it sends out routine statements or notices that could be considered collection
activity within 20 days after the Effective Date; nor will the CUSO be
regarded as in violation of this Assurance in the event that a payment from an
Affected State Consumer related to any Loan is discovered to have been
accepted or processed after the Effective Date, provided that the CUSO, or the
Servicer acting on the behalf, makes efforts to return the full

payment to the Affected State Consumer as speci?ed in the Redress Plan.

19

 



89.

90.

91.

92.

93.

Within 30 days of the Effective Date, the CUSO will discharge and cancel all
outstanding balances of all Affected State Consumers? Loan accounts, including their
associated fees, charges, and interest.

Within 30 days of the Effective Date, the CUSO will submit written requests to all
Consumer Reporting Agencies to which the CUSO or the Servicer has reported
information about the Affected State Consumers? Loans, directing those Consumer
Reporting Agencies to delete the consumer trade lines associated with the Affected
State Consumers? Loans by updating these consumer trade lines with the appropriate
codes to re?ect that each of those consumer trade lines has been deleted and, if an
explanation is required, with codes referencing a negotiated settlement.

Within 30 days of the Effective Date, the CUSO will send noti?cations to the Affected
State Consumers, by first class mail to the most recently available postal address
contained in the Servicer?s system of record for each Affected State Consumer,
informing them of the new status of their Loans, and the requested updated status of the
credit reporting related to their Loans, consistent with this Assurance.

Except as and to the extent provided herein and in the Redness Plan, the CUSO will
relinquish all dominion, control, and title to all Loan payments made by Affected State
Consumers after the Effective Date. No part of those funds may be retained by the
CUSO.

Upon the Effective Date, the CUSO will begin implementation of the Redress
Plan consistent with the requirements of this Assurance. The States have reviewed the

Redress Plan and have approved it. The Retirees Plan, among other things:

20

 

a. Speci?es how the CUSO wiil notify Affected State Consumers, consistent
with this Assurance, of the new status of their Loans and (ii) the request
to the Consumer Reporting Agencies to update the status of the credit
reporting related to their Loans.

b. Provides an? exemplar of written communications to be sent by the CUSO
or the Servicer to Affected State Consumers regarding their Loans and the
redress provided in this Assurance.

e. Identi?es a Servicer telephone number that will be active fer 150 days
after the Effective Date to assist Affected State Consumers who have
questions about the status of their Loan accounts, and describes the types
of questions to which the Servicer will be prepared to respond.

d. Specifies the efforts that the CUSO will undertake to prevent any payment
made on a Loan item being accepted after the Effective Date.

e. Provides a copy of the notice to be posted to the home page of the
website, maintained by the
Servicer, which notice will provide generai information for Affected State
Consumers regarding their Loans.

f. Speci?es how the CUSO will make efforts to return, to reverse, or
otherwise effectively to reject in full any payment on a Loan of an
Affected State Consumer that has been received by the CUSO or the
Servicer after the Effective Date.

94. In the event that a payment on a Loan of an Affected State Consumer is received by

the CUSO or the Servicer after the Effective Date, and the state of the last known

21

 

residence of the person who made that payment (the ?Payor?) is among the States, and
notwithstanding the efforts pursuant to the Retirees Plan, the refund
remains undeliverable, undeposited or uncashed, or (ii) the payment was received more
than 150 days after the Effective Date, then the CUSO will pay any such funds to the
State of the Payor?s last known residence in accordance with the Instructions Regarding
Unreturnable Payments attached as Exhibit 2 hereto. Prior to any transfer of funds
pursuant to this Paragraph, the Servicer will stop payment on any outstanding refund
check representing those same ?tnds. Under no circumstances will the Servicer or the
CUSO be required to make more than one payment on account of any payment
received after the Effective Date.

95. The CUSO and the States acknowledge that the enforceability of the Affected State
Consumers? Loans is the subject of a dispute and threat of legal action by the States and
the Bureau. The CUSO discontinues collection of those Loans only as a result of this
bona ?de dispute. The CUSO will not issue internal Revenue Service Form
iO99~C?s ("Form 1099?s?) to Affected State Consumers without ?rst having used i
commercially reasonable efforts to obtain guidance from the IRS indicating that the
CUSO is not required to send Form 1099?s to Affected State Consumers as a result of
the debt relief required by this Assurance and the Bureau Order. If such guidance is
sought, the CUSO will notify the Lead State that it has been sought. In the event that,
after any such guidance is sought, the CUSO reasonably believes it is required to issue
Form 1099?s to Affected State Consumers, the CUSO may do so, provided, however,
that if the Taxpayer Advocate Service of the IRS has prepared a fact sheet for Affected

State Consumers, to accompany Form 1099?s, regarding potential tax implications to

22

 

96.

97.

the Affected State Consumers of the Settlement CUSO will cause
to be included, with each Form 1099 sent to Affected State Consumers, a copy of the
TAS Letter.

If any Form 1099 and, if applicable, TAS Letter mailed to an Affected State Consumer
is returned as undeliverable, the Servicer, within 30 days after receiving the returned
mailing, will use commercially reasonable efforts to obtain the Affected State
Consumer?s updated mailing address and, if successful, than will re-send the Form
1099 and, if applicable, TAS Letter to the Affected State Consumer. The commercially
reasonable will include: using a commercial skip tracing service to obtain an
updated address for the Affected State Consumer; sending an email to the Affected
State Consumer?s email address on ?le and requesting an updated mailing address; and
calling the Affected State Consumer using his/her telephone number(s) on ?le,
verifying his/her identity, and requesting an updated mailing address. Assuming the
foregoing yields new mailing address information, the Servicer will make up to three
attempted deliveries of the Form 1099 and, if applicable, TAS Letter to each Affected 5
State Consumer.

The CUSO, whether acting directly or indirectly, may not engage in or substantially

assist in unfair, deceptive, or abusive acts or practices, or violate any of the laws

referenced in Footnote 1 or sections 1031 and 1036 of the CFPA, 12 U.S.C. 5531

and 5536, in connection with the Loans.

23

 

II.

CONSUMER INFORMATION

98. The CUSO, and its of?cers, employees, representatives, and agents who receive actual
notice of this Assurance, whether acting directly or indirectly, may not disclose, use, or
benefit from Consumer Information, except as follows:

a. Consumer Information may be disclosed if requested by a government agency
or required by law, regulation, or court order;
b. Consumer Information may be used to effectuate and to carry out the
obligations set forth in this Assurance; and
c. The restriction on the use of Consumer Information does not apply to the
participating credit unions.


REPORTING REQUIREMENTS
99. The CUSO will notify the Lead State of any development that may affect the 

compliance with obligations arising under this Assurance, including but not limited to
dissolution, assignment, sale or merger of the CUSO, or other action that would result
in the emergence of a successor entity to the the creation of a subsidiary, parent,
or af?liate of the CUSO that engages in any acts or practices subject to this Assurance;
the ?ling of any bankruptcy or insolvency proceeding by or against the or a
change in the name or address. The CUSO will provide this notice, if
practicable, at least 30 days before the development, but in any case no later than 14
days after the development. The Lead State may in turn notify the other participating
States of the development.

100. Within 120 days of the Effective Date, the CUSO will submit to the Lead State:

24

 

a. an accurate written compliance progress report that describes in detail the

manner and form in which the CUSO has complied with this Assurance; and

b. a list of all Affected State Consumers that, for each Affected State Consumer,
will set forth his/her name, corresponding unique identifying Loan
number(s), last known contact information (mailing address, email address
and telephone number), and outstanding Loan balance(s) on the day prior to
the Effective Date (broken down among principal, interest, fees and any 
other amount due and owing);

c. a list of all Affected State Consumers whose notices of discontinuance of
billing and collection of the Loans, after commercially reasonable efforts,
were undeliverable; and

d. a list of Loan payments that were not able to be returned, reversed, or
otherwise effectively rejected, as described in Paragraphs 88 and 93 above.

IV.

ASSURANCE DISTRIBUTION AND CONTACT
101. Within 30 days of the Effective Date, the CUSO will deliver a copy of this Assurance

to the Servicer and to the board, as well as to any CUSO manager, employee,
service provider, or other agent or representative who has responsibilities related to
compliance with this Assurance.

102. The CUSO will direct and provide all notices, submissions, or other communications or
documents required to be sent to the States or requested by the States pursuant to this
Assurance, including, but not limited to notices and reports pursuant to Section 
above, or records pursuant to Section VI below, to the Lead State, Of?ce of the

Kentucky Attorney General, Of?ce of Consumer Protection; Attn: CUSO Settlement",

25

 

1024 Capital Center Drive, Frankfort, Kentucky 40601, by overnight courier or ?rst-
class mail, for appropriate subsequent distribution by the Lead State to the other States.
Nothing herein shall preclude any State from requesting of the CUSO, in writing, that
the CUSO provide any such required notice, submission or other communications or
documents pertaining to residents of that State directly to that State, and subject to the
limitations provided in Paragraph 104 hereof, the CUSO agrees to comply with any
such reasonable request of an individual State.

103. The CUSO will secure a signed and dated statement acknowledging receipt of a copy of
this Assurance, ensuring that any electronic signatures comply with requirements of the
E-Sign Act, 15 11.8.0. 7001 et seq., within 30 days of delivery, from all persons
receiving a copy of this Assurance under this Section IV.

V.
RECORDKEEPING

104. The CUSO will maintain, until the ?rst to occur of the expiration of three years from
the Effective Date or (ii) the dissolution, all documents and records necessary
to demonstrate full compliance with this Assurance, including all submissions made to
the Lead State pursuant to Paragraph 100(a) hereof.

