1 

 2 

 3 

 4 

 5 

 6 

 7 

 8 

 9 

 10 

 11 

 12 

 13 

 14 

 15 

 16 

 17 

 18 

 19 

 20 

 21 

 22 

 23 

 24 

 25 

 26 

 27 

 28 

DAVID C. SHONKA

Acting General Counsel

SARAH SCHROEDER, Cal. Bar No. 221528 

ROBERTA TONELLI, Cal. Bar No. 278738 

EVAN ROSE, Cal. Bar No. 253478 

Federal Trade Commission

901 Market Street, Suite 570 

San Francisco, CA 94103 

sschroeder@ftc.gov, rtonelli@ftc.gov, erose@ftc.gov

Tel: (415) 848-5100; Fax: (415) 848-5184 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

FEDERAL TRADE COMMISSION, 

 Plaintiff,

 vs. 

AMERICAN FINANCIAL BENEFITS 

CENTER, a corporation, also d/b/a AFB and AF 

STUDENT SERVICES; 

AMERITECH FINANCIAL, a corporation; 

 

FINANCIAL EDUCATION BENEFITS 

CENTER, a corporation; and

BRANDON DEMOND FRERE, individually 

and as an officer of AMERICAN FINANCIAL 

BENEFITS CENTER, AMERITECH 

FINANCIAL, and FINANCIAL EDUCATION 

BENEFITS CENTER,

 

 Defendants. 

 

Case No. 4:18-cv-00806-SBA

DECLARATION OF MARK DANT IN 

SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR 

PRELIMINARY INJUNCTION

Case 4:18-cv-00806-SBA Document 28 Filed 03/02/18 Page 1 of 3

DECLARATION OF MARK DANT IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
1 

2 

3 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

DECLARATION OF MARK DANT 

1. My name is Mark Dant and I reside in California. The following statements are 

within my personal knowledge and if called as a witness I could and would competently testify 

thereto. 

2. I started working for American Financial Benefit's Center on or around February 

of 2015. Approximately two to three months later, Brandon and Tyler terminated me for not 

enrolling enough clients and insubordination. 

3. In the short time that I was at the company, I worked in the sales department 

where I took calls from people that were struggling with their student loans and wanted to reduce

their payments. 

4. Prior to starting, my training lasted approximately one week. The first red flag 

was the quality of the training and the fact that it took place between two sets of doors at the 

entrance of an office building. We were never taught specifics about the student loan process and

were simply told to follow the script. 

5. When people called, I would qualify them for our program based off income, 

occupation, and family size. Since occupation and income are hard to falsify due to the IRS, we 

were told to focus on exaggerating the family size to help people qualify for our program. 

6. I recall Cameron, a manager, telling us off script that we had to embellish family 

size and that anyone the potential client gave gifts to could be considered a family member. The 

idea behind this was that if you told the government you had many dependents, there was a 

higher likelihood that your student loan payments would be reduced. The highest family size I 

saw get approved was certainly in the double digits, somewhere between 12-15 family members.

7. The fees we collected were a document preparation fee and a monthly service fee.

I don't recall how much the document preparation fee was but I do know the monthly fee ranged

from approximately $49-$99 a month. This fee would be paid indefinitely until a client's loan 

was paid off. 

Dant Declaration - Page 1 

Case 4:18-cv-00806-SBA Document 28 Filed 03/02/18 Page 2 of 3
1 

2 

3 

4 

8. My understanding was that the monthly fee would go towards AFBC for 

document preparation and that any extra monies paid were allocated for paying down a client's 

student loan. 

9. I don't recall consumers ever being offered a benefits package as part of our 

program. 

10. I recall being confused about how the business operated, mainly because my 

questions were never answered and because of how micromanaged and compartmentalized the 

business was. I recall not being allowed to talk to anyone other than the sales manager. 

11. I declare under penalty of perjury that the foregoing is true and correct. Executed

r::-1 l "'\ o'V\ 

on r-"t.-!:) cf--C , 2018, in California. ----==-+------""'-----

Mark Dant 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

23 

24 

25 

26 

27 

28 

Dant Declaration - Page 2 

Case 4:18-cv-00806-SBA Document 28 Filed 03/02/18 Page 3 of 3