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 

Case 4:18-cv-00806-SBA Document 68 Filed 03/05/18 Page 1 of 4 

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 

RELATED TO: 4:17-cv-04817 SBA 

DECLARATION OF BEVERLY 

SILLS IN SUPPORT OF FEDERAL 

TRADE COMMISSION’S MOTION 

FOR PRELIMINARY INJUNCTION 

DECLARATION OF BEVERLY SILLS 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

Case 4:18-cv-00806-SBA Document 68 Filed 03/05/18 Page 2 of 4 

DECLARATION OF BEVERLY SILLS 

1. My name is Beverly Sills and I reside in Memphis, Tennessee. I work at a 

Veteran’s Affairs Hospital. The following statements are within my personal knowledge and if 

called as a witness I could and would competently testify thereto. 

2. Around February 2015, I received an email stating that I qualified for lower 

interest payments on my student loan. I called the phone number provided in the email and 

spoke with a representative named Michael. Michael told me he worked for AmeriTech 

Financial (“AmeriTech”) and that AmeriTech would take over my loan from FedLoans, a loan 

servicer for the federal government. 

3. Michael sent me a lot of paperwork relating to my student loan. He told me that 

my new monthly student loan payment would be $207 for several months, then $99 for one year, 

and then revert back to $207 for at least 10 years. He also said I had to make an up-front 

payment of $250 to AmeriTech and $50 to another entity. The payment structure was confusing, 

but I trusted AmeriTech. I completed the paperwork and began making monthly payments to 

AmeriTech. 

4. In 2016, I received a letter stating that my student loan was in forbearance. I do 

not recall who sent me the letter. I was confused because I had been making monthly payments 

to AmeriTech. I believed my monthly payments were going toward my student loan balance. 

5. In February 2016, I received a letter from Global Client Solutions stating that it 

was my “account provider.” An information sheet attached to the letter stated, “Global is the 

account provider for your dedicated Account. Our duties include the drafting of funds from your 

primary bank account into your Account as provided for in your Application as well as executing 

disbursement instructions in a commercially reasonable manner as soon as practical after receipt 

of such instructions.” A true and correct copy of the letter I received from Global Client 

Solutions on February 9, 2016, with my handwritten notes and personal information redacted, is 

attached as Sills Attachment A. I understood from this letter that Global Client Solutions was 

collecting my student loan payment on behalf of AmeriTech. 

Sills Declaration - Page 1 
   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

   

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

Case 4:18-cv-00806-SBA Document 68 Filed 03/05/18 Page 3 of 4 

6. In January 2017, I received a letter from AmeriTech stating, “Account 

Management Plus will collect all payments moving forward.” The letter was confusing, but said, 

“Nothing about your payments or payment plan will change.” I assumed that a new company 

would be collecting the payments for my student loan. A true and correct copy of the January 

13, 2017 letter I received from AmeriTech, with my personal information redacted, is attached as 

Sills Attachment B. 

7. In summer 2017, it dawned on me that something was not right so I called 

FedLoans to inquire about the status of my student loan. FedLoans told me that it had not 

received any loan payment from me since December 2015. FedLoans explained that I had been 

scammed. I was shocked and very angry. I reported AmeriTech’s theft to my bank, but my bank 

said it could not recover the funds. 

8. I paid AmeriTech over $3,000 that I believed was going towards my student loan. 

I am a single person who works in the health care profession. I could not afford to lose this 

money. I never heard of a membership program for things like financial planners and would not 

have wasted my money on such a program. 

9. When AmeriTech contacted me, my loan balance was approximately $23,000. 

Now it has ballooned to approximately $30,000 due to unpaid monthly payments and interest. 

I am now working with FedLoans and will begin making payments to FedLoans again in 

November. I am searching for an additional part-time job to help cover my loan payments. 

10. On July 26, 2017, I called the Federal Trade Commission (“FTC”) to file a 

complaint against AmeriTech. I told the FTC that AmeriTech offered to help me pay off my 

student loans, but FedLoans informed me that no payments had been made. The summary 

attached as Sills Attachment C accurately reflects my complaint to the FTC. My personal 

information has been redacted. 

11. I stopped paying AmeriTech when I discovered that none of my money was going 

towards my student loan. I recently received a collection notice from AmeriTech stating “RE: 

Student Loan Payment” and “***YOUR FILE IS CURRENTLY ON HOLD***.” If I did not 

know that AmeriTech was a scam, I would assume that this notice related to my student loan 

Sills Declaration - Page 2 
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 

payments. A true and correct copy of the notice I received from AmeriTech is attached as Sills 

Attachment D. 

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

on_~---' 2017, in Tennessee. 

Sills Declaration - Page 3 

Case 4:18-cv-00806-SBA Document 68 Filed 03/05/18 Page 4 of 4 
Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 1 of 6 

Sills Attachment A 
Global Client Solutions LLC 

4500 S 129th E Ave, Suite 175 ·---

Tulsa, Ok 7413;,-\ -- /) _ 

U-/JVMl Mu~~~~~ February9,2016 o0fJ- 1CJrz_,..-f1{/! f'!-/ 

... 

Memphis, TN 38127-4113 

Welcome to Global Client Solutions LLC 

Welcome to Global Client Solutions LLC (Global)! We are the account 

provider for your dedicated account (Account). We invite you to read the 

following ~ and In its fillfu.!lli'. because it contains important 

information regarding your account. Lat's stert with frequently asked 

questions about your account. 

The first question most customers ask is: "How do I access my 

Account?'' 

