182 3180

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Joseph J. Simons, Chairman

Noah Joshua Phillips

Rohit Chopra

Rebecca Kelly Slaughter

Christine S. Wilson

In the Matter of

SHOP TUTORS, INC., a corporation,

d/b/a LendEDU,

NATHANIEL MATHERSON, individually and 

as an officer of Shop Tutors, Inc., 

MATTHEW LENHARD, individually and as an 

officer of Shop Tutors, Inc.,

and

ALEXANDER COLEMAN, individually and as 

an officer of Shop Tutors, Inc.

DOCKET NO.

COMPLAINT

The Federal Trade Commission, having reason to believe that Shop Tutors, Inc. 

(“LendEDU” or the “Company”), Nathaniel Matherson, individually and as an officer of 

LendEDU, Matthew Lenhard, individually and as an officer of LendEDU, and Alexander 

Coleman, individually and as an officer of LendEDU (collectively, “Respondents”), have 

violated provisions of the Federal Trade Commission Act, and it appearing to the Commission 

that this proceeding is in the public interest, alleges:

1. Respondent Shop Tutors, Inc., also doing business as LendEDU, is a Delaware

corporation with its principal office or place of business at 80 River Street, Suite #3C-2, 

Hoboken, NJ.

2. Respondent Nathaniel Matherson (“Matherson”) is the co-founder and Chief Executive 

Officer of LendEDU. Individually or in concert with others, he controlled or had the authority to 
2

control, or participated in, the acts and practices of LendEDU, including the acts and practices

alleged in this complaint. His principal office or place of business is the same as that of 

LendEDU.

3. Respondent Matthew Lenhard (“Lenhard”) is the co-founder and Chief Technology 

Officer of LendEDU. Individually or in concert with others, he controlled or had the authority to 

control, or participated in, the acts and practices of LendEDU, including the acts and practices 

alleged in this complaint. His principal office or place of business is the same as that of 

LendEDU.

4. Respondent Alexander Coleman (“Coleman”) is the Vice President of Product of 

LendEDU. Individually or in concert with others, he controlled or had the authority to control, 

or participated in, the acts and practices of LendEDU, including the acts and practices alleged in 

this complaint. His principal office or place of business is the same as that of LendEDU.

5. Respondents have marketed consumer financial products to consumers.

6. The acts and practices of Respondents alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act.

RESPONDENTS’ BUSINESS PRACTICES

Overview

7. Since 2014, Respondents have operated the website www.lendedu.com, which they 

promote as a resource for consumers in search of financial products such as loans and insurance. 

In numerous instances, Respondents have described the content on the website, including their 

rate tables, star ratings, and rankings of the companies offering these financial products, as 

“objective,” “honest,” “accurate,” and “unbiased.” In reality, this content is not objective and, 

instead, is based on compensation from the companies. In addition, Respondents have touted 

positive consumer reviews about their company and website that, in fact, were written by 

LendEDU employees or their friends, family members, and associates.

Respondents’ LendEDU Website

8. Many consumers have learned of LendEDU while searching or shopping for loans or 

other financial products. Respondents have promoted LendEDU through social media, content 

marketing, and search engine advertising, including with Google’s AdWords, and search engine 

optimization strategies. Google search results for “best student loan refinance companies,” for 

example, include an organic, non-paid Google “featured snippet” for “LendEDU’s picks for the 

8 best student loan refinancing and consolidation companies” with a link to Respondents’

website:
3 

LendEDU also appears as the third non-paid search listing below this snippet.

9. When consumers visit LendEDU’s home page, they have seen a screen similar to the 

following: 

best student loan refi nance companies 

Here are LendEDU's picks for the 8 best student loan 

refmancing and consolidation companies: 

• Earnest. 

• CommonBond . 

• Laurel Road. 

• SoFi. 

• ELFi. 

• Citizens Bank. 

• iHELP. 

• LendKey. 

