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ALDEN F. ABBOTT

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

Related Case: 4:17-cv-04817-SBA 

DECLARATION OF STEVEN 

STALICK IN SUPPORT OF 

FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 113 Filed 04/19/18 Page 1 of 4

DECLARATION OF STEVEN STALICK IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
------+--11----------1-EGI:,AR-A-'FI0N-0F-S-rE-VEN-S-T*Lie 

1. My name is Steven Stalick, 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. For roughly two weeks from May to June 2017, I worked as a sales representative 

for AmeriTech Financial ("AmeriTech" or "the company") in the company's Rohnert Park 

office. My employment was considerably short as I was not morally comfortable with the sales 

technique used by the company. 

3. The company's business model was to sign up low-income earners who carry 

large student loan balances into government student loan forgiveness programs. The company 

operated a telemarketing call center where sales representatives would receive a phone call or 

make an outbound call. 

4. The company gave sales representatives a script to read, which included prescripted responses to various questions or comments customers might have. Sales 

representatives were expected to follow the script. 

5. I had a direct supervisor who wore a headset and could hop on calls for about 

10-15 sales representatives. The person above him also had a supervisory role and would hop 

on calls as well. They would try to help sales representatives close deals if a prospective 

customer was getting a little iffy. 

6. The company placed a huge emphasis on making the customer claim the largest 

family size possible. This was part of the scripting, and the company's incentive scheme 

rewarded the agents who had increased their customers' family size numbers the most. Sales 

representatives would get kudos, or get to ring a bell, for different sorts of accomplishments. 

The higher the family size, the more kudos you would get. It was how you would be promoted. 

7. There were only a few numbers to plug into the student loan calculator that sales 

representatives used to figure out how much the customer's payment would be. You could not 

really fudge how much income customers were making, or the other variables, but the 

Stalick Declaration - Page 1 

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Case 4:18-cv-00806-SBA Document 113 Filed 04/19/18 Page 2 of 4
------11 g0vemment~s-defi-niti0n-0-f ''family-sizell-was-loose;-so-that-was-the-tool-thatihe-c-ompanytaugh

the sales representatives to emphasize. 

8. If a sales agent was on the phone with a prospective customer and the difference 

between the company being able to add value or not would be contingent upon the customer's 

family size, a supervisor would take over the phone call and persuade the customer to increase 

the claimed family size by reading, re-reading, and overemphasizing specific words used in the 

government definition of "family size." It would be very common to see cases where a customer

claimed that their family size was upwards of 10-15 people simply due to the sales agent or 

supervisor emphasizing the word "support" in the definition of family size, and following up 

with something like, "If you say you 'support' them, by the definition I read to you would you 

say they're included in your family?" An original family size of three would suddenly increase 

to 11. One prospective customer who I spoke to said that he had given $10 to his uncle to help 

with rent last month. I responded with something like, "Do you think that counts under the 

definition of 'support'?" 

9. Each sales script included yellow highlighting over portions of the script that the 

head of HR had deemed legally necessary to read aloud. My second job interview at AmeriTech

as with the head of HR, and he said that he had developed the script to make sure it was legally

compliant. 

10. The highlighted portions included explaining the company's "document 

reparation fee," which was a large upfront sum, in the hundreds of dollars, and subsequent 

aintenance fees up to $99 per month to ensure the customer's re-enrollment into the program 

or "X" number of years until forgiveness had been reached. The fees were higher for customers

ith higher income. 

11. Also required, near the end of the pitch, was an attempt to up-sell the customer 

nto an on-going financial education package consisting of various unrelated products of minimal

alue. Sales representatives were supposed to keep trying to sell the package even if the 

ustomer initially declined. 

Stalick Declaration - Page 2

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Case 4:18-cv-00806-SBA Document 113 Filed 04/19/18 Page 3 of 4
-----1 11----t-2-. --+he-l-ast-few-pages-0Hhe-se1:ipt-ine-l1:1clecl-requi-recl-diselosures-that-were-worded-in 

a way that was hard to understand, like a pharmaceutical disclosure. My impression was that 

consumers did not really understand the disclosures; they just heard that their payment would be 

lower and hung on the line for that. 

13. There were printed brackets in each cubicle showing the total amount the 

customer paid, the amount that would be paid to service the loan, which was often minimal, and 

the spread earned by the company. 

14. My experience at AmeriTech included one week watching training videos, a few 

days shadowing a sales agent, and a few days on the phone. When coming close to signing my 

first customer, I felt disgusted, disconnected the line, and quit the job. 

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

on /r/ov(?:/,/4_ I 5 '2018, in California. 

Steven Stalick 

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Stalick Declaration - Page 3 

Case 4:18-cv-00806-SBA Document 113 Filed 04/19/18 Page 4 of 4