105. Subject to the retention limitations provided in Paragraph 104 hereof, the CUSO, or its
appointed designee if any, must make the documents identi?ed in Paragraph 104 hereof
available to the Lead State upon the Lead State?s request.

VI.
COOPERATION WITH THE ATTORNEYS GENERAL
106. Until the dissolution, the CUSO, and its agents, officers and employees, wilt

cooperate fuliy with the States in this matter and in any investigation by the States

26

 

107.

108.

related to or associated with the conduct set forth in this Assurance. The CUSO will
provide truthful and complete non-privileged, non-work product information, evidence,
and testimony. The CUSO will appear and will cause its of?cers, employees,
representatives, or agents to appear for interviews, discovery, hearings, trials, and any
other proceedings that a State reasonably may request upon 10 days? written notice, or

other reasonable notice, at such places and times as the Lead State may designate,

..-.. . .

without the service of compulsory process.
The States agree to make good faith efforts to coordinate, with each other and with the
Bureau, any such future requests of the CUSO for information, evidence or testimony,
to the extent they are reasonably able, in order to avoid multiple or duplicative requests
of the CUSO and to avoid any undue burden on the CUSO in providing such
information, evidence or testimony; provided, however, nothing in this Assurance will
limit the States? law?il use of civil investigative demands under State law, the use of
examinations under Federal Rules of Bankruptcy Procedure 2004, or any other
discovery device available under State law or the Bankruptcy Code, 11 11.8.0. 101 et
seq. subject to the ability to seek a protective order.
VII.

RELEASE
The States, and each of them, release and discharge the CUSO from all potential
liability for civil violations of consumer protection law that the States have or might
have asserted under the State consumer protection laws referenced in Footnote 1 or
otherwise, based on the practices described in this Assurance, to the extent such
practices occurred before the Effective Date and the States know about them as of the

Effective Date. The States may use the practices described in this Assurance in future

27

 

109.

enforcement actions against the CUSO, 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 States to determine and ensure compliance with this Assurance, or to seek
penalties for any violations of this Assurance.

MISCELLANEOUS -
Each of the Parties is responsible for its own costs and expenses, including, without
limitation, attorneys? fees. Notwithstanding the foregoing, the CUSO agrees to pay
?ling fees for the ?ling of this Assurance with the Courts in the States where such

?ling and such fees are required.

110. The Parties may modify or amend this Assurance in a writing executed by those Parties

111.

affected by the modi?cation or amendment. In those States in which Court approval of

this Assurance was required, notwithstanding any other provision hereof, any time

limit for performance fixed by this Assurance may be extended by mutual written 2%
agreement of the CUSO and the affected State(s) and without Court approval; 

details related to the administration of Sections through VII of this Assurance and to

the terms and implementation of the Redress Plan may be modi?ed by written

agreement of the CUSO and the affected State(s) and without Court approval; and 

any other modi?cation to this Assurance may be made only upon approval of the Court,

upon motion by either Party.

This Assurance will not prejudice or otherwise negatively affect the States? claims

against any other party. Nothing in this Assurance will be deemed to preclude the States

28

 

112.

113.

114.

from pursuing claims against other parties based on the practices described in this
Assurance.
IX.
ENFORCEMENT

This Settlement may be enforced by the States in any and all ways consistent with State



laws. For all necessary purposes, this Settlement will be considered a formal, binding
agreement on the Parties, which may be enforced only by the Parties in any court of 
competentjurisdiction. Any material violation of this Settlement may result in a State
seeking all available relief to enforce this Settlement, including injunctive relief,
damages, and any other relief provided by the laws of the State, or authorized by a
court of competentjurisdiction.

X.

GENERAL PROVISIONS

By agreeing to this Assurance, the CUSO reaf?rms and attests to the material
truthfulness and accuracy of all of the information provided by the CUSO to the States
prior to entry into this Assurance. The States? agreement to this Assurance is expressly
premised upon the material truthfulness and accuracy of the information provided by
the CUSO to the States throughout the course of the investigation of this matter, which
information was relied upon by the States in negotiating and agreeing to the terms and
conditions of this Assurance.

The CUSO will not participate, directly or indirectly (including without limitation by
forming a separate corporation or entity), in any acts or practices prohibited, in whole

or in part, by this Assurance.

29

 

115. Nothing in this Assurance will be construed to waive or limit any right of action by any
individual, person or entity, including, but not limited to any other state or
governmental entity.

116. The Parties acknowledge that the discontinuance of collection of the Loans, as
described in this Assurance, is based on alleged in?rmities in the original creation of
the Loans, stemming from alleged unlawful actions or other alleged misconduct,
perpetrated at the time of the Loans? origination, that allegedly render the Loans
unenforceable, The cessation of collection is for the purpose of correcting the alleged
unlawful business practices and alieged misconduct.

117. This Assurance sets forth all of the promises, covenants, agreements, conditions and
understandings between the Parties, and supersedes all prior and contemporaneous
agreements, understandings, inducements or conditions, express or implied. There are
no representations, arrangements, or understandings, oral or written, between the
Parties relating to the subject matter of this Assurance that are not fully expressed
herein or attached hereto. Each Party speci?cally warrants that this Assurance is
executed without reliance upon any statement or representation by any other Party
hereto, except as expressly stated herein. in the event that any term, provision, or
section of this Assurance is determined to be illegal or unenforceable, subject to
consultation with all Parties to this Assurance, such determination will have no effect
on the remaining terms, provisions, and sections of this Assurance, which will continue

in full force and effect.

30

 

118. The titles and headers in each section of this Assurance are used for convenience
purposes only and are not intended to lend meaning to the actual terms and conditions
of this Assurance.

119. This Assurance will not be construed against the ?drafter? because all Parties
participated in the drafting of this Assurance.

120. This Assurance may be executed in counterparts, each of which will constitute an
original counterpart hereof and all of which together will constitute one and the same
document. One or more counterparts may be delivered by facsimile or electronic
transmission, or a copy thereof, with the intent that it or they will constitute an original
counterpart hereof.

121. Nothing in this Assurance will be construed as relieving the CUSO of its ongoing
obligations to comply with applicable state and federal laws, regulations or rules.

122. Any failure of any of the Parties to exercise any of its rights under this Assurance will
not constitute a waiver of its rights hereunder.

123. The CUSO agrees to execute and deliver all authorizations, documents and instruments
which are necessary to carry out the terms and conditions of this Assurance, whether
required prior to, contemporaneous with, or subsequent to the Effective Date, as
de?ned herein.

124. The Parties agree to this Assurance, without any adjudication of fact or law, to settle
and to resolve ail matters arising under State consumer protection laws, including those
referenced in Footnote 1, based on the allegations asserted herein. The States and the
CUSO understand and agree that this is a compromise settlement of disputed issues and

that the consideration for this Assurance will not be deemed or construed as: an

31

 

admission of the truth or falsity of any allegations made herein; approval by the
States of any alleged act or practice of the CUSO or ITT as described in the Factual
Allegations section herein; an admission by the CUSO of its having lmowledge of
the conduct and acts of ITTadmission by the CUSO that
it has violated or breached any law, statute, regulation, or obligation.

l25. Unless otherwise speci?cally provided, all actions required of the CUSO pursuant to
this Assurance will commence as of the Effective Date.

XI.
RETENTION 0F JURISDICTION

126. In those States in which Court approval of this Assurance was required, the Court will
retain jurisdiction over matters pertaining to this Assurance for pulposcs of its
construction, modi?cation, and enforcement. The Parties may jointly seek to modify
the tonne of this Assurance, which, except as speci?ed in Paragraph llO hereof, may be

modi?ed only by Court order.

7-H.
Dated this If): day of a QUE 2019.

STUDENT CU CONNECT CUS O, LLC

By: -
Li?saeydehdher 

Presi at

32

 

WHEREFORE, intending to be legally bound, the parties have hereto set their hands and seals.

SIGNATURE PAGES TO FOLLOW

33

 

Date: 


For the Petitioner:

COMMON WEALTH OF 
OFFICE OF ATTORNEY GENERAL

JOSH SHAPIRO
ATTORNEY GENERAL

By: 

?sse F. Hawey .
Chief Deputy Attorney General
PA Attorney Id. No. 63435
Bureau of Consumer Protection
1251 Waterfront Place
Mezzanine Level
Pittsburgh, 15222
Telephone: (412) 565-2883
Facsimile: (717) 880-0196
jharvey@attorneygeneral.gov

34

 

For the Rupondonu
STUDENT CU CONNECT EURO. LLC

2.251222223242029 

3mm By 2929222

Eli Bugulro 
20on a: Ludw- LLP
500 AWN, Suite 2790
Detroit. Michigan 43226
(313) 234-9192

99m

 

 

EXHIBIT 1

STATE REDRESS PLAN

 

 

STATE REDRESS PLAN

Student CU Connect CUSO, LLC (the submits, to the States of Alabama,
Arizona, Arkansas, Colorado, Connecticut, Delaware, Florida, Georgia, Idaho, Illinois, Indiana,
Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota,
Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New
York, North Carolina, Ohio, Oklahoma, Oregon, South Carolina, South Dakota,
Tennessee, Texas, Utah, Vermont, Virginia, Washington, West Virginia and Wisconsin, and to
the District of Columbia (the ?States?), acting through their respective Attorneys General,
Departments of Justice, or Of?ces of Consumer Protection, the Redress Plan (the ?Redress
Plan?) referenced in the Stipulated Final Judgment and Order entered in the action entitled
Bureau of Consumer Financial Protection v. Student CU Connect USO, LL C, in the United
States District Court for the Southern District of Indiana.