Jul 1, 2019 

ear esl: 

Refinance Student Loans: Compare 8 Best Companies 2019 I Lend EDU 

htlps://lendedu.com/blog/refinance-student-loans/ 
4 

Respondents have encouraged consumers to use their website “confidently” and to “save time 

and money by comparing your options” in one place. As depicted above, the website allows 

consumers to choose from various financial products, including student loan refinancing, private 

student loans, personal loans, and credit cards. 

10. As one example, consumers selecting student loan refinancing are taken to Respondents’ 

student loan refinance webpage. On this page, Respondents have provided a rate table, rankings, 

star ratings, and reviews for what Respondents have represented to be the best or top companies 

offering the financial product. The top of the page has looked similar to the following: 

Student Loans Personal Loans Cred it Cards Other Prod ucts Read More 

Finance Confidently. 

Your finances don't have to be complicated. Our free tools and 

resources make it easy for you to manage your money. 

Student Loan Refinancing 

Private Student Loans 

Personal Loans 

Credit Cards 

save on interest or lower 

your monthly payments. 

compare interest rates, repayment options, and 

eligibility requirements from our top rated student loan 

refinance lenders. 

Variable Rates Fix.ed Rates 

2.38% - 9.38% 3.29% - 9.62% 

Refinance Student Loans 

8 TllEW.\LLSrRll'T JOllt \L f:~•~•wlJorktl111u Bloomberg Forbes YAHOO! liEIJ 

Save time and money by comparing your options 

,. 

' 91 -

- . _··:~-~~ 

REFINANCE STUDENT LOANS 

Refinancing your student loans 

can red ce your over a I cos: 

and monthly paymen s. 

PRIVATE STUDENT LOANS 

Private student loans can help 

finance your education a'i:er 

you h, federa l lim its.. 

PERSONAL LOANS 

You can use a personal k>an to 

consolidate deb:. or finance 

large purchases.. 

CREDIT CARDS 

8cplore our top·rated picks in 

each category tot nd the 

perfect card or your situation. 
5 

11. Scrolling down the page, Respondents show a rate table that compares these best 

companies, including their interest rates and loan terms:

A lendedu Refinance Student Loans Private Student Loans Personal Loans News Login ~ 

Student Loan Consolidation & 

Refinancing Lenders for 2018 

STUDENT LOAN 

REFINANCING & 

CONSOLIDATION 

2018 

Updated: 3/28/2018 

•• • . 

Looking to refinance student loans? Want 

to consolidate student loans'? 

Today, 7 out oflO graduates are graduating with some form of student loan 

debt. With an average balance of $28,000, student debt is a big part of the 

average college graduate's life. 

At Lend EDU, we help borrowers compare the top student loan companies in 

one place. We put together this guide to help you get information on all of the 

top student loan refinance lenders without having to jump around multiple 

websites. After you are done. you will know how to refinance and 

consolidate student loans. 

Below we've ranked the leading student loan refinancing and consolidation 

companies. It is free to apply and the process usually takes about 15 minutes. 

How much could you save? Find out today. You might be able to save $20,000 or 

more! 

Our Top Picks 

SoFi :§~ ***** Learn More 

eame~  I.. Learn More 

LendKey ** **is. Learn More 

$ EDUCATION 

LOAN FINANCI! ***** Learn More 

D Citizens Bank  -u Learn More 

O commonBond ** ** Learn More 

Colleg~   Learn More w lau~ey r~d ** ** Learn More 
6 

A consumer clicking the “Check Rate” button is taken directly to the website for that company. 

12. Below the rate table, Respondents then have ranked the best or top companies: 

Compare the Best Student Loan Refinance Rates 

Instantly view loan options from $5,000 to $500,000 using our student loan refinance comparison tool. 

Easily select your loan type, educational level, and loan amount to compare loan companies that meet your selected criteria. 

