Business ProfileforUSA Student Debt Relief

On November 16, 2023, the Commissioner of Financial Protection and Innovation and Respondents (Start Connecting LLC, d/b/a USA Student Debt Relief and Douglas R. Goodman) entered into a Consent Order.

This Consent Order resolves the issues before the Commissioner in a manner that avoids the expense of a hearing and other possible court proceedings, protects consumers, is in the public interest, and is consistent with the purposes, policies, and provisions of the Student Loan Servicing Act (SLSA) and California Consumer Financial Protection Law (CCFPL).

The Telemarketing Sales Rule (TSR) (16 C.F.R. §§ 310.1-310.9) is the implementing regulation of the federal Telemarketing and Consumer Fraud and Abuse Prevention Act (Telemarketing Act) (15 U.S.C. §§ 6101-6108). Pursuant to section 3(c) of the Telemarketing Act (15 U.S.C. § 6102(c)) and section 18(d)(3) of the Federal Trade Commission Act (FTC Act) (15 U.S.C. § 57a(d)(3)), a violation of the TSR constitutes an unfair or deceptive act or practice in or affecting commerce in violation of section 5(a) of the FTC Act (15 U.S.C. § 45(a)).

Beginning at least as early as 2019, Start Connecting marketed student loan debt relief services to student loan borrowers in California and nationwide.

Start Connecting advertised its services to student loan borrowers and acquired customers via telephone calls. Start Connecting claimed that it would assist consumers in obtaining student loan relief with Start Connecting acting as an intermediary between borrowers and the borrowers’ lenders or loan servicers with the goal of helping those consumers lower, eliminate and/or manage their student loan debts (Debt Relief Services).

Consumers contend that during these sales calls, Start Connecting’s representatives gave the impression that Start Connecting was part of, or affiliated with, an official government agency. For example, Start Connecting’s representatives represented that they would manage and process the consumer’s loan repayment through, or in affiliation with, the United States Department of Education, a federal agency. Some consumers also understood that the recurring monthly charges and some of the fees would be applied towards the consumer’s federal student loan debt. Start Connecting’s representatives also told consumers that they could help consumers lower their federal student loan payments or assist them with student loan forgiveness. Start Connecting's representatives presented consumers with options to enroll in income driven repayment programs based on income and/or family size, commonly known as loan forgiveness programs.

From September of 2019 through May 2023, at least 193 California consumers enrolled in Start Connecting’s Debt Relief Services. Upon initial enrollment, consumers paid an up- front one-time set-up fee of $99.00, paid a servicing fee between $400.00 to $850.00, and recurring monthly payments between $9.00 to $29.00. Start Connecting has collected at least $82,114.00 from California consumers during that period.

Based on the facts above, the Commissioner finds that Respondents violated: (1) the SLSA by engaging in unlicensed student loan servicing activities, (2) the CCFPL by engaging in unlawful, unfair, deceptive, or abusive acts or practices with respect to consumer financial products or services, and (3) the TSR by charging advance fees for debt relief services.

Respondents admit to the jurisdiction of the Commissioner.

Pursuant to Financial Code sections 28160 and 90015, subdivision (d), Start Connecting LLC, d/b/a USA Student Debt Relief, and Douglas R. Goodman are hereby ordered to desist and refrain from engaging in the business of servicing a student loan in this state without first obtaining a license, in violation of SLSA, and are ordered to desist and refrain from engaging in unlawful and deceptive acts and practices with respect to consumer financial products or services in violation of the SLSA, CCFPL, FTC Act, and TSR.

Respondents are further ordered to desist and refrain from owning, managing, operating, or controlling any entity that services student loans, or which offers or provides any consumer financial products or services as defined by the CCFPL, unless and until they have the applicable approvals from the Commissioner and are in compliance with the SLSA, CCFPL, FTC Act and TSR. These desist and refrain orders are final and effective from the effective date of this Consent Order, as defined in paragraph 28 (Effective Date). Pursuant to Financial Code sections 90015, subdivision (e), and 90012, subdivision (b)(1), all contracts between Start Connecting LLC, d/b/a USA Student Debt Relief, and any California consumer, regarding its services (Contracts) are hereby rescinded. Respondents shall not assign, sell, hypothecate, or transfer the Contracts to any other entity, nor shall Respondents charge or collect any additional payments pursuant to the Contracts.