The Redress Plan, a copy of which is annexed hereto, sets forth a summary of the tasks
that will be performed to implement the settlement entered into by and between the CUSO and
the federal Bureau of Consumer Financial Protection, the methods that will be used in
performing these tasks, and the timeline for completion of those tasks.

The Redress Plan also will serve as the ?Redress Plan? referenced in the 
Assurance of Voluntary Compliance with the States.

 

REDRESS PLAN

Student CU Connect CUSO, LLC (the submits this Redress Plan to the Bureau of
Consumer Financial Protection (the ?Bureau? to set forth a summary of the tasks that will be
performed to implement the settlement with the Bureau, the methods that will be used in
performing those tasks, and the timeline for completion of those tasks. This document will serve as
the Redress Plan referenced in the [Proposed] Stipulated Final Judgment and Order (the ?$988611:
that will be submitted to the United States District Court for the Southern District of
Indiana in the action to be filed therein and to be titled Bursar! Pruiem'an a. Student

CU Connect CUSO, LLC (the ?Action??.

To the extent that this Redress Plan provides for tasks to be performed by the Servicer (as
de?ned below), the CUSO has directed and will direct the Servicer (currently First Associates Loan
Servicing, LLC) to perform those tasks, and the Service: has agreed to perform the tasks using the
methods and in accordance with the timeline set out herein. The CUSO has committed to give
notice to the Servicer of the Effective Date upon learning that it has occurred.

1. De?nitions
The following defined terms, in addition to those set forth above, are used herein:

a. ?Affected Consumers? means those borrowers with Affected Loans (as de?ned
below).

b. ?Affected Loans? means those loans in the Program (as defined below), including
active loans and charged off loans, that have more than a zero balance on the
Effective Date (as defined below).

c. ?Consumer ?op opting Ag gcies? means the credit bureaus and consumer reporting
agencies to which the Servicer (as defined below) has reported information about the
Affected Loans.

d. ?Consumers? means the borrowers, including but not limited to Affected
Consumers, of Program loans.

e. ?Effective Date? means the effective date of the Consent Order.

f. orm 1922? means Internal Revenue Service Form 1099-6, for reporting
Cancellation of Debt.

g. means the Servicer?s standard interactive voice response system.

h. ?Notice? means the noti?cation to be sent by the Servicer pursuant to Section 
below.

i. Borzoi? means the portion of the Website (as de?ned below) that
functions as an entry point for certain Consumers, enabling them, once they log in,
to access individual, accountnlevcl information.

 

II.

j. ?Tayors? means those who make payments on Affected Loans, including but not
limited to Affected Consumers.

k. ?Eroggarn? means the CUSO loan program serviced by the Servicer.

1. ?El; means the written document that will assist the Servicer in responding to
telephonic inquiries from Consumers about the Settlement (as defined below) and
the status of their Program loan accounts after the Effective Date.

ca. ?Sem?cer? means the servicer of the Program loans.

n. ?Settlement? means the coordinated settlements of the CUSO with the Bureau and
the States (as de?ned below) relating to the Program.

0. ?gates? means Arianna, Arkansas, Colorado, Connecticut, Idaho, Illinois, Iowa,
Kentucky, Louisiana, Maryland, Massachusetts, Minnesota, Missouri, Nebraska, New
Mexico, North Carolina, Oregon, Tennessee, Washington, West
Virginia, Wisconsin, and the District of Columbia, and any other state that may join
in the Settlement.

p. ?Website? means the webpage maintained by the
Servicer, that provides general information for Consumers regarding their Program
loans.

(1. mgturgable Funds? means funds from a payment on an Affected Loan that was
received after the Effective Date, which payment either (1) cannot be returned,
reversed or otherwise effectively rejected pursuant to the procedures described in
Sections We, and below, or (2) is received more than 150 days after the
Effective Dateiand (ii) is not required, pursuant to a Settlement agreement between
the state of the Payor?s last known residence and the CUSO, to be paid to that state,
because either the state has not so required or the Payor?s last known residence is not
in one of the States.

Noti?cation to Affected Consumers

The Servicer will identify the Affected Consumers and Affected Loans, by conducting a
query against the servicing system of record that will output a list of Program accounts
with balances greater than zero on the Effective Date.

. The Servicer will prepare a list of all Affected Consumers, which, for each Affected

Consumer, will set forth his/ her name, corresponding unique identifying loan
number(s), last known contact information (mailing address, email address and
telephone number), and Affected Loan balance(s) on the day prior to the Effective Date
(broken down among principal, interest, fees and any other amount due and owing).
The Servicer will identify mailing addresses for the Affected Consumers by locating the
most recently available postal address contained in the Servicer?s system of record for
each Affected Consumer.

Within 30 days after the Effective Date, the Servicer will send to each Affected
Consumer, by first class U.S. mail, the Notice, consisting of a copy of the Notice to
Affected Consumers of Discontinuance of Billing and Collection, in the form of Exhibit
A hereto, and (ii) an account statement re?ecting an updated balance of $0 for each of
the Affected Consumer?s Affected Loans, in the form of the sample Form of Zero

 



Balance Account Statement attached hereto as Exhibit B. The account statements may
be used by the Affected Consumers as veri?cation that no further payment is due with
respect to the Affected Loans.

. If any Notice sent pursuant to Section Ila: above is returned as undeliverable, the

Servicer, within 30 days of receiving the returned Notice, will use commercially
reasonable efforts to obtain the Affected Consumer?s updated mailing address, and, if
successful, then will re~send the Notice, containing the materials outlined in Section Il.c
above, to the Affected Consumer. The commercially reasonable efforts will include: 
using a commercial skip tracing service to obtain an updated address for the Affected
Consumer; (ii) sending an email to the Affected Consumer?s email address on file and
requesting an updated mailing address; and calling the Affected Consumer using
his/her telephone number(s) on file, verifying his/her identity, and requesting an
updated mailing address. Assuming the foregoing yields new mailing address
information, the Servicer will make up to three attempted deliveries of the Notice to
each Affected Consumer.

The Servicer will prepare a list of all Affected Consumers whose Notices, after
commercially reasonable efforts, were undeliverable, including, for each such Affected
Consumer, his/her name and last known mailing address, email address and telephone

number.
Online Account Updates and Service}: Provision of Information

The Servicer will designate 877662-2470 as the telephone number Consumers should
call with questions about the Settlement and the status of their Program loan accounts
after the Effective Date. This number will route through the IVR, which provides basic
account information and an option to speak with a live agent. Commencing on the day
that the Servicer has received notice of the Effective Date, and until the Service:
telephone agents have completed their training to respond to Consumers? questions
pursuant to the Script and the recorded introductory statement set out in the Script has
been activated (but in no event later than five business days after the Effective Date), the
live agents will answer any question concerning the discontinuance of collection of the
Affected Loans by stating, ?We have discontinued collection and enforcement of certain
loans and are in the process of implementing this new policy. More information will be
available by [dafe?va barium cg?ar E?m?m Data] 3?

. Within ?ve business days after the Effective Date, the Servicer will update the online

accounts of all Affected Consumers for all Affected Loans, so that the Affected
Consumers? online accounts for each of the Affected Loans will re?ect a $0 balance as of
the Effective Date; (ii) will make copies of the Notice accessible to Affected Consumers
through the Payment Portal, in connection with their online accounts for the Affected
Loans; (ill) will send an email to each Affected Consumer who is registered to receive,
and who regularly receives, email notices of his/ her Affected Loan statements or
balance(s), providing a link to his/her online account(s) for the Affected Loan(s); (iv)
will post a notice on the Website home page, in form of Exhibit hereto; and will
ensure that (1) Consumers calling the Servicer with questions about the Settlement or the
new status of the Affected Loans will be directed through the NE to the recorded
introductory statement set out in the Script, and (2) those Consumers who opt to Speak

 

IV.

with a live agent after listening to that recorded message will be directed to telephone
agents who will respond to questions in accordance with the Script. The Script is
attached as Exhibit hereto.

The Payment Portal will be deactivated, and will become inaccessible to Consumers, two
months after the Effective Date. The Servicer will maintain its above~referenced
telephone number and the Website for 150 days after the Effective Date, after which
time the telephone line and the Website will be dismantled.



Discontinuance of Collections and Rejection of Payments after the Effective Date

Within five business days after the Effective Date, the Servicer will cease issuing
account statements to the Affected Consumers, whether by mail or by
electronic means; (ii) will deactivate all active recurring and scheduled payments, and
cancel all automatic payment arrangements, relating to the Affected Loans (whether
through ACH or payment cards, via the IVR or the Payment Portal, or otherwise); and
(ill) will initiate additional commercially reasonable efforts not to accept any payment
received after the Effective Date on any Affected Loan, including by arranging for
blocking or automatic reversal of ACH payments and bank transfers.

. Within 30 days of the Effective Date, the CUSO and the Servicer will discharge all

Affected Loans and will cancel all outstanding balances of all Affected Loans, including
principal, interest, fees and any other amount due and owing.

In the event that a check has been received by the Servieer?s automated lockbox, or that
a payment otherwise has been made for which a refund check is necessary (for example,
payment by cash or an electronic payment sent through a bill pay service from the
Payor?s banking institution), the Servicer, within 30 days after receipt of the payment and
identi?cation of the correct CUSO account, will mail a refund check, by first class U.S.
mail, to the most recently available postal address contained in the Servicer?s system of
record for the Payer, together with a Letter to Payer with Return of Post-Effective Date
Payment, in the form of Exhibit E. hereto.

