National Collegiate Student Loan Trusts
On September 18, 2017, the Bureau filed a complaint and proposed consent judgment against the National Collegiate Student Loan Trusts. On the same day, the Bureau issued a consent order against Transworld Systems (TSI), the Trusts’ debt collection subservicer. The Bureau alleges that the Trusts brought debt collection lawsuits for private student loan debt that they could not prove was owed or was too old to sue over; that they filed false and misleading affidavits or provided false and misleading testimony; and that they falsely claimed that affidavits were sworn before a notary. Soon after the Bureau’s filing, several entities moved to intervene to object to the proposed consent judgment. The judge granted the intervention motions, and on May 31, 2020, the Court denied the Bureau's motion to approve the proposed consent judgment filed with the original complaint. On December 13, 2021, the Court denied defendants' motion to dismiss the Bureau's amended complaint. On February 11, 2022, the Court certified two holdings in its opinion denying the motion to dismiss for interlocutory appeal to the Third Circuit and stayed the matter. On April 29, 2022, the Third Circuit granted the petition to appeal. On March 19, 2024, the Third Circuit held that the Trusts are covered persons subject to the CFPA’s enforcement authority and the Bureau did not need to ratify its action before the statute of limitations had run. The case remains pending.