• Your Account may be accessed via the Internet or by calling 

our Customer Support line a-t (800) 398-7191. See below for 

more details on how to access your Account through these 

different meihods. 

• Internet ac~ss requires that you enter 

6036335021136591 as your User ID, and a Password. You 

may obtain your Internet Password by going to 

Https://Myaccount.Globalcller1tsolutions.Com and following the 

instructions to recover a temp0rary lntemet Password. You 

may also contact Customer Support at (800} 398-7 191 for 

assistance with retrieving your temporary Password. You will 

have the option of changing your temporary Password once 

you login to the website for 1he first time. 

• Telephone access requires tnat yov use your 4-<ligit IVR 

Passcode to access Account Information. Additionally, your 

Passcode may be used tor verificaNon purposes if you need to 

contact a customer support representative. To obtain your 

Passoode, please contact Customer Support at 

(800) 398-7191. 

• We encourage you to take advantage of these access methods 

to monitor your Account on a regular basis. 

I{) 

CUSTOMER SUPPORT INFORMATION ·-- Website Address: 

DEPOSIT INSTRUCTIONS 

Payment Address: 

PO Box 690870 

Tulsa, Ok 74169 

E.xpress Mall Payment Address: 

Attn: Banking Services 

4500 S 129th E Ave, Suite 175 

Tulsa, Ok 74134 

Telephone: (800) 398-7191 

Wire Transfer Instructions: 

US BamkN.A. 

Kansas Cify, Mo 64105 

ABA:101000187 

For Credit to the account of Global Clfent 

Solutioms LLC 

Administrall'.lr - Master Account for 

, Consumers on FIie 

Deposit Account 

4500 s 129th E Ave. Suite 175 

Tulsa, Ok 74134 

Account #: 145592004215 

For furtl;ier credit m Beverly Sills, 

MoneyGram Instructions: 

The MoneyGram Agent Locator can be 

found at W)YVJ.mgney9@m,com 

Sending Instructions: 

Pay to: Glo~al Client US Bank 

Receive Code: 7926 

Account#: DR21135591 

Sills Attachment A - 1 

Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 2 of 6 
are my fUnds being held on deposit? 

• Your Account balance is on deposit at an FDIC-insured bank and is FDIC-lns1i1red up to $250,000 or such other limit 

that may be detennined by the FDIC from time to time. 

How do I keep track of the activity regarding my Account? 

• F0IIO'-Nlng your first deposit, you will receive your first monthly statflment showing your Aooount activity and balance 

by mail, all others wlll be rnade available online. If you desire to continue receiving a paper statement via the United 

States Postal Service, please contact Customer Support toll free at (800) 398-7191. 

Where do I find detailed information about my Account? 

• A copy of the Dedicated Account Agreement is Included in this packet. This document lists an applicable fees 

related to your Account and discloses the rules and regulations for your Account. 

What ls Global's role? 

• As mentioned in the first paragraph, Global is the account provider for your dedicated Account Our duties include 

the drafting of funds from your primary bank account into your Account as provided for In your Application as well 

as executing disbursement instructions in a oommercially reasonable manner as soon as practical after receipt of 

such instructions. 

• Any questions regarding the status of your Student Loan ConsoHdation program should be directed to your program 

sponsor. 

• It is important to keep your address curtent in our records. We enoourage you to use the methods available to 

contact us with updates to your address. 

How do I contact Global? 

• Customer Support can be reached by phone .it (800) 398-7191 or by sending an emall to 

Customersupport@Globalcllentsolutlons.com. 

• Our office hours are 9:00am to 6:00pm CST/CDT, Monday through Friday, excluding bank holidays. 

Keeping you informed of the activity on your accounts Is very Important to us, and we strive to provide excellent 

customer service in the process. We strongly recommend you use the access methods mentioned above to monitor 

your accounts on a regular basis. 

Sincerely, 

_GIQbal Cli_ent S!:>lutlons LLC 

Customer Support Team 

Sills Attachment A - 2 

Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 3 of 6 
ACCOUNT AGREEMENT ANO APPLICATION 

L This OedlcatQd Account Agreem,nt 

and Applicatlon (" AgM<>ment") oontalnt. lhe 

letma, conditions, and disclosures that appjy to 

your dedicated accounl ('Acoovnt'"). 8y slgn'ng 

1hls Agreem11nt or uaing your Account, you 

agree that this Agreement ~hall ,pply; and you 

agree to abide b)' aD of 11,., temt5 end conditions 

set forth horcin, induding Iha •ARBITRATION 

Of DISPUTE" p,ovislon In par,gr:iph XVIII on 

page 2 of this A9reemeot, which require~ you to 

arbrtrats any dispute vnth Global. If you h ave 

any q-uestions that you do not believe are 

addressed in this Agreel'118nt, you can and 

ahould caij, email, or Wl'ite Global Cll<lflt 

Solutions, LLC ("Globalj at the numbllf or 

addregsea 8"own at the end of this Agreement. 

Pica•" relliew this Agr11ement earel\Jlly and 

keep rt with your othar Important record• In 

this Agreement. the worda, i•. "me", "min<>", 

"my', "yo.,• and · your" mean you and a ny other 

par1y whe> you authorize to use your P.ccount. 