Current Loan Type 0 

All Loan Types 

I want to compare: 

@MMl:id- Loan Details 

Lender 

o•• SoFi :i~ 

earnesl: 

LendKey 

Highest Degree Obtained 0 

All Degree Types 

Eligibility Requirements Application & Fees 

Fixed APR Variable APR 

3.25% - 7.13% 1 2.89% - 7.38% 1 

Fixed APR Variable APR 

3.25% - 6.32% 2.57% - 5.87% Fixed APR Variable APR 

3.15% - 8.1 2% 2.56% - 7.94% Fixed APR Variable APR 

Loan Amount 0 

All Loan Amounts 

Loan Terms (Years) 

5, 7, 10, 15 or 20 Check Rate Q 

Loan Terms jYears) at SoFi'S secure website 

5- 20 Check Rate Q 

Loan Terms jYears) at Earnest's secure 1Nebs1te 

5, 7, 10, 15 or 20 Check Rate Q 

Loan Terms (Years) at Lend Key's secure website 
7 

A consumer clicking the “Visit Site” button is taken directly to the website for that company.

13. Respondents further have assigned each company a star rating, ranging from a low of one 

star to a high of five stars. An example of Respondents’ star rating appears below.

Top 9 Companies for Student Loan Refinancing: 

In-Depth Reviews 

l. SoFi 

o•• SoFi :i~ 

a Reduce your payment and interest rate_ 

m Members save $22,359 in 15 minutes• VISIT SITE » 

✓ Refinance and consolidate both federal and private 

student loans 

✓ 5, 7, 10, 15, 20 year repayment terms 

✓ No application fees, origination fees, or pre-payment 

✓ fees Rates as low as 2_89% for variable rates 

✓ Rates as low as 325% for fixed rates ✓ Unemployment protection is available 

✓ Easy application process 

2. Ea rnest 

earnest a You could save a boat load. m Customers save $21,810 on average• 

VISIT SITE,.,. 

✓ Refinance and consolidate both federal and private 

student loans 

✓ Fixed rates as low as 3-25% 

✓ Data-driven customer evaluation helps you get 

✓ 5 - 20 year repayment terms qualified 

✓ Variable rates as low as 2.57% 

3. LendKey 

Lendl<ey 

✓ Zero application fees, origination fees, or prepayment fees 

9 You deserve a better student loan 

Average client saves $16,6571 VISIT SITE» 
8 

14. The web page layout for other financial products is similar and has included a rate table, 

rankings, star ratings, and reviews. 

Respondents Represent that LendEDU’s Content Is Not Influenced by Compensation

15. In numerous instances, Respondents have represented that the resources on their website, 

including the rate tables, star ratings, and rankings, are “objective,” “honest,” “accurate,” 

“unbiased,” and not based on compensation. Respondents, for example, have represented that 

their “ratings are completely objective and not influenced by compensation in anyway [sic].” 

Respondents also have claimed that their “research, news, ratings, and assessments are 

scrutinized using strict editorial integrity.” Respondents have further represented that their 

“editorial staff and independent contractors do not receive direction from advertisers on our 

website” and “are not rewarded in anyway [sic] for publishing favorable or unfavorable 

reviews.” A webpage about “editorial integrity” signed by Respondent Matherson represents 

that the information on Respondents’ website is “honest, unbiased, and fact based.” Similarly, a 

webpage about “LendEDU Partners” written by Respondent Coleman represents that “[w]e do 

not publish favorable (or unfavorable) reviews or assessments at the direction of any company.” 

16. Respondents have described their resources as “designed to help consumers better 

understand and make choices about which products fit their needs.” Respondents have further 

represented that they “do not publish favorable or unfavorable reviews or ratings at the direction 

of any companies,” that their “editorial staff and independent contractors are tasked with 

providing accurate and fact-based analyses,” and that their “editorial staff and independent 

contractors are not rewarded in anyway [sic] for publishing favorable or unfavorable reviews.” 

Respondents also have touted their extensive experience reviewing and researching financial 

services companies since 2014. 

17. The LendEDU website also has a page devoted to explaining its methodology for 

analyzing the financial products promoted on the website. Respondents have claimed that the 

Company’s staff rigorously uses objective criteria to rank and review lenders, including “breadth 

of products offered, interest rates by term and product, available term length options, applicable 

fees, soft-credit check process, borrower benefits and unique incentives, borrower protections, 

ease of use, quality of customer support staff, and time to funding.” More recently in 2019, 

Respondents have represented that they weigh different criteria based on their importance for 

that product or service:

earne~ 

Editorial Rating (4.54 / 5.0) 

****"1 
9 

18. In addition to explaining the criteria purportedly used by Respondents to analyze each 

company, Respondents have sought to reinforce the objective and non-paid nature of their ratings 

and reviews by representing that “[e]ach piece of criteria is cross checked and audited by 

multiple members of the LendEDU team.”