. If any refund check and Letter to Payor with Return of Post?Effective Date Payment

sent pursuant to Section above is returned as undeliverable, the Servicet, within 30
days after receiving the returned check and Letter to Payer, will use commercially
reasonable efforts to obtain the Payor?s updated mailing address and, if successful, then
will Ire-send the check and the Letter to the Payer. The commercially reasonable efforts
will include: using a commercial skip tracing service to obtain an updated address for
the Payer; (ii) sending an email to the Payor?s email address on ?le and requesting an
updated mailing address; and calling the Payer using his her telephone number(s) on
?le, verifying his/ her identity, and requesting an updated mailing address. Assuming the
foregoing yields new mailing address information, the Servicer will make up to three
attempted deliveries of the returned check and the Letter to Payer with Return of Post-
Effective Date Payment to each Payer.

If any refund check sent purSuant to Section We above, and not returned as
undeliverable, is not deposited or cashed within 30 days, the Servicer will use
commercially reasonable efforts over the ensuing 30 days to contact the Payer, at least
additional times, by email or by telephone, in order to advise the Payer to deposit or
to cash the check.

 

V.

f.

g.

The Servicer will prepare a list of all Affected Loan payments received after the Effective
Date that were not able to be returned, reversed or otherwise effectively rejected.

Any payment on an Affected Loan that should be refunded but, notwithstanding the
efforts made pursuant to Sections Nd and above, remains undeliverable,
undeposited or uncashed, or that is received more than 150 days after the Effective
Date, will be paid to the State of the Payor?s last known residence, if that State has so
required in a Settlement agreement between that State and the CUSO, in accordance
with the terms specified in that agreement, or, (ii) if the payment quali?es as
Unreturnable Funds, will be paid by wire transfer to the Bureau or to the Bureau?s agent,
in accordance with the Consent Order. Prior to any transfer of funds pursuant to this
paragraph, the Service: will stop payment on any outstanding refund check representing
those same funds. Under no circumstances will the Servicer be required to make more
than one payment on account of any Affected Loan payment received after the Effective
Date.

Credit Reporting

Within 30 days after the Effective Date, the Servicer will submit a Metro 11 file to all
Consumer Reporting Agencies, directing them to delete the consumer trade lines
associated with the Affected Loans by updating those consumer trade lines with the
appropriate codes to re?ect that each of those consumer trade lines has been deleted. If
any Consumer Reporting Agency should require an explanation, the Servicer will report
?deleted as a result of a negotiated court settlement.?

To identify the appropriate Consumer Reporting Agencies, the Servicer will use its
standard Metro 11 reporting for the Program loans and will update the
Consumer Reporting Agencies? in formation based on the application of a designated
account status for the Affected Consumers? accounts.

The Servicer will respond to all Consumer Reporting Agency inquiries concerning this
procedure.

For as long as the CUSO exists as a legal entity, it will comply with any applicable
requirements under the Fair Credit Reporting Act and Regulation V.

Issuance of Form 10995

If the CUSO determines to issue Form 10993 to Affected Consumers, the CUSO will
notify the Bureau Enforcement Director of that determination, and the CUSO will direct
the Servicer accordingly. The Servicer then will prepare and will send the Form 10993,
by ?rst class US. mail, to the most recently available postal addresses contained in the
Servicer?s system of record for the Affected Consumers.

If any Form 1099 sent pursuant to Section We is returned as undeliverable, the Servicer,
within 30 days after receiving the returned Form 1009, will use commercially reasonable
efforts to obtain the Affected Consumer?s updated mailing address and, if successful,
then will re?send the Form 1099 to the Affected Consumer. The commercially
reasonable efforts will include: using a commercial skip tracing service to obtain an
updated address for the Affected Consumer; (ii) sending an email to the Affected
Consumer's email address on file and requesting an updated mailing address; and 

 

VII.

calling the Affected Consumer using his/ her telephone number(s) on ?le, verifying
his/her identity, and requesting an updated mailing address. Assuming the foregoing
yields new mailing address information, the Servicer will make up to three attempted
deliveries of the Form 1099 to each Affected Consumer. The Services will maintain
copies of ali returned and undeliverable Form 30995 and their envelopes for a period of
'12 months after the initial mailing thereof.

The Service: will respond to all Affected Consumer inquiries concerning the issuance of
Form 10993 by advising the Affected Consumers to consult with their tax advisers, as set

forth in the Script.

Timeline for Retirees Plan and Noti?cations to the Bureau

. The CUSO will comply with all deadlines set forth above and in the Consent Order.

120 days after the Effective Date, the CUSO will provide to the Bureau, on an 
disk or drive:
i. The list of the Affected Consumers, with their last known contact information
and the Affected Loan balances, as described in Section above;
ii. The list of undeliverable Notices, as described in Section 11:: above; and
The list of Affected Loan payments that were not able to be returned, reversed,
or otherwise effectively reiected, as described in Section above.
It is currently anticipated that the agreement between the CUSO and the Servicer will be
terminated after the completion of the Servicer?s Settlement implementation
tasks as described in this Redress Plan.

. It is currently anticipated that the CUSO will begin the process of dissolution, winding

up and termination after the completion of its obligations under this Redress
Plan and the Consent Order.

 

EXHIBIT A

FORM OF NOTICE TO AFFECTED CONSUMERS
OF DISCONTINUANCE 0F BILLING AND COLLECTION

 

E:

SERVICING CUSO 

mm 201 8
BORRO WER NAME
ADDRESS LHVE I
ADDRESS LINE 2
CITY, STATE ZIP

Re: NOTICE THAT NO FURTHER PAYMENT IS DUE ON YOUR i
STUDENT CU CONNECT LOAN
Account 11): (your ?Student CU Connect Loan?)

Dear BORRO WER NAME:

You are receiving this notice because you are a former student of ITT Technical
Institute who received a private student loan in connection with your ITT education,
which loan is now outstanding, owned by Student CU Connect CUSO, LLC (the and
serviced and collected by First Associates Loan Servicing, LLC (?First Associates?). Pursuant to
a settlement with the Bureau of Consumer Financial Protection and certain state Attorneys
General, the CUSO has agreed to discontinue collection and enforcement of the entire
outstanding balance of all such outstanding loans (the "Student CU Connect Loans?), effective as
of [insert Effective Date of settlement].

This notice is to inform you that you are no longer obligated to make any
payment on your Student CU Connect Loan.

The CUSO and First Associates have discontinued billing, and have discontinued
collection of payments, for your Student CU Connect Loan. There will be no further action by
the CUSO or First Associates with respect to any balance previously due and owing on your
account. An account statement reflecting a $0 balance on your Student CU Connect Loan is
enclosed with this notice, and you may use this account statement as veri?cation that you are not
obligated to make any further payment on your Student CU Connect Loan.

Additionally, all consumer credit reporting agencies to which the CUSO and First
Associates formerly reported credit information concerning your Student CU Connect Loan will
be directed to delete the trade lines regarding your Student CU Connect Loan.

If you have other outstanding Student CU Connect Loans, they wiil be treated in
the same manner. You will receive a copy of this notice and an account statement re?ecting a $0
balance for each of your outstanding Student CU Connect Loan accounts.

 

it is possible that some billing statements or other notices relating to your Student
CU Connect Loan(s) were mailed prior to or shortly after the effective date of the settlement. If
you receive such a billing statement or notice from the CUSO regarding your Student CU
Connect Loan, you may disregard that document, as it is no longer valid, and payments are no
longer required on any Student CU Connect Loan.

First Associates will reject or return any payment on your Student CU Connect
Loan(s) that it receives after [insert E??ecn?ve Date of settlement].

If you have a recurring or one-time electronic payment through the First
Associates payment platform that is scheduled to make any payment on your Student CU
Connect Loan(s) after the date of this letter, please note that First Associates has cancelled that
payment, and all future payments, for your Student CU Connect Loan(s).

If you were sending payments directly through a bill pay service from your
banking institution, you will need to contact your bank immediately to stop the payments on your
Student CU Connect Loan(s). First Associates is not authorized to stop these transactions, as
they are sent from your banking institution.

Please note that you may have other types of loans related to your education
that are not Student CU Connect Loans. This notice relates only to your Student CU Connect
Loan(s) and does not apply to any other obligation you may have (even if serviced by First
Associates), including other debts associated with your XTT education, loans owned by someone
other than the CUSO, or loans that once were owned by the CUSO but were paid in full prior to
[insert E?ective Date of settlement].

Any questions about this notice or the status of your Student CU Connect Loan
account(s) may be directed to:
Student CU Connect CUSO, LLC
PI). Box 503430
San Diego, CA 92150-3430

com
877662?2470

Further information about the settlement is available through the Bureau of Consumer
Financial Protection?s public website and telephone line ((855) 411-2372 or
(855) 7292372)).

Sincerely,

 

Student CU Connect CUSO, LLC

31101.: Account Statement [re?ecting a 30 loan balance]

it

 

EXHIBIT 

FORM OF
ZERO BALANCE ACCOUNT STATEMENT

 

 

 

 

 
  
 

StUdent CU Accountaummary
Amwnt?umba: 
Om MINNIE
Payment $0.00
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617-652-2470
Amount Rammed I I
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In CON
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Amount
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charged
mum: charged $0.00

 

 

..

 

EXHIBIT 

FORM OF
NOTICE TO BE POSTED ON THE WEBSITE HOME PAGE

 

NOTICE THAT 0 FURTHER PAYMENTS
ARE DUE ON STUDENT CU CONNECT LOANS

Pursuant to a settlement with the Bureau of Consumer Financial Protection and
certain state Attorneys General, and effective as of [insert E??ecttve Date of settlement], Student
CU Connect CUSO, LLC (the has agreed to discontinue collection and enforcement of
the entire outstanding balances of all outstanding CUSO loans made to former students of HT
Technical Institute who received private student loans in connection with their 
education (the ?Student CU Connect Loans?).

Borrowers are no longer obligated to make any payments on their Student
CU Connect Loans.

The CUSO and the serviccr of the Student CU Connect Loans, First Associates
Loan Servicing, LLC (?First Associates?), have discontinued billing, and have discontinued
collection of payments, for all Student CU Connect Loans. There will be no further action by the
CUSO or First Associates with respect to any balance previously due and owing on any account.

An account statement re?ecting a $0 balance for each Student CU Connect Loan
with an outstanding balance as of [insert E?ective Date ofsettiement] will be delivered to each
borrower of those Student CU Connect Loans, and these account statements may be used as
veri?cation that the borrowers are not obligated to make any further payment on those Student
CU Connect Loans.

First Associates will reject or return any payment on Student CU Connect Loans
that it receives after [insert Effective Date of settlement].

For those borrowers who have recurring or one?time electronic payments through
the First Associates payment platform that are scheduled to make any payment on a Student CU
Connect Loan after [insert Effective Date of settlement], please note that First Associates has
cancelled those payments, and all future payments, for Student CU Connect Loans.

If you were sending payments directly through a bill pay service from your
banking institution, you will need to contact your bank immediately to stop the payments
on your Student CU Connect First Associates is not authorized to stop these
transactions, as they are sent from your banking institution.

Additionally, for each borrower who had an outstanding balance on a Student CU
Connect Loan as of [insert E?eetive Date of Settlement], all consumer credit reporting agencies
to which the CUSO and First Associates reported credit information concerning that Student CU
Connect Loan will be directed to delete the trade lines regarding that Student CU Connect Loan.

It is possible that some billing statements or other notices relating to Student CU
Connect Loans were delivered prior to or shortly after the effective date of the settlement. If you
receive such a billing statement or notice from the CUSO regarding your Student CU Connect

 

Loan, you may disregard that document, as it is no longer valid, and payments are no longer
required on any Student CU Connect Loan.

Please note that borrowers may have other types of loans related to their ITT education
that are not Student CU Connect Loans. This notice relates only to Student CU Connect Loan(s)
with balances as of [insert li'?f?etive Data of settlement], and does not apply to any
other student loan (even if Serviced by. First Associates), including other debtsassoeiated with
IT-T, leans oW?ned by someone other than the CUSO, or loans that once were owned by the
CUSO but were paid in full prior to [insert E??ctive Date of settlement].

Any questions about this notice or the status of a Student CU Connect Loan
may be directed to:
Student CU Connect CUSO, LLC
P.O. Box 503430
San Diego, CA 92150?3430

377-662-2470

Further information about the settlement is available through the Bureau of
Consumer Financial Protection?s public website and telephone line
((355) 4114372 or (855) 729-2372?.

 

EXHIBIT I)

FIRST ASSOCIATES SCRIPT
FOR ANSWERING CONSUMER INQUIRIES
CONCERNING THE SETTLEMENT AND ITS IMPACT
ON THE STATUS OF THE PROGRAM LOAN ACCOUNTS

 

 its: Set-i 
to: ansmeting. Consumer ingm'g'leg concer?g
the settlement and its impact on the s. tatus ofvthe nggtam loan @0me

 

Thank you for calling about the recent settlement between Student CU Connect CUSO and the
Government.

The Bureau of Consumer Financial Protection, along with the Attorneys General of several states,
entered into a settlement with Student CU Connect CUSO concerning collection and enforcement
of private student loans that were made to students of ITT Technical Institute, and are owned by
the CUSO. Under the settlement, Student CU Connect CUSO agreed to discontinue collection
and enforcement of the entire outstanding balance of each of these loans.

What this means to you is that: if you are a former student of ITT Technical Institute, and (2)
you received a private student loan in connection with your ITT education, and (3) that loan is
owned by Student CU Connect CUSO, and (4) that loan had an outstanding balance clue and owing
as of Date then you do not have to make any further payment on that
loan.

If you still have questions about your Student CU Connect loan, please stay on the line, or dial
to speak with a live operator.

If you still have questions about the settlement, you can contact the Bureau of Consumer Financial
Protection through the Bureau?s public website and telephone line
((855) 411?2372 01' (855) 729?2372?.

We 
Elwood}? who settled what with Whom and Why?

For details about the settlement, you can contact the Bureau of Consumer Financial Protection
through the Bureau?s public website and telephone line ((855) 411-2372.
or TDD: (855) 729-2372?. In what State do you live? {aback against fin? :y'pan?iojtakhg states, 2?0
be .mpp?ea?. b" taller lives it: one tam states and it be: it: own contact iaybmmaa?w borrowers} You also can
get infotmation from your State at {list cy?pqu?ba?rg tiara: am! campaadzhg contact in?mm?ioa to be

applied} .

What does the settlement mean to me?

 

Under the settlement, Student CU Connect CUSO agreed to discontinue collection and
enforcement of the entire outstanding balance of each of the loans that it owns.

Am 1? affected?

You are affected if (1) you are a former student of HT Technical Instimtc, and (2) you received a
private student loan in connection with your education, and (3) that loan is owned by Student
CU Connect CUSO, and (4) that loan had an outstanding balance due and owing as of [insert Effective
Date ty' settlement].

This applies date on your payments, or if you are delinquent in your
payments, or if you have defaulted on your loan.

I aheady paid o?'my loan?

If you previously have paid off your Student CU Connect loan, the settlement does not affect you or
that loan.

We Is the reliefrhat affected borrowers receive?

Student CU Connect CUSO and First Associates have discontinued billing, and have discontinued
collection of payments, for Student CU Connect loans with outstanding balances due and owing as
of [insert E?ctius Dots g/set?smmj.

This includes the outstanding principal amount, as well as any and all outstanding fees, penalties and
other account charges.

There will be no further action by Student CU Connect CUSO or First Associates with respect to
any balance previously due and owing on your account.

An account statement reflecting a 30 balance on your Student CU Connect loan has been, or shortly
will be, sent to you, and you may use this account statement as veri?cation that you are not obligated
to make any further payment on your Student CU Connect loan.

What Whopper: to any negative credit reporting that may have ?owed myla to
payment, argon-pa?neng ofmy CUSO Joan?

Student CU Connect CUSO is requesting that credit reporting agencies delete any reference to these
accounts from the credit reports of the affected borrowers.

If you previously paid off your Student CU Connect loan, no change will be requested on your
credit report. It will continue to re?ect that you made payment in full.

.00 I need to take any action to qualify for re?ex?

No. Affected borrowers do not need to do anything to receive the relief. The relief is automatic.

 

Does the discharge ofmy Joan a?oat myincome tax liabiliqri?

The IRS has not made a ?nal determination concerning whether Student CU Connect CUSO must
send you a Form 1099 in connection with the discharge of your Student CU Connect loan.

If the IRS requires Student CU Connect CUSO to send you a Form 1099, that will not necessarily
mean that the discharge of your Student CU Connect loan will give rise to income tax

liability. Based on your personal circumstances, you may be able to exclude the discharged debt
from your taxable income. You should consult your tax advise: if you have questions in this regard.

Does the reliefextend to any other loan?

The settlement affects only amounts owed on Student CU Connect loans as of [firms E??m'ue Date of
settlement].

The settlement does not affecr any amount that you may owe on federal student loans, or on any
student loan held by PEAKS, by itself, or by another entity other than Student CU Connect
CUSO. .

The settlement does not affect any Student CU Connect loan that already has been paid in full.

If you have a federal student loan or another ITT~relatecl private loan, you must contact your lender
to determine if you remain responsible for paying it. If you are still obligated to make those
payments, failure to do so could harm you, by creating delinquencies and negative remarks on credit

reports.
What about my other loans that are serm?ced by First Associates?

The settlement affects only amounts owed on Student CU Connect loans as of [imm?B??s?ve Date a
realm/emf]. It does not affect any amount you may owe on another loan, even if that loan is also
serviced by First Associates.

We: is the amount of my Joan that was discharged under the settlement?

If you have questions about your payments to First Associates, or about the outstanding
balance on your Student CU Connect loan, please provide your account number, and we will assist
you. {Lean-ma?a gaes?oas to be answered as apparition}

 

EXHIBIT 

FORM OF LETTER TO PAYORS
WITH RETURN OF POST-EFFECTIVE DATE PAYMENT

 

 SERVICING CUSO 

mm 201 8
PA FOR NAM
ADDRESS LHVE I
ADDRESS LINE 2
CITY, STATE ZIP

Re: NOTICE OF REJECTION AND RETURN OF PAYMENT
Account (your ?Student CU Connect Loan?)

Dear PAYOR NAM:

You are receiving this notice because you are a former student of ITT Technical
Institute or have made a payment on behalf of a former ITT student, who received the
private student loan with the account identi?cation number referenced above, and because we
received a payment from you in connection with that Student CU Connect Loan after [insert
E?ective Date of settlement].