Pursuant to Financial Code section 90012, subdivision (b)(2), Start Connecting LLC, d/b/a USA Student Debt Relief, and/or its officers, successors, and assigns, by whatever names they might be known, jointly and severally, are hereby ordered to refund all fees and payments they collected from California consumers no later than thirty calendar days after the Effective Date of this Consent Order. All Refunds shall be paid directly to the respective California consumers by mailing a check to the California consumers’ current mailing address, unless a new address has been provided by the consumer pursuant to Paragraph 7 prior to checks being issued. Payment of a refund to any consumer under this Consent Order may not be conditioned on that consumer waiving any right.

Respondents shall submit a report to the Department providing satisfactory proof of refunds no later than forty calendar days after the Effective Date of this Consent Order. The report shall contain each California consumer’s name and contact information, the total amount collected from the California consumer, the amount of the refund, the date the refund was issued, and proof of having sent or deposited refund. The report shall be sent to Afsaneh Eghbaldari, Senior Counsel, by email at: [email protected].

Respondents shall escheat any returned or unclaimed Refunds to the California State Controller’s Office within the period provided by Code of Civil Procedure section 1520 of the Unclaimed Property Law (Cal. Code Civ. Proc. § 1500, et seq.). No later than sixty calendar days after the Effective Date of this Consent Order. Start Connecting shall send a report to Afsaneh Eghbaldari, by email at: [email protected], setting forth all escheated funds and a copy of any escheatment report(s) submitted to the California State Controller.

Notice to California Consumers:

No later than seven calendar days after the Effective Date of this Consent Order, Respondents shall send a notice to each consumer owed a refund. The Notice shall be sent to the consumer’s last known e-mail address and mailing address.

The notice shall say:

Pursuant to the consent order with the California Department of Financial Protection and Innovation, Start Connecting LLC, d/b/a USA Student Debt Relief is refunding all fees, payments, and money you paid to them. You will receive a refund in the amount of $XXX.xx. All agreements between you and Start Connecting LLC, d/b/a USA Student Debt Relief are hereby rescinded. We plan to mail a check to your current mailing address. Please contact us immediately at [email protected] to confirm your current mailing address and contact information.

Pursuant to Financial Code sections 28170 and 90012, subdivision (c), Start Connecting LLC, d/b/a USA Student Debt Relief, and Douglas R. Goodman, jointly and severally, shall pay the Commissioner the penalty amount of $30,000.00 no later than seven calendar days after the Effective Date of this Consent Order. The amount shall be paid to the Commissioner by ACH transfer, pursuant to instructions which shall be separately provided. Notice of penalty payment shall be sent concurrently to Afsaneh Eghbaldari, by email at: [email protected].

The Parties hereby acknowledge and agree that this Consent Order is intended to constitute a full, final, and complete resolution of the Findings, and that no further proceedings or actions will be brought by the Commissioner in connection with the findings under the SLSA, CCFPL or any other provision of law, excepting therefrom any proceeding to enforce compliance with the terms of this Consent Order.

Respondents acknowledge that the Commissioner is ready, willing, and able to proceed with the filing of an enforcement action upon the charges contained in this Consent Order. Respondents hereby waive the right to any hearings, and to any reconsideration, appeal, or other right to review which may be afforded pursuant to the SLSA, CCFPL, the California Administrative Procedure Act, the California Code of Civil Procedure, or any other provision of law. By waiving such rights, Respondents effectively consent to this Consent Order, and the Desist and Refrain Order contained herein, becoming final.

Respondents agree that, if they fail to comply with the terms of this Consent Order, the Commissioner may avail herself of any remedies she has under the SLSA, CCFPL, or any other provision of law, until Respondents are in compliance. Respondents waive any notice and hearing rights which may be afforded under the SLSA, CCFPL, the California Administrative Procedure Act, the California Code of Civil Procedure, or any other provision of law, that the Commissioner may use to ensure compliance with this Consent Order. In the event of a filing of bankruptcy, or insolvency proceeding, Start Connecting LLC, d/b/a USA Student Debt Relief, and Douglas R. Goodman, are jointly and severally liable for the refund payment to consumers and paying the penalty to the Commissioner.

This Consent Order is binding on all heirs, assigns, and/or successors in interest.

This Consent Order may be rescinded by the Commissioner, and the Commissioner may pursue any and all remedies available under the law against Respondents, if the Commissioner discovers that Respondents have knowingly, or willfully withheld or misrepresented information used for and relied upon in this Consent Order.