Respondents Rank Financial Services Companies Based on Compensation

19. Contrary to their claims, Respondents have provided financial services companies with 

higher numerical rankings or star ratings and higher positions on rate tables based on 

compensation. Respondents also have added or removed companies from their content based on 

compensation. 

20. In numerous instances, Respondents have required financial services companies to 

increase their payments to LendEDU to maintain or improve upon their current rate table 

positions and rankings. Respondents Matherson, Lenhard, and Coleman either directly requested 

additional compensation from financial services companies in exchange for better placements on 

Respondents’ website, or had knowledge of such requests. For example, in an email, 

Respondent Matherson asked one student loan refinance company to pay $9.50 per click to 

retake the number one ranking after falling to number three. Respondent Matherson copied 

Coleman on the email chain requesting more compensation and forwarded it to Respondent 

Lenhard. The company ultimately agreed to pay $8.50 per click for the number one ranking and 

rate table placement.

21. Respondents later asked the same student loan refinance company to increase its 

payments to $16 per click “to maintain the #1 position on our site.” In an email to the company, 

Respondent Coleman wrote: “We want to keep [your company] positioned as the #1 lender on 

our site, but we need to justify the move from a business perspective.” The company agreed to 

pay $15 per click, and Respondent kept the company ranked number one and positioned first on 

the rate table.

22. Respondents offered another student loan refinance company the number three position 

for payment of $16 per click. The company agreed to the paid placement, and Respondents 

moved the company from the number four ranking to the number three ranking and from the 

number four position on the rate table to the number three position. 

Description of Rating Categories 

Product (65%}: Interest Rates (30%), Term Lengths (35%), Loan Amounts (25%), Fees (10%) 

App/Eligibility (5%}: States Available (20%), Soft Cred it Pul l (25%), Degree Requ ired (30%), Loans Accepted 

(25%) 

Repayment (15%): Cosigner Release (30%), Forbearance (30%), Deferment (30%), PLUS Transfer (10%) 

Benefits/Discounts (10%}: Benefits (50%), Discounts (50%) 

Customer Service (5%): Ways of Contact (50%), Better Business Bureau Rating (25%), Trustpi lot Rating 

(25%) 
10

23. The contract between the company and LendEDU expressly provided that LendEDU 

would rank the company “[n]o lower than position 3” on LendEDU’s refinance student loans 

webpage.

24. Another student loan refinance company paid Respondents for the number three ranking 

and rate table position prior to the company above and, later, increased the amount of payment 

per click for the number two ranking and position.

25. Respondents’ paid placement policies and practices have resulted in some previously 

highly ranked companies dropping spots for refusing to pay for their position. For example, 

Respondents ranked one student loan refinance company number two in the rankings and listed it 

second in the rate table for several months. When the company refused to pay more to be placed 

in the second spot, Respondents dropped the company’s ranking to number five or lower and 

listed it fifth or lower in the rate table.

26. Respondents have repeatedly acknowledged to financial services companies doing 

business—or seeking to do business—with them that they can pay for placements, even though 

Respondents have publicly represented to consumers that their website content is not based on 

compensation.

27. Respondents’ presentation material to a prospective bank customer included a slide that 

discussed “Partner Positioning & Ordering,” explaining that “compensation may influence the 

products we review and write about, the order in which partners appear in our articles, whether 

products appear on our site, and where they’re placed.” 

28. In an email to a private student loan company, Respondent Coleman admitted that 

Respondents rank companies based on a number of factors, including “compensation terms,” and 

that Respondents also “allow[] partners to pay for premium listings.” The company 

subsequently entered a contract agreeing to pay LendEDU in return for “the highest level of 

visibility equal to the Number 1 position” on Respondents’ private student loans webpage from 

March 1, 2018 to January 31, 2019. Respondents had not previously ranked the company on 

their website. Following the paid placement agreement, Respondents immediately ranked the 

company number one starting March 1, 2018. Respondents also positioned the company at the 

top of the rate table. During this time, even though other companies had higher star ratings, 

Respondents placed them lower in the rankings and rate tables.