II. Purpoae, Nature and Use of the 

Account: Your Aec01.1nt is a dedicated acc,oum 

that you cen uee in connt1ction with the financial 

service program you hove underteken to ossist 

you with the con90hdatlon of your fcd<!ral 

studont loan&. Global ia not a patty to your 

flnancial &ervlce program ond doM not 

part,cipote in 1h11 consolidation of your federal 

student loan:. In 9en11ml, you w11 be (i) moking 

periodic deposits to your Account from your 

primary bank account and/or via debiVcredit 

card transactions, if applicable. ond (ii) you w-D 

bo periodiallly dlsborsmg funds from your 

Account to pay for the services as110ciafed with 

your 6nancinl service program and your 

Acoount, and, If applioallle, to pey studenl loan 

lendera. Your Accounl la a FaclerQJ Depo&it 

lm:.urance Corporation (''FDIC-) insur11d subaccount within a master cusfodial acoount 

muln!alned at a bahk de&/gnated or aelecied by 

Global. Mclitionally, you autl,on~ GiobOI to 

transfer your Account to another FDIC insuNld 

institution under the existing terms. Global will 

provkle written notice to you of ouch change. 

Any such notice. and any other wntten nofJC<> 

that Is provided for in lhl• Agreement, WIii be 

sent 10 you al either the physlcnl i,ddrean you 

have prolllded ,n the application portion of this 

Agreement and/or tho email oddret.s you 

establish with Global. II an emoil ttddrea• is not 

provided to Global, all notleea that ue provtded 

for in thia Agreement wtN be sent 10 you at the 

phya,eal add=3 you hir,e provided in the 

application portion of this A9reernen1, Your 

Account m.iy not be used for any illegal 

purpose. 

Ill. Past1codes I Password.,; You win be 

provided with D four-digit pa&$Code (your 

"PaaalXlde") that wm onoble you to aceaH ycur 

.-.Ceount 'Ila the telepl'IOne ~nd la Identify 

yo,1rsclf when coritactlng • custom@< suppor1 

representative. You will also be provided "'4th 

ar, in1bal Internet password (your ·Password") 

!hat will enable you to access your Account vl.i 

the lnlarnet. You may change your Pa~sword 

at any time for aecurily purposes a,,q you ar<> 

encouraged to do so from time to dme. You are 

responsible for the prott>ction and use or your 

Paaooode ond Password. Do not discloso your 

Passcodo or Password to anyone who does not 

have your perml .. ion to access your Account. 

rv. T4!lephonic Electronic 

Communications: You authorize 131obal lo 

accept and act upon soy IMtrucbOn received 

from you or authorized by you Undel' !hi$ 

Agreement concerning your Account, where 

you have communicated thet instruction or 

uuthoriUtion by lelephor,e, tac,rmile, email or 

other eloCll'tJniC means uaing a ti>lephcne 

keypad or computer. Uno of your Passcode, 

Pa&eword or any o1har form of idcrnlficaeion 

c!esigna!od by you in MY tre11et1ction constilutoa 

and will be aoceptod as your eledronic 

signature, as that term is ur;ed in tho federal 

Electronlc Signature, in Global and Nallonal 

Commen:e Act and other applicable laws. 

V. Authorlzino and Initiating 

Transactlona: In this Agreemant yell authorize 

certain ltansadlone involving your Account. 

UnlKA you dlrect othsMloe ,n writing, GlobOI 

m"y also act upon thooe Instructions thQI you 

hAve conveyed lo your Sponsor, at <le'fined In 

lhe aP!)fr<:at on ~ortion of this Agreernent, and 

such instructons may be 3Cled on without 

further G0<1firmation. From time to lime. yoo 

may chenge lho•e instructions and/or give other 

lnatruclionB by contacting Global's Cusiomer 

Support. tn any event. you must always provide 

a reasonabla period of time to act L1pon your 

lnotructiona. Ali d•poaits to your Account will bo 

euthorlzad and Initiated, as epplicable, pursuant 

to your instruclions, and en dlsbvrsemorrts from 

your Account wlll be uuthorized and inttiated 

pursuant to your lriitructlons and provided it 

comains sufficient funds to cova· tho amount of 

tl,e disbul'M!ment However, neither Global, nor 

any sorvice pr,,vlder to Gle>bal ,h·au bG 

r&«po,,,slbie for determir,ing when a payment is 

nelually due, nor llho.11 they be responsible for 

determining whitther a payment Is for !he 

correc1 amount er othen.vise proper. Global's 

ll<lle cbllg,,tion In lhia regard will be to execute 

your payment inwucL'ono in a commercially 

reasonable manner as soon as practical alter 

receipt or •uch tnetl\lC!ionn. Global nhQII not i,. 

responoible for ony late i:,eyment fee, P<)nal(y or 

Olhe,- c::h:arge levied against you; or lot •ny othar 

adver&n action taken by any party. Global $halt 

not be lic,ble !or any conaequenc•e or d:amag<:a 

you may daim resulting from Global ac:ting on 

your int.1J'\JCtions. 

VI. Fee,i 311d Charges; Tha 

"SCHEDULE OF FEES AND CHAAGES" 

ldellbTles the fee, IU1d charges you aro obligated to pay Global in connection wi1tl this 

Agreement and your Acoount: and you agrae 

that theoc fee$ and charges may be decl.lcted 

dlredly from your AcGounL The feo:: and 

charges In the "SCHEDULE Of FEES AND 

CHARGES' are thO only reoo associated with 

Global's eervices and your Acc01Jnt The 

Monlhty Sorvioe Chari;e for the firat month In 

whleh your Ae¢0Unl Is Mlobllshed will not be, 

prorated .ind will be deamccl earn,,d in full u of 

the day 1h11 Aocount ia eslabVt.hed, o g , if your 

Account la estabflllhed on the 15"' day of a 

month. 1he Monthly Service Charg<> for sueh 

month ahall bo corned os ol th"t day. 

Th"resfter. lhe Monthly Set'llice Charge will be 

deemed eamed in full on tho r.rst day or each 

e3f8"dar month during which your AccC>IJnt 

rorfUlfns open. Olhar fees will be dae~ 

e,rned at the time of the transactlon or the 

event t1iet give& ri$e to tha fee. You expreuly 

acknowledge that Global may inaease the fees 

ancl eherges an0cill1ed 'Mlh your Account al 

any time. ancl that you will be pre>vided wi1h written notice al leest thirty (30) daye' prior to 

such increase. GIObal allal not be responsible 

for Qny other tees and/or charges that you may 

incur in assoclatioh wnh your finenciol service 

program. 

VII. Termination of Agreem•nt 

Account Closure: You may terminate ~is 

/\greemet1t end dote your Account at any II= 

by ll&Jlding a writtM noUce to Global's 

Cu~tomor Support. The wr~cn notice must 

p.-ovlde Global with the following information; 

1. Your lull name and current address: 

2 . Your Account num0er; 

3. The date of the requoet; and 

4 . You, reql»st lo dooo your Account. 

Plea-se provide Global with ~ufl",cienl time to 

process lhc requeat. In additi0f1, Global may 

,wcpend, cane,,! or terminate this >,greeme-rt 

and your Aecount at ony time without notioe for 

inactMty, or If your nnanci$I service program 

has been ltlrmirwted or is no longer being 

managed, if your Account Is mprope,ly 

maintained or u~t'd, or 1f you otherwiae violate 

any provisaon of this Agreement. If this 

Agreement iG terminated tor Olly realOll, or 

upon Account clo;,ure, 11,11 colledad bel•nce in 

your Account will be credited to the debll/orecf~ 

card account utilized for depooits and/or Will b& 

sent 10 you 0y ch«k, as deemed appropriate by 

Globe I, wilhln a """sonable period of time. 

VIII. Monthly Statements: You will 

recoive your ~rst monthly sblemenl by ma! 

llhowmg you, Account actll1\1y r,nd balance by 

mall. The,walter. monthly stntementa wm be 

avail~ble onllne, and may be accessod using 

your lo;;in Information and Password. Should 

you desire to c:onHnue reco,vin9 a paper 

atolemenl via tho United Stataa Postal Service, 

please contact Global's Cuatorner Support and 

make a request 10 recelv1! mailed paper 

atatementa. You moy cbUln balaneo and 

transaction rnformation by using your Passcode 

to oooess your Account over lhe telephor,e, by 

using your Paa&word to log Into Globol's 

W11beite, or by carron11 Globers Cuetomer 

Support. You agree lo raview your statement 

carefully and to reJX)rt any srroneous, m,proper 

C1I' unau1horized tranSIICllona promptly. 

IX. Non-loter11st Account: Your 

Account is Q non-inti,reot bearing Account. 

X, Unauthorlzad Transactions and 

O'U$tcM'ler Rospone,fblllty: You should never 

9f'111re your Pesacode or Pnsword(s) wtth 

anyone and ehould keep your Account 

information and papera in a ,ocure ~oe. It 

you ~ liev11 aomeono hos 1rana,.,rred or may 

transfer monoy from your Account without your 

Sills Attachment A - 3 

Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 4 of 6 
contect GlobaJ'o C1n1tomer Support 

1mmedl8lely. 

XI. FDIC lllsuraneo: · The funds in your 

Account 'Ml! be FDIC in9ured up to a ma)<lmum 

of S-250,000.00. Tile inSUNtd emount may 

lncr&a5e or d8Ctl!ll9e and is subJed to limits ""t nn<I re~et by the FDIC rtcm time 10 time. 

XI. ln«>mplete Transactions: Neither 

Global nor • nY servlc;o provider to Global &hall 

be llable for falling to complete a IrensaC1Jon 

d~e to lnr.ufficient flJnds in your Account; or if 

cimJll'lfltJnces beyond their conll'0I prevent the 

oompletfon of the transaction, Including, without 

llmlf81ion, the ads or omissloM of any ACH, 

check or olh8r proce ... or, the Netton11J 

Automated Clewin9 Hoose A$80Ciation, the 

Federal Re$('{Vf) System. any bank, er the 

cflfflCtive of any ragulato,y authority. 

XIIL Error R8SOlu11on Prooedurea: In the 

ovent of potential elTl:Jr'S or quMtions 

concerning specllle tno.nsadlona fnvoMng your 

Aceou1t, you musl call or write Global'a 

Custorn<>t Support no later than sixty (60) deys 

altar the lr.lnsadion In qu~on ap,-ir.s on 

your monthly s1atement. Fur1h"'l'm0nl. ;rt the 

very minimum you 11'"'5I provide Global with the 

following Information: 

1. Your fU!1 name and Aa;ount 111.1mber; 

2. The dlite end amount or IM 

tT111nsac1;on; 

3. The type ol transa,;tion ond a 

deseriptlon of the sll$p0cied em,, 

(pleaff a)(f)lein as clearly as 

poseible wtly you believe there is an 

error or why you need additional 

informetion); and 

4. The dollar amount of the GUSpe~d 

error. 

If th@ informalion mos pn:,vided over the phone, 

you may be asked And requlmd to provide it 

again in WT1ttng Within ten (10) business days. 

Global will Inform you of the result$ ot the 

lnvesllgatloo of the autpected erl"Or within ten 

(10} bwliness daya ofter you submll Che 

infonnatlon and al\y error wil b& promptly 

com,cted. However, If Global requires more 

tirne to investigate tho suspeete<I error, it may 

ltlk e up to AA adcfdlonot thirty (30) d•ys to 

comptete the lnve,tigallon. If Global 

dAMrn,;nes lhnt there Is r,o em>t, you wift be 

pro\lided with a wntten explanation within threa 

(3) bu&lnen days of such dAt@rtr11natlon; and 

you may a.$k to, aod receive cop!ea ot tho 

doc:umenta used In making any such 

determination. 

XIV. Diaputes: You und,gtand ona 

fl1@0 that Glr>bal Is not o 

ft>dera p•dle 

sW e•rtv to voyr flfl~fJ~JII rate 5ri,v/ce ~· do"" not /r, th~ld~ of vour 

!ftudont IWIQ:!>. This Ag-•rrt i& 

~arate and /r,depflrldem from any 

co~uat obligatit>ns you may have with 

your studem I0'1n lend&m or your Sponsor, 

oo defln<Jd ;" the appllcat/or, portJon of lhls 

Agn,M>1mt Accordlngly, rou herebx 

Pltpren{y acknowt•m that Global dott not 

have any /nvo(yem,mt In 9( c,:soom,/bl/ltiff..'I 

of any n.turn. w1μ1 "'tRfCI to l('OUf 

contractufll •atNmont wtth vouc sean,or. 

your flrnmf/111 ,...,..,;er program or th• fllOY/f;t 

lhot you may or may not oehlt1vv from vour pR(tlcfp;Jflon ltt e t1n .. ne1n1 servkt> proqaro. 

Furthonnore, you h,,,.by e,cpre!l&fy 

.,;knr,w(&Cigfl that any repres«>f;Jo(lon, 

st.nam,mt or obllgatlon mad• by your 

Sponsor or fr, cormoction with your fim,nc/11I 

servfco program dO{lti not ""d ,;annot bind 

Global Finally, yOu upracs/y 11eltnowf~ 

thllt Glob:,/ fh•II i,of b• l#abl• for any odlons 

taken by yo,,r SpQflsor In connedTr>n with 

your /fn1111clal tiervlce program, 

XV. Gamlt.hml!flt AcknoWledgemant In 

the event ttiat a creditor of yourg moves to 

gamiah fl.Ind$ In your Account, you <JXP'9$$ly 

acknowledgi, tht Gk>bal wf/1 answer the•

gamuhment and comply with any writ 

/s,;ued by the Court In 11c:con:far,cq with lh• 

appllcablt1 $tllle law. Furth..,,.,oro, you 

11xpressly IICknowlfKlg• thm. Glr>bal WIii not 

be ret;ponslble for chalklngfng or raatng :, defenSII to the garnishment r,n your behalf. 

You specifically agree to lncfcmnify and hold 

Global harmless t'rom any lo&s, liablllty, 

ob!Jgation. damage, cost and expense rooulUng 

fNlf'l'I a c:Bdlto,'s attempt to gamlsh and/nr hold 

Global Hable for any judgment against you. 

XVJ. Governing ~ This Agreement 

hall be 90vemed by the tawe of Iha elate 

where you roside, except t.hlll trie state's nJles 

or statutes govemln!J e.rbltr.!ltlon Pro<'.E'dunis 

shall not t1pply. If 111'1)' part ol thlo Agreemem is 

d11d11f«t void or unenforceable. tn,ch 

provlsion(i;) "1Qil be deemed se11ered /torn this 

Agreement, and the remoinder of Jhis 

Agroement shnn romain In full force and .:,ffect. 

Th;s Agreement may be modif1ed to the extent 

necessary IX> gl'll'I 1uch force ond e lled lo the 

rnme.ining pn:,visions. No delay or forbearance 

in the slr\ct Observance or perfo<m.nce of any 

provision of this Agreement, nor any failure to 

exeroise a right or remedy hereundt!r, snnll be 

CO<'lstllled :io a waiver of such f)QlfOfTTlaooe. 

right, or remedy, as the case may be. 

XVII. Limitation of Liabtllty: Undor no 

<:ircumstanc:es llliall Global eve,- be Uabre for 

any speciol, inddontal, consequonl!R!, 

exemplary or · punlti\/0 damogoa. Moreovet. 

undlor no d rctJn>Gtances snau Global ever be 

lieble for the conduct or contradual ob!i!Jatlons 

of a third perty, Including. but not nma.d to, the 

Sponsor, ar. defined In the appl1C311on portion of 

thi$ Agreement. 

xvm. ARBITRATION OF DISPUTE -

IMPORTANT NOTICE AFFECTING YOUR 

RIGHTS: In the event of any contrQVersy 

bctwoon the parties, Including, but not limited, 

to any clalm, dlspute. suit. damend, crosa claim, 

counterclaim, or third party compt.int (whether 

slirtutory, in tort. or otherwise) arising out of or 

ret11tir19 to thla Agreement or It, permrrnance. 

b,aacto, termination. en"""8ment, Tnte,pmllrtlon 

or vard',ty, fncludlng Ole w lidity, SCOl)4'I or 

appllcabltlty of this l)IOVision to arbltrato, ah11Jl 

be determinod by bindln!l arbltnrtion. This 

arbitration pr011ision is governed by the Fttderal 

A,t,ltMI.""' Act ('FIA"), 8 U.S,C . § 1 ot -,. end 

not by any atate rule « statule governing 

&rbitration. Arbitration under this p,ovi,.;on $hall 

be conduetod in elH'Mlr lhe county In i<'Rllch the 

00n$umer resJdM o, tl>e clo!!#at metropolitan 

county. THE PARTIES AGREE TMAT 

ARSlTRATION SHAW. BE BEFORE A 

SINGLE ARBITRATOR ON AN INDIVIDUAL 

BASIS AND NOT AS A. CLASS OR MASS 

ACTION. FURTHERMORE. THE PARTIES 

AGREE THAT 'TltE ARBITRATOR MAY NOT 

COl'ISOLIDATE PROCEEDINGS 01' MORE 

THAN ONE PERSON'S CL.AIMS. The 

Arbltmlion shal be admin!steted I)\' the Judicial 

Arbma!lon Mediation Services ("JAMS"), 1920 

Main Street, SUilC 300, Irvine, CA 92614 

/Www.iamr.agr.com), lhe American Arbitration 

A~cialion (°AAA"), 335 Madison Ave., Floor 

10, New York, ~ 10017-4805 fwwwadr,orgl. 

or another · nai!onally known consumer 

arbtlrntion service on which th~ partlaa ehall 

agree. Arbitration ahall be administlfflld 

ac::amllng to tho arbt\ration se,vice's lee 

schedule and the service's c:ummt eppliellble 

trules and f)fOce<luraa except: 1) lh6t /hG potties 

exprr,s'5/y waf\te the opp/icsbflily of My rule 

governing c/oss or 1l'141$$ action; tmd 2J that the 

partlos og,89 /he( ""Y specific art,itrotion 

procedure provided for herein shot/ spp/y to IN! 

orbitratJon procetldln9- The srbit,.,tor shall be 

r,qutraJ Md /nd&pendent and !JhaU comply wilh 

Ills seledttd •rbitref,on sen,ic.,'s code of ethics. 

Aeiorttonolfy, the arbllrotor sh11" be guidfld by 

and apply th@ Federal Rules of Evidence and 

"t)oveming subston/lV9' lew. Th<! arbitrlrt0<'s 

llwatd shalt be final and bind'ng on all p.arties. 

Judgment on lhe art>llretion eward may be 

entered In ony court havillg juriodlction over the 

parties. Ir t1 party fab to oompfy with the 

amltrtltor's ;wmrd, the othe,- party may ~ Jon a 

coun having jurise1clion to enforcn the award. 

Toe pol1iu shaU bear their own «ttomeya' fees 

u11f"8$ such fnoa are oxpreaoly pn:wldl>d for by 

applicable law. If the arbitrator d«tertTiines that 

reasonabljl attomoya· fees ara to be awarded 

under appfic.lble law, the parties agree that the 

11rbitrator will ol5o d111ormine the amount under 

the award for attomeys' fees. In tho event a 

pony falls to pn,ceed with art,Jttolion. tafls to 

comply with the arbitrator's aWQrd or 

uneuo::ocssfu11y clnollenges the erbilrator't. 

award. tho other porTy ;5 entltl&d to any co&tS 

and ""'P""Ses lncun'od, lndudlng a rea-.bfe 

attorneys' fee for having to compot a,bilraUoo or 

de~nd or enforce tllfl award. 

,,.rt/«$ Binding Arbi tration ,,,_II$: (1) fhat bot/1 ghli, up t1Nl right to a tri~ by a Judge 

r>r Ju,y; (2) that both par1ie9 give up th• right 

to •ppeal rrr>m 11m Mbltmtor's rvl/ng 1t><cnpt 

for a narrow rango of appt!/Jltlble 1,Jt;ues 

'"'Pressly provided for ir, fl IJ.S.C. § 16; •nd 

(3) that dlsc'10l'flry ""'Y be !JOvterely llmlmd by 

tho arbitnfr>r, Md should the arl,/ln,tor 

decide fr> nllow full dlscovvry, the 11rl>ltmtor 

may not cxcffd dittcovery limitations t1ei 

forth by Iha FederaJ Rum ol Civil 

Proceduro. 

XIX. USA Patriot Act Compliance: As 

requlrBd by the USA Po.trio! Act. you aulhome 

Globel to take ma•onable and p<actlcal 

mea .. ures to verify !he accuracy of the 

Jnrorma1lon you have provided in lhe applic:GVon 

poT11on of this Agraament as well aa to verify 

your ldcnttly by. irl<;lu<llng anct VYithout limit!tlon, 

socuring or ocoessing your credtt report, and/or 

o btaining any othe, onformalio'l about you in 

o r<l@r to e,a'at ,n c:ombatin9 19n'ori-ml ana preventtng Glot>af.s &yntem and the banklng 

eyetem from being uoed for money laundering 

er other impermls•lbla, Illegal purposes. 

Sills Attachment A - 4 

Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 5 of 6 
PRIV -,cy POLICY: Global may collect 

poreonol information that you provide: (1) In the 

applica1lon portion of u,J.s Aarvemenl, (2) in any 

updatod lniormatton you may provide from ttme 

to time; and (3) u part of the transaction, 

processed through your AceounL A deserlption 

of the Privacy l"olicy applicable lo your Account 

is provided below, If you have add~ionsl 

quostions regardi11g this Agreement's l"nvacy 

Policy, plea~ contact Giooors CusiO<T1er 

Support. 

a. Collectlon I Uee of Pa,..o nal 

lnform3tion: Collection of your 

pel'SOtlal lnl'orrnation Is d.eslgned 

to protect accaoo to your Account 

a!ld lo assist u, provi<!ing !/OU Wlth 

the products and sarvicee you 

have t\!qu~&ted. AJI personal 

information collected onct stored 

by Global, or on its behalf, la us9d 

for specific business pt,rpose,,: 

(1 J to protect and administer ywr 

A<:count and i11itiato your 

~uthorfzed trancnciiona; (2) to a19ist in the design or 

lmprovoment ol produe(a and 

services: (3) to ""'"'ICM Identify addllionol 

produda or offered by 

Global anct/or its affiliated 

com pa nlea that may meec your 

needs; and (4) to oompty with 

state and fsderal banking 

regutat'°'1s. Only approved and 

1uthoriied personnel wlll hall!! 

accan lo such informolion To 

furtlier protect your informalion, 

ouditlng mechanisms !lfe in plaoa 

to Identify anyone who may have 

aeeesse<l and in ony way modif'""d 

your pemonal information. 

b. Ma,ntenance of Accurate 

Information: You may update 

your perSONI infom,alon onllne, 

at any time, by using your 

Pgssword to log Into Global's 

website or by con1act1ng Globat's 

Customer Support. To ensure that 

Global is • ble to protect your 

Acoount and verify your 

Information, it is in your best 

intereolS to maintain accurate and 

current any records eonceming 

your per11onal information. 

o. Limited Access to PersoMJ 

Information: Acee.,• to your 

personal fnformalion Is llmited to 

only thooa perGQflMI wtth 11 

buaineSG reason for aca,ssing 

woh ln'formalion. In t1ddllion, all 

personnel are trained and 

Aducated about tho importMce of 

con(Kfeo1lali1y $1ld 0111:tomer 

privacy. Individual USlll' name& 

end passv,orvs are ueed by 

approved personnel t(l aceees 

your i:,ersonol information, 

provldi~ aua,t trolls to further 

&afeguard tho privacy of your 

personal ,nfo,mation. 

d. Thlrd•Party Olael~ur@ 

Rutrtcttona: AU third part,ies with 

a businaas noo<I to acccaa your 

personal information are requlrad 

to Mhere to atrfngent privacy 

policies Your par90nal 

information moy be supplilld to e 

third party in 0tdl!r to process a 

tr.ansacilon you hiwe aulhorlzed or if the disclosure ia aUo""1d or 

required by lew, e.g.. the 

<>•change of information with 

reputable reporting agencies In 

reapcnse to a subpoena, In 

connection with the invest!gatiOn 

of fraudulent aclivfry, etc. 

e, Sh;irlng of Information: You 

auV1orlze Glob,.r fo ehare certain 

lnformation v11th your S:,onsor, as 

defined in the AppllClltion pof1ion 

cf thia AgMernent. and any third 

party to the 11lltent necessary to 

admlnlater your Account In 

t!CX'-Orde noe with vour instructtons 

and authorization, Yoo expre$$(y 

ar::know/edge that Global cJo•~ 

not maintain rtH;orr:h; or er,y 

doeumt>nts or lntorm,JJon 

"-Ssoclated with your finnnelal 

service program. 

XXI. Engtlgh l.anguago Goverl\8: The 

terms of this Agreement and the products and 

services we l)IVvlde are govemt>d by the 

English langi,age. As a co,ntegy; Globlal has 

made thi• Agreement available ,n longuag~ 

other than English. If there is any difference in 

meaning t,et,ieen the, English Md non-Engllsh 

version of any of cur documents, Including t'1is 

Agrc,,menl, the English version v.;11 apply to 

yowr ACGOunt ond Is av811able to you upon 

request 

XJOI. Morger Cleusa: Thi& Agreoment 

contaiMs the c:omplale and !lnal understorta,ng 

between the partSea. Any prior or81 sla1ements, 

representations, or agreement, are &Upel'S4Kled 

by thia Agr&ement 

SCHEDULE OF FEES & CHARGES 

Monthly s ervlco Charge $8,00 

tncoming Wire Transfer s,o.oo Acl1 Payment Fee $1.50 

Outgo·n9 W.-t> Transfer $1S.OO 

Manual Check Peymont $i.oo 2nd Day Oe!lvory $1 0.00 

Overnight Oalive,y S20.00 

Stop Pay Foo $1 7.50 

Sills Attachment A - 5 

Case 4:18-cv-00806-SBA Document 68-1 Filed 03/05/18 Page 6 of 6 
Case 4:18-cv-00806-SBA Document 68-2 Filed 03/05/18 Page 1 of 2 

Sills Attachment B 
AMERITECH 

- FINANCIAL2s•i6• 53il 111 ••1

~*~••~••••MIXB.r1 A,/\DC 9.56 

Beverli Sills 

Mempis, TN 38J27-4 I I 3 

•I 1111

11 I ,I, 111 •1

tfll 11111111111

1

,

11 1 l'I " 11

11 11 •11 I 1'1 "'" l•l • I 

AmeriTech Financial 

110J Investment Blvd 

Ste 290 

El Dorado Hills, CA 95762 

Toll Free: (800) 792-8621 

Ja.nuary 13, 2017 

Account Number: 

Dear Bevc.rly Sills: 

On behalf of Ameri.tech Financial and Financial Education Benefits Ceuter, we write to advise 

you that the servicing of your dedicated account i.s being transferred to a 11ew company for 

processing effective 02/01/201 7. There is nothine; you oeed •uo reg![diing this chana:;e; it just 

means that after that date your monthly document prepar.ation payments that you are setting aside 

and/or membership fees will now be collected by Account Management Plus (AcctMgtPlu) 

instead of Global Clients Soh.ltions (GCS). 