Pursuant to a settlement with the Bureau of Consumer Financial Protection
(?Bureau?) and certain state Attorneys General, the owner of your Student CU Connect Loan
agreed to discontinue collection and enforcement of the entire outstanding balance of the Loan,
effective as of [insert E??ective Date of settlement]. As a result of the settlement, you are no
longer obligated to make any payment on your Student CU Connect Loan.

Because we received a payment from you after the date we stopped accepting
payments on your Student CU Connect Loan, we are returning the payment to you. Enclosed
please find a check representing the return of funds received from you.

Please deposit or cash this refund check as soon as possible. If you fail timely
to deposit or to cash this check, the check will be cancelled after 60 days [or such other longer
period, ifany, as may be required by First Associates? banking agreemen? as noted on the face
of the check, and the funds will be deemed to be unclaimed property and will be sent to the state
of your last known residence or the Bureau.

IF APPROPRMTE: This check represents a refund of the electronic
payment you sent from your banking institution. We are not authorized to Stop these
transactions, as they are sent from your banking institution. Please contact your bank
immediately to stop future payments on the Student CU Connect Loam]

 

Any questions about this notice or the status of your Student CU Connect Loan
may be directed to:
Student CU Connect CUSO, LLC
P.O. Box 503430
San Diego, CA 92250-3430
.
877662-2470

Further information about the settlement is available through the Bureau of

Consumer Financial Protection?s public website and telephone line .2
((855) 411-2372 or (855) 729-2372?. 

Sincerely,

 

Student CU Connect CUSO, LLC

 

EXHIBIT 2

INSTRUCTIONS
REGARDING UNRETURNABLE PAYMENTS

 

Instructions Regarding Untemmable Payments

 

State Mode of Pam em '5 Address to which To Send Additiog Contacts for Reference inthe
i Check {13" 'gg] and Cover 1 Event of Questions.
Alabama Check payable to State of Alabama - Of?ce of Cover letter stating the Noel S. Barnes

. ?State of Alabama the Attomey Gmetal identity of the payer,1 and Assistant Attorney General

Of?ce of the 501 Washington Avenue the last known contact State of Alabama
Attorney Genetal? Montgomery, Alabama 36130? information for the payer 3341-3533196
1 - 0152 5 nbames'QagostateaLus
Arizona. Check payable to O?ce of the Attorney Genecal Covet letter stating the Shane Foster
?State of Arizona Attention: Consumer i identity of the payer, and Suzie): litigation Counsel
Attemey Genetal?s Protection. 6: Advocacy Section the last known contact O?ce of the Arizona Attorney
Of?ce? or by such 2005 N- Contra}. Avenue infomJa?on for ?ne payer General
other means as the '2 Phoenix, Anzena 85 004 oozseem
parties may agree These payments will be shanefostct@azag.gov
deposited in an mtetest? 1
beanng account within the
Consumer Res?tu?on and 
Remediation Revolving 
Fund pursuant to Adz.
., 3 Rev. Stat. 444 531.0203) 1-
Arkansas Check payable to 3 Andrea Lee, Auditor of State Covet lettuce stating the David AF. McCoy
?Audiwt of State? Unclaimed Property Division - identity of the payer, the Assistant Attorney General
. 1401 West Capitol Avenue last known contact Of?ce of Arkansas Athemey
Suite 325 information for the payer, Genezal Leslie Rutledge

Little Rock, ?tkansas 72201 and that Fitet Associates 501-682-7506

I I I has attempted to notify davidmccoy@atkansasag.gov
i the payee i

 

1 Throughout this do cement the term ?payer? is used to refer to the student bettowet or mine: payer who made the metamable
payment.

 

 

or
i Ejosh Wood
i 501-682-6000

Colorado Check payable to Colorado State Tram Cover letter stating that Olivia. D. Webster 
. ?Colorado State Unclaimed Property Division the ?mds are being Senior Assistant General 
Treasury 1580 Logan Steet remitted pursuant to 720-508?6203 
Unclaimed Suite 500 agreement with the 
Property Division? Denver, Colorado 80203 Colorado Attorney 
General
I 
First Assodates? 
TIN PEN must appear 

 

E.


on the check
Connecticut Check payable to State of Connecticut Cover 1ette1: stating that Cathy Kristof
Of?ce of the State Treamrer the ?m?s are being Associate Examiner
Property Division, Unclaimed Property Division remitted pursuant to Of?ce of the Treasurer 
Connec?cm Of?ce RC). Box 150435 agreement with the _-860 702-327 6
. of ?ne Treasurer? Hartford, Connecticut 06115? Connecticut Attomey 
I 0435 

 

or

. Attention: Cathy Kristof, '5 Enclose completed and 
Associate Examiner notarized Form ST77, 30331331} (31131115313
3, available at Assistant Attorney General
. XXWW 860- 803-5270
cpdocs/2017/ReportofUn 1' cs 32- chamber 

claimedepertyFormSI? 
77? Octobec%202017.pcif 

  

 

 

In completing the form, 
1 use NAUPA code M311 
("Re?l?ds Due?): 


Ifmexe than three checks 
. are to be sent, contact
i ECaththistoffer further
instructiom 

 

Delaware Check payable to Delaware Department of Cover letter stating the Cb?s?an Douglas Wight,
?State of Delaware Justice - identity of the payer, the Director of Consumer Protection
Consume: Am Director of Consumer 3 last known contact Delaware Department efjustice 5
EPtetection Fund? EPtotectiee ?infonna?en for the payer, 302-577?8944 
820 Ner?a French Street the social secutity number 
5th Floor of the payer (if available) 
:mmingmn, Delaware 19301 Emd the amount for each
Payer: and identifying 
impart? (by name: 1
a . contact infoma?en, and 
I BIN) onwhese behalf the 
check is submitted 

 

 

District of ?1 Check payable to Benjamin M. Wism Cover letter stra?ng the Benjamin M. Wisemzn
Coiumbia Treasmet? Director, Of?ce of Consume: identity of the payer, and Director, Of?ce of Consumer
. Pretec?en the last known contact Protection
3 D.C. Of?ce of the Attemey iofozma?en for the payer Of?ce of the Attorney General
. General 202?741-5226
441 Street NW Any part of these funds, at Benfaminm'is 
. Suite 6008 the discretion of the 
i Washing-teal, DC. 20001 i Attorney General for the 
District of Columbia, may 
be (2) held by the Disttict a.

 

 

 

2 refers to the National Association of Unclaimed Property Adminisocators.

3

 

Florida

Check payable to

?Department of
5 Legal Af?nirs

I Escrow Account? 

Check payable to

Department of

O?ce of the Attorney
General, State of Florida
3 Arm. Robert: Eddman; CU SO
AVC
1300 Rivet-place Boulevard
Suite 405
Jacksonville, Florida 3220?

Consumer Protection Division

Georgia Department of Law

2 Martin Luther King, Jr. Drive
Suite 356

A?anta, Georgia 30334

as unclaimed property on

behalf of consumers or 

used in accordance with

District iaw for any other .

i lawful purpose including
?the payment of res?mtion

i to impacted consumers.

3 The check should include
the infoma?on 9?3~
1294? on the face of the

check.

3 Cover letrec swing the

i payer?s name, last known

contact information, and 

that funds are being

rcmitned subject to

AVG 1.19?3-
132?94?

1 Cover 16:1:th referencing
the AVG and including
the following information:
ithe idenzity of each payor,

i the amount of funds due
to each payor, the lasr

5 known contact

infoma?on for each

payor, the social security .

_numher or taxpayer

:iden??ca?on number, if 3

known, or payer, and
:the 5 Federal
Employer ID Number

 

 

3. Assistant Attomey Gmeral Robert
Edelrnan

O?ce of the Attorney General,

3 State of Florida

(904) 343?2720 3
1





1
I


Chrisn'ne Hom

3 Assistant Attorney General
Consumer Protec?on Division
404?656-4739
chom@law.ga.gov

 



 

:Check payable to
?Idaho Unclaimed

Eonpezty?

Transfer of ?mds
- _made via the

Eminois State

Treasoxex?s O?ee? .

 

Idaho State Treasuxex?s O??ce
Unclaimed Property
- PO. Box 83720

Boise, Idaho 83720-910}



Check to be accompaoied.

1. by a. ?holder report? using
the NAUPA format: or
manually, at



5 Megan Gregory

Business Spedalist
Unclaimed Property O?ce
208-332- 2977

 

gov/app/mbmit?a?report 

1

EFunds to be seotwith a.
report Submitted via the
same 0331511?: portal as the
funds, which report must:
be signed by or on
behalf of First

Associates or the

as to its completeness

and accuracy;
2. iden?fy the amount ofE

funds due to the payer

GI

Jane Hochbetg
Deputy Attorney General
208?332-3553 . 

 

Gregory jones

Assistant Attorney General
312614-4987

5 

 

coso andbe veri?ed

i

II

and the umber of any .-

uncashcd

reimbursement cheek

3. s?cate the name; last?
known address

i



inchdingzipcodgif 

known; and social
secmity number or

taxpayer identi?cation e.

 

 

Check payable to

3' ?Of?ce of the

Indiana Attorney


or by such other

a means as the

1 parties may 3:21?

Check payable to
?Treasurer of the
EState of Iowa?

number, if known or 
readity ascertainablc, of 

the payer,
4. state the date of the
uncashed




5. state that the funds are
being remitted
pmsuant to agreement
with the Ii?nois

taken to return the

sentto thepayogand


1



funds to ?ee owner of

such funds in

accordance with that

agreement, but the
payer has not been
located

Of?ce of the Indiana. Attorney Cover letter stating the

Geneml

302 West Washington Street

- IGCS Fifth Floor
Indianapolis, Indiana 46204

Iowa State Treasurer?s Of?ce
5 Unclaimed Property

1 13.0. Box 10430

5 Des Maine-s, Iowa 50309



identity of the payer the
last known contact

:that can help
identify/locate the
individtml

Cover letter stating that

1 the ?mds are being

remitted pursuant to
agreement with the Iowa
Anomy General

1
1

Clinton Bohm

Director of Finance
O?ce of the Indiana Attomey
information for the Genera}

and any other information 317 234?7131



317-525 5192

Clmtombohm@atg.in.gov

Jessica Whitney

Special Assistant Attomey General

. 515?281?5926

"essica.wh1m' - 

 

 

First Asseciates?
must appear
. on ?ne check 
Kansas Check payable to I Sarah M. Dietz iCover letter stating the FTabe?rla Mallonee
?O?ce of the Assistant Attomey General 1 identity of the payer, and Director of Fiscal Opera?ons
Kansas Attorney Of?ce of the Kansas Attorneyi the last known contact IO?'ice of the Kansas Attemey
General? 3 General information for the payer, General
I 120 SW 10'h Avenue and that the funds ate 785?296-: 553
2'?1 Floor remitted pursuant to the Tabefnama?enee?agkagev
Topeka, Kansas 66512 agreement with the 1
J, Kansas. Attorney General 
Check payable to Of?ce of the Attorney General Cover letter stating the Todd E. Leatherman
. ?Kentucky State :1024 Capital Center Drive identity of the payer, and Special Attorney
Treasurer? Suite 200 the last known contact Of?ce of the Kmtucky Attorney

Frankfort; 40601 infomation for the payer General
I

Arte: Todd Inathennan 5. 502696-5384
3 Tod?emerman?llmgov
Louisiana Check payable to :State Capitol Building Annex Covet letter stating ?ee Gite
?State of Louisiana 1051 N. 3}?1 Street iden?ty of the payer, the Assistant Attorney General
Unclaimed Room 150 1. last known contact 225-326- 6414-
Property Division? Baton Rouge, Louisiana 70802 infoma?en for the paon gitsc@a.g.leuisiana.gov
and that the funds are 
remitted pursuant to
agreement with the 1:
Louisiana Attorney 
Maine Check payable to 2 Of?ce of Maine Attorney Cover letter stating ?ee Linda Conti
.F ?State of Mne i General identity of the payer, and 3 Assistant Attomey General
attomty General 5 11 1 Sewall Seen: the last atom contact 207-626-8591
Of?ce? FBurten Cross State Of?ce information for the payer 
Building 
Floor 
Augean, Maine 04330 i

1

1
I

?mww?vll? -v -

 

 

 

 

?5 Atto: Consumer Protection

Maryland i Cheek payable to Unclaimed Property Division

?State ofMaryland Comptroller of Maryland

Unclaimed 3 Attention: Eric Eichler
Property Division?

Cover letter stating:

1. the identity and last
known contact

5 301 West Preston Street

Room 310

Baltimore, Maryland 21201

 

last known address, for
the payer;

that the funds are
memable ?lnds
being delivered
pursuant to an
agreement with the
Maryland Attemey
General;

. the amount due to the
1. Palm:

1 the date that the
payment to he

 

- the date of the last
transaction with the

payer with respect to

the funds (that is, the

date that the last letter

 

was senttao, orthelast 

contact was actually
made with, the payer)

information, including
but not limited to the 

Christopher Mdaio
Assistant Attorney General
410~576~6585
emadaio@oag.state.md.us






I

submitted to the state
was ?rst received; and 7

 

O?ce of ?ne Attorney General? Covet letter stating the
?Commonwealth ATTN Katie Hurley Eiden?ty of the payer, and
i of Massachusetts? Insurance and Financial 'the last known contact
Service: Division information for the payer
One Ashburton Place 

Massachusetts Check payable to

Diane Hooley

 

.1 Asnstan' tAttomey General
617-963-2198
Idianahool

 

 

 

Minnesota

Check payable to
?State of Mchigan?

Check payable to
3 ?Sense of
Minnesota?

Check payable to
?Mssissippi

Attomey General?s

Of?ce?

18th Floor

Boston, Mssachusetts 02108

Mchigan Department of
Attorney General

Corpomte Oversight Division

P.O. Box 30736

Lansing, Midnigan 48909

Katherine Kelly

Minnesota Attomey General's

445 L?nnesota Street

Suite 1200

=3 SL-Paul, Minnesota 55101
5 Bridgette W. Wiggins

Consumer Protection Division
Mississippi Attorney General?s

O?ce
Post Of?ce Box 22947
. jackson, Mississippi 39225

Cover? leaner stating the

name and last known
comaet informa?on for

i the payer, and, in the

event of multiple payers,

Brian G. Green

Assistant Attorney General
Corporate Oversight Division
517?335~7632

. greenb@micbigan.gov

the amount due per payer 

Cover letter stating the
3 identity and last known
contact information,

including but not limited

Katherine Kelly

7 Assistant Attorney General

1 651-7574 308


to the last known address,

for the paw:

Covet: letter stating the
iden?ty and last known
contact infoma?on,
including but not limited
to the last known address,
for the payer

Bridgette W. Villains
Director, Commune}: Protection

'on

3 Mississippi Attorney General?s

Of?ce
601359?4279


 

Check payable to
?Mssouri State
5 Treasurer?s Of?ce?

Mssouri State Treasmer?s

Of?ce

Unclaimed Property

- P.O. Box 11272

Jefferson City,Missouri
65102?1272

Cover letter stating that

the ?mds are being
ren?rted pursuant to

agreement with the

Missouri Attorney

General, and diligent,

good faith efforts were

taken to ream: the funds

so the owner of such

in accordance with
?rat agreement, but were
unsuccess?al

Mssouri State Treasurer?s Of?ce

Unclaimed Property
573?751?8533
Massacre?

  

;or

mend Schwalberr

..
Attorney Gmeral

1 314?340?7888



 

 

 

 

 

 

Nebraska

ENevada

New
Hampshire

Check payable to
?Nebraska State
Treasurer?

Check payable to
?Nevada State
Treasurer?

Check payable to
?Treasurer, State of
New Hampshire?

Enclose completed

Unclaimed Property

Report Form (available,

with instructions, at

W. treasurer. mogov/U
gnclaimedPropertyIPDFs 



Nebraska State Treasurer Covet letter erasing the
Attention: Meaghan Aguirre iden?ty and last known
Director of Unclaimed contact infonnadon,

i

Property including but not limited
809 Street Eto the last known address
Iineoln, Nebraska 68508? 1390I for the payer

5 Nevada State Treasurer Cover letter stating the
Arm: Unclaimed Property idennty and last known
555 East Washington Avenue contact infomation,
ESuitc 4200 iincluding but not limited
Las Vegas, Nevada 89101 to the last known. address, 2

for die payor

'I'homas Madnespie Cover letter stating (to the
Abandoned Property Director extent the information 15

- 25 Capitol Street available) the identity and
.- Concord, New Hampshire last known COIltaCt

03301 information, including but 5

I not limited to the last
known address, for the

paw, date ofbirth of the 3

payor social secu?ty

I number of the payer, and 

i amount of payment to be
reamed

 

Meghan Stoppel
Chief, Consume: Protemion
EDivision
EAssistant Attorney General
402-471-0858

In hansto e1 _nebrasl:a; 
Elinda Tobin

EDeputy State Treasurer
702?486-4354
itobin@nevadatreasuret.gov

Thomas MeAnespic

Abandoned Property Director

603-271-1499


i

1





 

Newjersey

3 Check payable to
5 ?Ncwjersey
5 Division of

Case Initiation and Tracking Cover letter stating the i

Unit identity of the payor, 
3 New Jersey Division of social security number of

 

10

 

   

 

New Mexico

 

 

NewYo?t

North
. Carolina

Check payable to
?New Mexico

3 Of?ce of the

Attomey General?

Attention: Chief Financial
Of?ce:
P.O. Drawer 1508

Consumer Affairs 

Of?ce of Consumer Protection i
124 Halsey Steet

7tht Floor

2 Newer}; Newjersey 07102
Attn; Van Mallett, Lead
Investigator

the payor, last known 

contact information,

5 including but not limited

1 to last known address, for

i the payoz, the amount

of ?mds due to the payer,
that good faith efforts

were taken to 1343111131 the

funds to the payer, but

i that the payer has not

been located, and the
funds are being sent
pmsuant 130 an agreement
with the Of?ce of the
Newjersey Attorney

5 General

Of?ce of the Attorney General

3 Sane Fe, New Mezdco 87504?

31503

:3 Check Payable to
?State of New
York?

Check payable to
?North Carolina
1. Department of

Justice?

and Protection
1 28 liberty Street

Justice
Attention: Matt Liles, Assistant
Attorney General

3 1 14 W. Bdeoton Street

Carolyn Fast, Special Counsel
Of?ce of the Attorney General
Bureau of Consumer Frauds

1

New York. New York 10005
North Catalina Department of 

adage North Carolina 27603

11

Cover letter stating the

identity and last known
contact infomation,
including but not limited

I

5

i Cholla Khoury 1
1 Assistant Attoxney General .1
505-490-4060 
c?kho - 

 

to the last known address,

for ?ne payor

Cover letter referencing
the Assurance and sta?ng

the identity, Jasr known
I. contact infomation, and

amount due to be
re?mded to each payer
Cover letter stating the

3 identity of the payer, and

the last known Contact

3 Carolyn Fast; Special Counsel

1 O?ce of the Attomey General
Bureau of Consumer quds and

I Protection

212-416-6250

I Carolyn?st?agmygo?

Matt mes

Assistant Attorney General

919-716?0141

1 information for the payer mliles@ncdoi-g0V

 

 

 

Ohio Check payable to . Ohio Attorney General?s Cover letter referencing Eje?'rey Loam:
#01310 Attorney .2 Of?ce Ethe ave, statingthe ESenior Attorney General
General?? do Jeffery Loose: identity of the payor, and 614?466? 8831
30 East Broad Street the last known contact JeEloeser@OhioAttomeyGeneraL
j, 14"? Floor in?ammation for the payor. gov 
Columbus, Ohio 4-3215 
i salt to the
Ohio Attorney General .
pursuant to Paragraph 94 .:
of dais AVG shall be 5
considered consumer 
E. restinrtion under 03C. 1
1345.01 ct scg? E.
Oklahoma Check payable to Oklahoma State Treasurer - All checks must have a EDooice 1312ch 
?Oklahoma Stare Unclaimed Property Division notarized Veri?cation and? Senior Unclaimed Property Auditor 
Treasurer 2300 N. Lincoln Boulevard Checklist~ in the form of? Oklahoma State Treasurer?s Of?ce 
Unclaimed Room 217 Font; Nmber 49 6-UP- 405522?4086
Property Division? Oklahoma City, Oklahoma 731C Revision 05072018, to be
found ar

1

i
1


 



Include payofs full

name, date of birth, social

security number, last
known address (with zip
Ecode), and phone number;

the iden?fying number
and date of the payer?s
i erroneous payment (erg,
7' check number, transaction 
number, etc), as Well as

12

 

 

the date on which that .
ipayment was received by 
1 the Services/CUSO; and 1
the total amount due 1

this payer

 

?Oregon
1 Department of
Justice?
1 Check payabie to
1 ?Commonwealth
1 . of 
1 Of?ce of Attorney
1 General):

1

1 

1 Oregon 1 Check payable to


i

South Carolina Check payable to
?South Carolina

Protection 1infonnation for the payee,
1andthatthe?nndsare 1
15113. Floor being remitted pursuant to
1 Strawbetry Square agreement with the 5
Harnsbuzg, Pennsyivania Pennsyivania Of?ce of
171201Attemey Geneml

Oregon Department of Justice Cover letter swing the 1 Katherine Campbell
Attm Karen Rounsviile identity of the payer, and Assistant Attemey General

1162 Court Street NE the last known contact 880

Salem, Oregon 97301-40961infenna?on for the payer ?Ka
1 Of?ce o?1CevcrIetter stating the 1 jesse F. Harvey

Chief Deputy Attorney General
412-5655728831
Mycy?attem?gegetalgov

Attorney General identity of the payer, and
Bureau of Consumer 1 the last known contact

 

First Associates?
. must appear 
. on. the check 1

South Carolina Attomey Cover: loner 1 Kristin Simons

Geneml?s Of?oe Assistant Attemey General

1
i Attomey Gweral 1 Post Of?ce Box 11549 1 803-734?6134

Of?ce?

1 South Dakota Check payable to
1 State
Treasurer-w 

1Celumbia, South Carolina KSimees@scag.gov
=29211-1549 

South Dakota State Treasurer Cover letter stadng the 1 Lee Dejabet

1 UCP 1 iden?ty of the payer, ?ue UCP Administmter

5003231; Capitol Avenue lastknewn Contact 605-773-3900

1 Suite 212 infenzna?en for the payer, 1eedejabe1@state. scins
It Pierre, South Dakota 57501 1 and that First Associates

3
has attempted to notify 1 or
?ne payer. 1

13

 



 

 

Tennessee

5 . Wm.? Wham?n? .m 

 

Check yayable to
.3 ?Tennessee State
Treasurer?

A Check payable to

?Texas
Comptroller of

Public Accounts 
Unclaimed

1 Property Division?

501'

State of Tennessee, Treasury 
Deparunent 1.
Unclaimed Property Division 1
PD. B01198649

Nashv?le, Tennessee 37219? 

i 8649 E2.

Program Manager, Unclaimed


Atm: Jacob Bagett 
i
ProPerL-y 3

.3

i

i

Cover letter stating:

the identity and last
known contact
information for the
1333701;

that the funds are
being remitted
pursuant to a
settlement agreennent
with ?re Tennessee
Attorney General, and
diligent, good faith
efforts were taken to
return the ?mds in
accordance with that
agreement, but were
unsuccessful; and
thatJacob Baggett
approved payment by
this method and by
remittance outside of
the portal

Texas Comptroller of Public - 1 Cover letter stan'ng payor

Accounts
Unclaimed 35?mperty DiVision

name, last known contact
infoma?on (address,

Mr. Bryant Clayton email address, phone,

1 13.0. Box 12019

Anson, Texas 7871 1?201 9 1

3 etc), dare of birth and
2 social security number (if 
. available), account and/ or i.

Anissa Grambi?nler

 

Compliance Manager
605-773-4168 

john Gabriel.

Director

Unclaimed Property Division
Treasury Department
615-253-5362

Eor

Ann Mikkelsen
1 Assistant Attorney General

615-253?3819



 

Bryant Clayton

Assistant Director of Unclaimed .

Property Division
Texas Comptroller of Accounts

(512) 463?6059,

BryaneCIayton@cPa.texas.gov

description or

14

i

 

 

.- . .. .. . . - 1 . 

Utah

 

1 Wire transfer via 
1 instructions 5:01:11
1 Mr. Gay-ton or Mr.

Utah State Treasurers O?ice
142321

Salt Lake City, Utah 84114-
2321

Check payable to
?Tltah State
Treasurers Of?ce?

15

ofthe payment, and the 

1 amount due to the Mew Angus

payer. prossibie we Supervisor

1 would also like images of 3 Undzitned Property Division
?ne ?out and back of the 1 Texas Comptroller of Accounzs
i check; ACH account (512) 463?5225

transfer information; and 1 Mtthew?ngus?cpatemsgov
names 1' contact 1

infoma?on of any other 

party who may be en?tied 

to zeceive the money, if

any.

Ideally, anmclainzed 1
property report: also 1111511 I
be submitted win: the 
funds and informa?on, 
?1e form for which can be 1
found at

i pp/create?a?repon I
Cover letter stating last
and ?rst name of payer,
last known address of
payer, social security 1 Property 
?numberofpzyondateof 16215112 ut?zh' 

1 last activity (last payment), 301-715?3303 direct line
1 check number 2111110211 I

a account number

mm
1 Progmm Specialist
I Utah State Of?ce of Unclaimed

 

or
i

Kevin McLean

-. Assistant Attorney General

Utah Attorney General?s Of?ce
3 801-366-0254

EManual?Iemnbe

   

 

 

?brgromndaimed

oranaupa??lemhe Ekmclean@agutah.gev
created aud uploaded at 

website listed above 

UPerchange and HRS
also 0561 software.

ro .com

 

 

 

Veunont

N0 5 Na emwcg?Check payable to
?Tteasurec of

Elili?

 

l- Vzrginia Treasury

Division of Unclaimed
Property 

P.O. Box 2478

Richmond, Virginia 23218-

2473 



16

 

address, telephone
number and email
address), the loan account
3 amber, and the amount

?5 due to be refunded to the
Payer

 

No mystic 

No meager mm?:


Vicki 315(1ng

Cover letter stating the .
Director

name of the payer, the
address of the payer, the
social security number of
the payer, the last known
contact infema?on for

the payer (including o:

1 Division of Unclaime' Property
804?225-3156 

3

 

William Badman

Records and Receipts Manage:
Division ofUnclaimed Property
f- 804-225?2547

Ear

James E. Scott

Assistant Attorney General
O?ce of the Attorney General
i (804) 2254778 O?ice

 

 

 

washington

West Virginia

Wisconsin

Check payable to
. ?State of

Washington

Attorney Genetal?s
Of?ce?

1 Check payable no
?West Virginia
State Treasure-1?

Check payable to

?Wisconsin

Department of

EJuStice?

 

. Of?ce of the Attomey General Covet letter stating the Miguel: Fame:
Attention: Margaxet Farmer,Eiden1ity of the payor, the O?ce of the Attomey General

Litigation Support Manager .last known contact Elitigaiion Support Manager
800 Fifth Avenue Einfonnation for the paying; 206?389 2521

5 Suite 2000 Eand the amount due E.mrga.tetf@atg wagov
Seattle, Washington 98104- i

Eor

1 Bade:

Assistant Attorney General

206-442-4482

CraigR1@atgwa.gov
West Virginia State Treasmet Coven: letter reques?ng Steve Jamil

I Unclaimed Property O??ce that the funds be Assistant Attorney General
1900 Kanawha Boulevard accepted, stating the i 304?558~8986

Capitol Complex Building #1 mounds), and stating 
Room E145 that the ?mds are being i
Charleston, West Virginia remitted pennant to

25305 ageement with the West 

{Virginia Attomey General I

Wisconsin Dcpment of Covet letter stating the R. Duane Harlow

1. Justice Epayox?s name, last known Assistant Attomey General
1 Consumer Protection and E,add:ess social security 608 ?266-2950

Antitrust Unit E,n1321bet and date of birth ha?owd ?do state-wins-

 

17 West Main Street

Po. Box 7857

Madison, Wisconsin 53707? .
7857 

17