29. LendEDU also has admitted in interrogatory responses to the FTC that, at least into early 

2018, “star ratings were typically assigned based on the order in which they appeared on the 

page” and that the “Financial Services Companies on these pages were ordered mainly based on 

the compensation we received from them. . . .”

30. In correspondence with financial services companies, Respondents have represented that 

the rankings and rate table placements influence a consumer’s choice in visiting particular 

companies’ websites to apply for a loan product or service. In an email to one company, 

Respondent Matherson wrote that a company paying for the number one position on the student 

loan refinance webpage would receive approximately 32 percent of clicks, while the number two 
11 

company would receive approximately 21 percent of clicks, and the number three company 

would receive approximately 15 percent of clicks. Respondent Coleman wrote to a different 

student loan refinance company in the number four position that a paid move to the number three 

spot would double its click-through volume, while a paid move to the number two spot would 

triple the volume.

31. Similarly, when offering a “top 4 position” to a personal loan company that held the 

number nine position, Respondent Coleman wrote that with a top four position, the company 

“could expect a ~50% increase in traffic,” while “[t]he #1 spot would likely result in a ~100% 

increase in traffic.”

32. Respondents have included on their website virtually no information about their 

relationships with the companies that appear on the site. In mid-2016, Respondents added a fineprint disclaimer that the “site may be compensated through third party advertisers,” in the 

website’s footer. After becoming aware of the FTC’s investigation into their conduct, around 

March 2019, Respondents also have listed the companies that “may provide compensation to 

LendEDU” on a page that consumers are unlikely to visit. 

33. Similarly, since approximately June 2019, Respondents have presented their rate tables in 

the following manner: 

Compare Companies That Refinance Student Loans 

See student loan refinancing options by adjusting the filters below to reflect your current student loan situation. 

Current Loan Type 

All Loan Types 

Lender 

earnest 

Fixed A PR 

Highest Degree Obtained 

All Deg ree Types 

Filter Loan Options 

Variable APA 

3.47%-7.59% 2.27%-6.89% 

Loan Amount 

All Loan Amounts 

Term s (Years) 

5 - 20 

Advertiser Disclosure 

Check Rate 

More Details .., Fixed APR Variable APA Terms (Years) on Earnest's secure website 

o•• SoFi :i~ More Details .., 

rf, EDUCAT ION \!f LOAN FINANCE 

More Details .., 

3.49%-8.07% 1 

Fixed APR 

3.29%-6.69% 

Fixed APA 

2.43%-6.65% 1 5, 7, 10, 15, 20 Check Rate 

Variable APA Terms (Years) on SoFi's secure website 

2.80%-6.01% 5, 7, 10, 15, 20 Check Rate 

Va riable APA Terms (Years) on EIFi's secure website 
12 

34. If a consumer were to notice the small font reading “Advertiser Disclosure” in the upperright corner and click on the phrase, a popup window would appear containing a small-print 

disclosure as follows:

The popup window has stated, in part, that “LendEDU is compensated by some of the financial 

services companies seen on our website” and that “[t]his compensation may impact where 

products appear on this site (including for example, the order in which they appear in a rate table 

or whether a company is written about on the site).” The popup window further has stated that 

“partners cannot pay us to guarantee favorable reviews or ratings.” 

Respondents Tout Fake Positive Reviews

35. Reviews about LendEDU’s website and customer service appear on third-party review 

platforms, including trustpilot.com (“Trustpilot”). Trustpilot allows users to select a star rating 

when reviewing a company. The ratings range from five stars (“Excellent”) to one star (“Bad”). 

LendEDU currently has 126 reviews on Trustpilot, consisting of 123 five-star reviews, one fourstar review, one two-star review, and one one-star review.