Global Client Solutions will stop collecting payments as ofOl/3 l/2017 and Account Management 

Plus wil.l collect all payments moving forward. On your bani< statement you will now sec the 

payments listed as' AcctMgtPlu' during yout regular.Jy sched11l.ed draft date. 

Nothing about your payments or payment plan will change. Foe any questioms, please contact 

Ameritech Financial customer service at l-800-792-8621 or FEBC customer service at 1-800-

953-1388. We are available Monday - Friday 8am - 5pm PST. 

We arc pleased to serve and assist you in any way possib le. 

Sincerely, 

At:o.eritech Financial 

1101 Investment Blvd. Suite #290 

El Dorado Hills, CA 95762 

(800) 792-8621 

Phone: (800} 792-8621 

Fax: (866) 818-9026 

Email: custoll]ler.service@ameritechfinancial.com Website: www.amerite 

Sills Attachment B - 1 

Case 4:18-cv-00806-SBA Document 68-2 Filed 03/05/18 Page 2 of 2 
Case 4:18-cv-00806-SBA Document 68-3 Filed 03/05/18 Page 1 of 3 

Sills Attachment C 
Record # 4 / 86644070 / Consumer Sentinel Network Complaint 

Reference 86644070 Originator 

Number: Reference 

Number: 

Language: English Contact Type: Complaint 

Source: Consumer DNC?: No 

Comments: Caller received an e-mail from Ameritech financial offering to help her pay off her student loans Fed 

Loans has informed her that no payments have been made. Consumer has realized this was part of 

a scam. 

Complaint 

disposition 

provided?: 

Complaint 

Disposition: 

Data 

Reference: 

Created By: MVELETA Created Date: 07/26/2017 5:28:06 PM 

Load Date: 07/26/2017 5:28:06 PM 

Updated By: Updated Date: 

Complaint FTC Call Center Product Advance-Fee Loans, Credit 

Source: Service Arrangers 

Description: 

Amount Amount Paid: 

Requested: 

Payment Bank Account Debit Agency Phone 

Method: Contact: 

Complaint 07/26/2017 Transaction 07/26/2015 

Date: Date: 

Initial Contact: Internet/E-mail Initial Phone: other 

Response: 

Statute/Rule: FTC Act Sec 5 (BCP) Law Violation: Deception/Misrepresentation 

Topic: Dispute with 

Credit 

Bureau?: 

Dispute with No Dispute with No 

Credit Bureau Credit Bureau 

- - Resolved to 

Responded?: Satisfaction?: 

Member of No Cross Border No 

armed forces Complaint?: 

or 

dependent?: 

Consumer Information 

Consumer 

Small 

Business or 

Organization: 

First Name: Beverly Last Name: Sills 

Case 4:18-cv-00806-SBA Document 68-3 Filed 03/05/18 Page 2 of 3 

Sills Attachment C - 1
I-

-

Case 4:18-cv-00806-SBA Document 68-3 Filed 03/05/18 Page 3 of 3 

Address 1: Address 2: 

City: Memphis State: Tennessee 

Zip: Country: UNITED STATES 

Home 

Number: 

Cell Number 

Work Number: Ext: 

Fax Number: Email: 

Age Range: Military 

Service 

Branch: 

Soldier 

Status: 

Soldier 

Station: 

Subject 

Subject: Ameritech Financial Normalized 

Name: 

Ameritech Financial 

Address 1: 1101 Besment Blv 290 Address 2: 

City: Eldorado Hill 

(Cleansed: El Dorado Hills) 

State/Prov: California 

ZIP: 95762 Country: United States 

Email: customer.service@ameritechfinacial. 

com 

URL: 

Phone 

Number: 

800-7928621 Ext: 

Subject ID 

Type: 

Subject ID 

Issuer State: 

Subject ID 

Issuer 

Country: 

Sills Attachment C - 2
Case 4:18-cv-00806-SBA Document 68-4 Filed 03/05/18 Page 1 of 2 

Sills Attachment D 
*** YOUR FILE IS CURRENTLY ON HOLD *** 

Account Number: STLNAS 

(866) 238-8210 

RE: Student Loan Payment 

4•s•1,339 .. ••*'•• .. •••MJXED AADC 956 

Bevedv Sills 

Memphis, TN 

•h 11••11•1• 11 llh • 111 • I •I• 11 t1 nl11IIIIr1 1 1 1111 I 11 1111' 1 '1 •I• ii I 

Dear Beverly, 

There was an issue in drafting your monthly payment. In order to get your file back on track you 

are required to resolve this matter immediately. 

Call us TODAY at (866) 238-8210, Monday through Friday from 8 am to S pm PST, and a 

Customer Servjce Representative will help you. 

We value you as a client and look forward to serving your needs. 

*** Dont riskfallin9 behind on your payments to our company 

for the services you asked us to perform - ACT NOW*** 

Warm Regards, 

Your Ameritech Financial Team! 

· ·· U01- J.n-vestmentBlvd,Su.~98·--· 

El Dorado Hills, CA 95762 

(866) 238-8210 -Toll Free 

1-866-818-9026 " Fax 

Account Number: STLN~ 

Sills Attachment D 

Case 4:18-cv-00806-SBA Document 68-4 Filed 03/05/18 Page 2 of 2