36. Of those 126 reviews, 111, or 90%, were written or made up by LendEDU employees or 

their family, friends, or other associates. All of those reviews provided five-star ratings for the 

Company. Examples include: 

• Kenny: “LendEDU showed me the light at the end of the tunnel. I was drowning in 

student loan debt then they showed up with a lifeboat and a warm blanket. The 

website was easy to navigate and with the help of their customer service team, I saved 

a lot of money refinancing. I can’t thank them enough and would recommend to 

anyone!” 

Compare Companies That Refinance Student Loans 

See student loan refinancing options by adjusting the f ilters below to reflect your current student loan situation. 

Current Loan Type 

All Loan Types 

Lender 

earnest 

More Details ,., 

o•• SoFi :i~ More Details " 

Highest Degree Obtained 

Al l Degree Types 

Filter Loan Options 

Fixed APR Variable APR 

3.36%-7.82% 2.41%-6.99% 

Fixed APR Variable APR 

3.49%-8.07% 1 2.43%-6.65% 1 

Fixed APR Variable APR 

Loan Amount 

All Loan Amounts 

Terms {Years) 

5- 20 

Terms (Years) 

5, 7, 10, 15, 20 

Terms (Years) 

Advertiser Disclosure 

7"c 

So, how does LendEDU make money? 

Lend EDU is compensated by some of 

the financial services companies seen 

on our website. Most often, LendEDU 

receives a fee when one of our readers 

clicks to, applies for, or receives a 

financial product from a LendEDU 

partner. This compensation may impact 

where products appear on this site 

(including for example, the order in 

which they appear in a Rate Table or 

whether a company is written about on 

the site). To be clear, partners cannot 

pay us to guarantee favorable reviews or 

ratings. LendEDU has not written about, 

reviewed, or rated all financial products 

available to consumers. Here is a list of 

our advertising partners. 

Check Rate 

on SoFi"s secure website 
13

• Scott: “Extremely user friendly and easy to use. . . . It was a pleasant surprise to be 

able to find personal finance education. As a student, high schools don’t really 

provide any basic financial course and credit cards are so easy to obtain. It was 

refreshing to be able to research and understand more through LendEDU.”

• Trace: “I wasn’t sure where to go, and stumbled onto an[] article LendEDU 

published. It was full of good tips that helped. I ended up going to their site and there 

was quite a bit of helpful stuff there too. They seem to be on top of it!”

The review written by “Kenny” actually comes from a LendEDU employee using a fake name. 

Similarly, “Scott,” the purported high school student researching personal finance, is actually the 

administrator of LendEDU’s 401(k) plan. “Trace” is actually a friend of a LendEDU employee. 

37. In addition, the vast majority of the reviewers do not appear to have used LendEDU. 

LendEDU offers a loan comparison tool, which requires consumers to enter an email address 

before they can see a list of potential lenders. Only eleven of the email addresses provided by 

LendEDU’s 126 reviewers on Trustpilot (9 percent) match email addresses that consumers 

provided to LendEDU. Nevertheless, several of the remaining 115 reviews reference 

LendEDU’s loan comparison tool. Examples include:

• LendEDU’s outside counsel: “The application process was very easy and I was given 

a number of options. While I didn’t end up refinancing my student loans, it was 

worth the look.”

• Friend of a LendEDU employee: “Genius! Spent 2 minutes filling out a form and 

saved thousands of dollars. Wish I had known about LendEDU earlier!”

In numerous instances, the reviews were fabricated and did not represent actual consumer 

experiences with LendEDU.

38. Respondents also have reposted and touted the Trustpilot reviews on LendEDU’s 

website, as well as fake reviews written by LendEDU employees who purport to be, but are not, 

actual users. The LendEDU homepage has, at times, prominently featured reviews from 

Trustpilot:
14 

39. A LendEDU employee wrote the review in Paragraph 38 under a fake name, stating “I 

would recommend this company for sure.” 

40. In other instances, the LendEDU homepage has included “testimonials” from consumers 

claiming they saved money by using LendEDU’s services. These testimonials have included 

consumer names, colleges, and years of graduation: 

Save Time and Money by Comparing Your Options 

l 

2 

3 

Complete One Simple Form 

0 90Se<:onds 

Just anS'Y\ler a few quick questions about your 

cur,enr. situation. 

Clet Personalized Quotes 

0 Instantly 

Instantly com pare actual quotes trom our 

vetted p<Jrtne rs 

Choose What Works Best For You 

0 Take A,; Long As You'd Like 

Review your options and choose the one tl"'lat 

fits your lifestyle 

Sophia Loren 

UniversityofTe·as 15 

See What Our Customers Have to Say 

.Lendedu 

T RUSTPILOT 

t1t1CH'lt1 

re someotme 

... ~ 

I would ,oi:ommond this company for suro. 

I was able to refinance $55,000 in federal and private student loan debt after using 

LendEDU. LendEDU helped me compare both the fixed and variable options in one 

place. I expect to save about $10,000 over the course of my repayment! 

Anna Fry 

University of Washington '12 

After leaving medical school I had about $90,000 in student loan debt! I was able to use 

LendEDU to make my monthly payments a little more manageable. Lend EDU helped 

me find a 20 year term with a fixed rate. It was easy to compare all the options in one 

place. Easy to use website! Thanks! 

Keith Johnson 

Uni •ersity of Alabama '13 

LendEDU helped me compare SoFi, CommonBond, and DRB in one place. The 

application was fairly straightforward and easy to get through. I really liked how 

LendEDU lets you sort and filter all of the options in one view. I refinanced all of my 

debt at 3% and saved about $11,500. 
15

None of these consumers exists. Respondents fabricated these “testimonials.”

Count I

41. In numerous instances in connection with the advertising, marketing, promotion, offering 

for sale, or sale of consumer financial products, Respondents represent, directly or indirectly, 

expressly or by implication, that Respondents’ website content promoting financial products, 

including their rate tables, rankings, and star ratings of companies offering those products, is not 

influenced by compensation.

42. In truth and in fact, in numerous instances in which Respondents have made the 

representations set forth in Paragraph 41, Respondents’ website content promoting financial 

products, including their rate tables, rankings, and star ratings of companies offering those 

products, is influenced by compensation from those companies.

43. Therefore, Respondents’ representations as set forth in Paragraph 41 are false and 

misleading and constitute deceptive acts or practices in violation of Section 5(a) of the FTC Act, 

15 U.S.C. § 45(a).

Count II

44. In numerous instances in connection with the advertising, marketing, promotion, offering 

for sale, or sale of consumer financial products, Respondents represent, directly or indirectly, 

expressly or by implication, that their website content, including rate tables, rankings, and star 

ratings, is a source of information about financial products.

45. In numerous instances in which Respondents make the representations set forth in 

Paragraph 44, Respondents fail to disclose or disclose adequately to consumers that financial 

services companies paid Respondents for website content, including rate tables, rankings, and 

star ratings. This additional information would be material to consumers in deciding whether to 

transact with companies ranked, rated, or reviewed by Respondents.

46. In light of the representations described in Paragraph 44, Respondents’ failure to disclose 

or disclose adequately the material information as set forth in Paragraph 44 constitutes a 

deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Count III

47. In numerous instances in connection with the advertising, marketing, promotion, offering 

for sale, or sale of consumer financial products, through the means described in Paragraphs 35-

40, Respondents have represented, directly or indirectly, expressly or by implication, that certain 

reviews of LendEDU reflect the actual experiences or opinions of impartial consumers. 
16

48. In truth and in fact, these reviews of LendEDU were not truthful reviews by actual 

LendEDU users, but instead were fabricated by persons who were friends, employees, or other 

associates of LendEDU.

49. Therefore, the making of the representations as set forth in Paragraph 47 constitutes a 

deceptive act or practice in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a).

Violations of Sections 5

50. The acts and practices of Respondents as alleged in this complaint constitute unfair or 

deceptive acts or practices in or affecting commerce in violation of Sections 5(a) of the Federal 

Trade Commission Act.

THEREFORE, the Federal Trade Commission this _______ day of _______, 20__, has 

issued this complaint against Respondents.

By the Commission.

April Tabor

Acting Secretary

SEAL: