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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 DANIEL 

HAMILTON IN SUPPORT OF 

FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 34 Filed 03/02/18 Page 1 of 4

DECLARATION OF DANIEL HAMILTON IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
Hamilton Declaration - Page 1

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DECLARATION OF DANIEL HAMILTON

1. My name is Daniel Hamilton 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. Attached as Composite Exhibit A are copies of miscellaneous AmeriTech related

documents I still have in my possession.

3. I started working for AmeriTech Financial around February of 2016. My 

employment ended nearly two years later when I was terminated around November 13, 2017. I 

was told that I deviated from the script by adding the word “any” to some portion of the script, 

however, my suspicion was that I was fired for asking too many questions about how the 

business operated. 

4. Throughout my tenure at the company, I was employed as an enrollment 

specialist in the sales department. I reported to the El Dorado Hills office located at 1101 

Investment Blvd STE 290, El Dorado Hills, CA.

5. My training prior to starting lasted approximately 2 weeks and consisted of a 

series of tests and mock phone calls. I was also given a script that I was to practice. This script 

changed numerous times throughout the course of my employment. 

6. I worked in an office where we received inbound phone calls from people that 

received our mailer. The mailer told consumers that AmeriTech Financial could reduce their 

monthly student loan payments and to call our phone number for more information. 

7. Once prospective clients called, my job was to encourage them to enroll in our 

program and help them fill out our application over the phone. I would tell them that our 

program was designed to eliminate or reduce their monthly student loan payments and that I 

could qualify them over the phone. 

8. The criteria I used to qualify clients were occupation, income, family size, and 

student loan balance. These factors determined if a potential client would qualify, with the most 

important factor being family size. 

Case 4:18-cv-00806-SBA Document 34 Filed 03/02/18 Page 2 of 4
Hamilton Declaration - Page 2

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9. In the event that a potential client did not qualify, management would encourage 

us to revisit the family size figure and get them to qualify. I recall being counseled by 

management when not giving examples of what constituted a family member. I recall a floor 

manager telling us that someone you gave gifts to meets the program’s definition of a family 

member. 

10. Each week, I had to enroll a minimum of five clients. After six clients, I began to 

earn a bonus. Some of my colleagues in the sales department enrolled up to 15-17 clients a week. 

They accomplished this by aggressively inflating family size figures. 

11. Page A-6 to my declaration is a copy of the family size to income matrix that we 

used to qualify clients. For example, if someone earned between $80,001.00 and $86,000.00 a 

year, they would need to claim a family size of thirteen to qualify for our program. 

12. The program fees were comprised of a document preparation fee and 

membership fee. The document preparation fee ranged from $800-$1,200 and was used to

restructure a client’s loan by filing forbearance or deferment paperwork. 

13. Once a client signed our contract, we would also sell them a packet of other 

benefits. I am unsure of what these benefits were or whether clients actually used them. There 

were different packages labeled “A” through “R.” The “A” package was the most expensive and

was sold to individuals that could afford more while the “R” package was sold to those that 

could not afford as much. 

14. To my recollection, these packages ranged from $69-$240 a month. The 

membership would renew each year and the monthly fees were designed to be collected each

month until a client’s loan was paid off or forgiven. This could in many instances take between 

10-25 years. 

15. My understanding was that at least some of the fees clients paid us were going 

towards paying down their loan balances and that we would pass along client’s payments to their 

loan servicer. Due to how compartmentalized the business was, I was unsure of what the fees 

were for or whether customers knew exactly what they were getting. 

Case 4:18-cv-00806-SBA Document 34 Filed 03/02/18 Page 3 of 4
1 16. I recall management being dismissive when I asked them about how this process 

worked and how we were helping our clients. My general impression upon leaving this company 

was that they were running a scam. 

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

on ~~ I ?. § /. 2018, in California. I 

Daniel Hamilton 

Hamilton Declaration - Page 3 

Case 4:18-cv-00806-SBA Document 34 Filed 03/02/18 Page 4 of 4
Hamilton Composite Exhibit A

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 1 of 18
)BNJMUPO "UUBDINFOU "  

Dare 

I 

~01;r e111p/01mem sratus Witl, Am«itecl, Ffoaaeia/ has chaoged for the following reason, 

.._/ Re.,;1 led / VOhu,t,~, quit efi'ecOvec ~ ~ayofreduclion in force effective: 

D . . I I ;, . . = . ~- - !scnarge tenninar,on e,£ectrve: 

0 

Refusal f · to accept ••aiiabte work effective, 0 

.~••ve •bseo~e effective, 

1:.:{pecte date ot return to i;vo1-Jc 

E01pleyee AcknowJedgmeat I cecoived a copy oftl is oorice on -l//2:;;, /, = 

Da~ 

---

---

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 2 of 18
)BNJMUPO "UUBDINFOU "  

Appendix A 

Employee Statement 

1. Confidential Information. Except as set forth below, I acknowledge that at the 

commencement of my employment with the Company I know nothing about the Confidential Information of 

the Company or its Clients, except information that has been disclosed to me by the Company: 

2. Conflicting Relationships. Except as set forth below, I acknowledge that I have no other 

current or prior agreements. relationships, or commitments that conflict with my relationship with the 

Company under this Agreement (if none, so state): 

Dated:. _ ________ _____ _ 

) W /ism I 

(Typed or Printed Name of Employee) 

l-123 IC 

Appendix B 

Termination Certification 

This is to certify that I do not have in my possession, nor have I failed to return. any Confidential 

Information or copies of such information, or other documents or materials, equipment, or other property 

belonging to the Company. I further certify that I have complied with and will continue to comply with all 

the terms of the Confidentiality, Non-Disclosure And Non-Compete Agreement which I signed as a 

condition of employment. 

I further agree that, in compliance with the Confidentiality, Non-Disclosure And Non-Compete 

Agreement, I will preserve as confidential and not use any Confidential Information or other information 

that has or could have commercial value or other utility in the business in which the Company is engaged. 

I will not participate in the unauthorized disclosure of information that could be detrimental to the interests 

of the Company, whether or not such information is identified as Confidential Information by the 

Company. 

On termination of my employment. I will be employed by _ _______ _

r--+------

_ ____ _ 

(name of new employer) 

(if not applicable, so state) _ ____________________ _ 

Dated:________ Y?w/l~ 

Employee Signature 

t)JhLJ tiA-m V:f) d 

Employee Name Typed or Printed 

-----

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 3 of 18
)BNJMUPO "UUBDINFOU "  

Disciplinary Action Notice 

• Verbal • Written • Final Written Termination 

Employee Name: _,D~an=-..,Hs::am:.:.:.:.il:..:.to...,n.,__ ________________ _ Date: November 13, 2017 

Department: -'S=a=Je=s~- --------------------

Job Title: Account Specialist 

Description of Events 

A 1/ach additional pages if necessary 

On August 18, 2017, you received a Verbal Warning for not meeting the acceptable standards for Call Compliance. On September S, 

2017, you received a Written Warning for not meeting the acceptable standards for Call Compliance. On September 18. 2017, you 

received a Final Written Warning for not meeting the acceptable standards for Call Compliance. 

A recent audit ofSalesforce record https://na72.salesforce.com/00I IH0000INpZEp has shown a Compliance score of80%. 

A recent audit of Sales force record https://na72.salesforce.com/003 l H0000 I nStay has shown a Compliance score of 80%. At 7:27, 

you say FS includes "any gifts, any loans" etc. At I :30:00 you tell the client that there is no negative effect on their credit. 

Description of Policy Violation 

Attach additional pages if necessary 

The Account Specialist role is required to maintain full compliance per the established Call Compliance matrix. 

BAD #16 - Family Size definition not read to consumer word for word. 

BAD #7 - Providing false / untrue legal. tax or credit advice. 

Corrective Action 

Attach add/Ilona/ pages ,fneceMOry 

Dischar e. 

I 

Employee Comments 

A11ach addilionol pages if necessary 

I 

Employee signature: _Q)....,._-"'-..,.ClM-~-=-.... f2--4,,,_~~"'-"-....___,,.,.~,.__,,_ ___ ________ Date: 

Manager signature: ________________ ____________ Date: _______ _ 

Witness signature: ____________________________ Date: _____ __ _ 

original to Human Resources; copy to employee 

Dirc,pfuwy Act,on Form 

Crated 11/16 

Rovaewod 11116 

Rovisod 11116 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 4 of 18
)BNJMUPO "UUBDINFOU "  

Performance Improvement Plan 

/ Employee Name: Dan Hamilton 

Supervisor: Taylor Parrott 

Date: July 24, 2017 

Subject: 

Performance Improvement Plan 

During the past 2 weeks, it has become evident to me that you have not been performing your assigned work in 

accordance with what is expected of an Account Specialist. . You are being placed on a written improvement plan. For the next 14 days, July 24, 2017 - August 6, 12017 

your work will be closely monitored by your leadership team. You must demonstrate immediate improvement 

in the following areas: 

Closing % equal to or greater than 16% 

We will review your progress on each of the above items requiring improvement regularly. We trust that in so 

doing, we can guide you in becoming a contributing employee of AmeriTech Financial. 

Improvement must occur immediately and must be maintained. If any portion of this improvement plan is 

violated at any time during the specified timeframe, disciplinary action to include separation from the company 

may occur. A decrease in performance after successfully completing the improvement plan may result in being 

dismissed from AmeriTech Financial without the issuance of another warning or improvement plan. 

As always, the Open Door Policy is available for you to discuss any concerns. 

Your signature acknowledges this discussion. It does not indicate agreement or disagreement with this plan. 

Employee Signature Date 

Performance Improvement Plan Template 

Created ll/16 

Reviewed 11/16 

Revised ll/16 

-------~ - - - ----

. 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 5 of 18
)BNJMUPO "UUBDINFOU "  

Agent Name: ___________________ _ Date: _ _______ _ 

Client Name: ____________________ _ 

Read the introduction to the script- Inform the client that we are a document preparation company. 

We are NOT the government but this program is through the department of education. 

Explain the recertification process. Meaning we re-certify and maintain the file every year for the 

full 10, 20 or 25 years. 

Read the FULL federal definition of family size. 

Have client write down the T-box and disclose the fees involved. 

If the client is PSLF- disclose that they must work a minimum of 30 hours per week for the full 10 

years to qualify. 

Inform to the client hat we collect the first months IBR/ICR payment but they are responsible for 

paying the servicer starting on month two. They will receive correspondence from the servicer 

stating the dollar amount. 

Follow the proper steps for AGI. 1- studentloans.gov 2- picture of tax return or paystub 3- stated 

income 

Read the script while reviewing the agreement with the client. 

Explain to the client that we have a dedicated escrow account with "global client solutions". No 

money is collected out of the account until the services are performed. 

Fully explain what the FEBCP is. 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 6 of 18
)BNJMUPO "UUBDINFOU "  

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 7 of 18
States We Do Not Do Business In 

NH New Hampshire 

CT Connecticut 

CO Colorado 

ME Maine 

GA Georgia 

SC South Carolina 

NC North Carolina 

WI Wisconsin 

KS Kansas 

WV West Virgina 

ID Idaho 

WA Washington 

IL Illinois 

OR Oregon 

VT Vermont 

States We Do Referral Business in ONLY 

IA Iowa 

DE Delaware 

MN Minnesota 

ND North Dakota 

RI Rhode Island 

MS Missouri 

NJ New Jersey 

OH Ohio 

PA~ c_~1 ~x· 

0 h « r>·q L, ro ~ 

Hamilton Attachment A - 7 -j 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 8 of 18
Compliance Enrollment Call Audit 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Pag

Agent name: Dan Hamilton Date of Call: 

Manager: Time of call: 

Date/Time of Audit: 10/24/17 8:10am Call 2 

Consumer name: Call 3 

Compliance officer: Wren Nicholson Call4 

Rev.9/11/17 

10/23/2017 

10:39am 

I Tlmestamp Process Compliance (Score out of 5) 

:40 1. Introduction Script 5 Reads script 

7:27 2. Family Size 0 Not on script 

18:09 3. T-Box 5 Reads script 

28:05/1:25:23 4. PSLF 5 Reads script 

1:24:51 5. Renewal 5 Reads script 

2:20:22 6. Servicer Business Practices 5 Reads script 

1:16:35/2:21:07 7. Terms & Conditions 5 Reads script 

1:24:13 8. Customer Service 5 Reads script 

4:58/1:09:31 9. AGI (If Stated) 5 Read off paystu b 

1:29:45/1:59:18/ 

10. Payment Breakdown 0 Does not break down 

2:09:22 enrollment 

l ~nllh.lmc 

Timestamp Process # Notes 0S.!1t;. 50 etcaama Sc2t.c: 

c. 80% 

7:27 Bad 16 Says FS includes 'any gifts, any loans' etc f~~ -

Agent Signature: 

Hamilton Attachment A - 8 

J 

e 9 of 18
10/25/2017 Compliance Enrollment Call Audit Rev. 9/11/17 

I Timestamp Process Compliance (Score out of S) 

1:00 1. Introduction Script 5 

7:45 2. Family Size 5 

21:55 3. T-Box 5 

1:35:15 4 . PSLF 5 

1:34:05 5. Renewal 5 

1:36:20 6. Servicer Business Practices 5 

0 Rep did not read the Terms & 

7. Terms & Conditions Conditions. 

1:33:25 8. Customer Service 5 

5:40, 1:32:40 9. AGI (If Stated) 5 

Rep did not disclose the one 

1:42:40 10. Payment Breakdown 0 

"T_,,_,...,,.._ time enrollment fee. 

-

Timestamp Process# Notes Outs,/;, 50 ,,,_., Smr«: 80% 

Agent name: Dan Hamilton 

Manager: Dan Henry 

Date/Time of Audit : 10/ 25/ 2017 @ 17:35 

Consumer name: 

Compliance officer: Matt Stone 

Call Recording location: Call Uploaded to Google Drive 

Agent Signature: 

Date of Call: 10/ 25/2017 

Time of Call: 9:22 

Call 2 

Call 3 

Call4 

Hamilton Attachment A - 9 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 10 of 18
)BNJMUPO "UUBDINFOU "  

Account Specialist Bonus Related Data: September 25th- 30th 2017 

Rep Name: Dao Hamilton 

Manager: Timothy Arquilla 

Branch: EDH 

Hours Worked: 39.7 

Hours Scheduled: 40 

Hours/Work Qualifier %: 99% 

Tardys: 0 

Tardy Bonus %: 100% 

Litmos Completed: Yes Compliance Audit (# <100%): 0 

Compliance Bonus %: 100% 

Utilization Time (Ready Call & VM, On 

Call): 31.23 

Utilization %: 79% 

% COO I Inbound Calls: 75% 

Ready VM Time: 0.00 

%Ready VM: 0.0% 

Total Unit Values: 3.5 

Utilization Override: No 

All Bonus Qualifications Met?: No 

Base Bonus: $0.00 

Bonus Factor (Closing% x Cancel% x Tardy% x Compliance%):% 

Referral Bonus: $0.00 

Net Bonus: $0.00 

Rolled Calls: 1 

Rolled Call%: 4.2% 

# Calls: 22 

# Contracts: 3 

**Closing %: 13.6% 

Closing % Bonus: 90% 

# Cancels: 1 

Cancel%: 33.3% 

Cancel Bonus %: 0% 

**2nd Voice Tier Candidate: No 

2nd Voice Prior-Results: 31.8181 81818 

Account Specialist signature: 

ales Manager signature: 

8)04-'v /J/~ 

S

Date: 

Date: 

/D - y-- ~ 17 

.. 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 11 of 18
)BNJMUPO "UUBDINFOU "  

Account Specialist Bonus Related Data: October 2nd - 7th 2017 

Rep Name: Dan Hamilton 

Manager: Timothy Arquilla 

Branch: EDH 

Hours ~WQrked: 40.0 

Hours Scheduled: 40 

Hours/Work Qualifier%: 100% 

Tardys: 0 

Tardy Bonus %: 100% 

\ Litmos Completed: Yes .,.,. 

Compliance Audit(# <100%): 1 

Compliance Bonus %: 90% 

Utilization Time (Ready Call & VM, On 

Call): 32.46 

Utilization%: 81% 

% COO I Inbound Calls: 74% 

Ready VM Time: 0.00 

%Ready VM: 0.0% 

Total Unit Values: 3.25 

UtiHzation Override: No 

All Bonus Qualifications Met?: No 

Base Bonus: $0.00 

Bonus Factor (Closing% x Cancel% x Tardy% x Compliance%): % 

Referral Bonus: $0.00 

Net Bonus: $0.00 

Rolled Calls: 0 

Rolled Call %: 0.0% 

# Calls: 21 

# Contracts: 3 

**Closing%: 14.3% 

Closing % Bonus: 90% 

# Cancels: 0 

Cancel %: 0.0% 

Cancel Bonus %: 100% 

**2nd Voice Tier Candidate: Yes 

2nd Voice Prior - Results: 

~ r31_ ,,,__ 

Account Specialist signature: \

Sales Manager signature: 

f;}!;,-J (l,i_ /~ Date: / D ~/G -/ 1 

Date: 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 12 of 18
)BNJMUPO "UUBDINFOU "  

A. Attendance Qualifier: The AS must-work a minimum of 80% of the time scheduled per pay period 

to qualify for a bonus. You're "normally" scheduled for 80 hours every 2 weeks, 80% is 64 hours. The 

10% you can miss is equal to 2 days. Out of 10 days, you can miss 2 days. 

B. Timekeepin& Policies Qualifier: 

1 Tardy 10% deduction 

2 Tardies 35% deduction 

3 Tardies 50% deduction 

You have a 6 minute window to clock in/out. IE; if you're scheduled at 8am and you clock in at 

8:06am, you're on time, at 8:07am you're tardy. Same qualifications go for breaks. Set alarms on y

cell phone to stay on schedule. Know how long it takes you to get to work and plan appropriately. 

C. Utilization Qualifier - 75 % : 

FIVE9 DISPOSITIONS: 

- To be used the majority of the day 

- To be used the majority of the day 

-NEVER USE 

-NEVER USE 

-NEVER USE 

-NEVER USE 

- NEVER USE 

In Verification - SM will watch deal, AS goes GREEN 

Training - Used for meetings - keep to a minimum. 

Break - Used for 20 mins per day 

Lunch - Used for 1 hour per day 

D. Rolled Call Qualifier- 5%: 

NEVER ROLL CALLS, PERIOD. THERE IS NO EXCUSE FOR THIS. 

E. Compliance Qualifier - 80% movine toward 100%: 

80% -100%- No deduction 

70.00%- 79.99% - 10% deduction 

60.00% - 69.99% - 50% deduction 

our 

F. Minimum Performance Qualifier; 10 points for the 2 week pay period. 

G. Continuin& Education Qualifier; Do your Litmos tests when you get them. 

H. Closin& Percentaee (%) Multiplier: 

00.00% - 19.99% Closing Percentage= 90% 

20.00% - 24.99% Closing Percentage= 100% 

25.00%- 29.99% Closing Percentage= 110% 

30.00%- 34.99% Closing Percentage= 115% 

35.00% + Closing Percentage= 120% 

I. Cancellation Percentaae Factor(%) 

0 - 20% cancels = 100% Bonus 

20.01 % - 25.00% cancels = 50% Bonus 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 13 of 18
)BNJMUPO "UUBDINFOU "  

Enrollment Compliance Audit Score Matrix 

~ffi~t~ri -::- · - - , ·.--~~t rit11.filo~: ~·; ~--•.- - _ -- ·_--:, -~c,i"jiJ~p<iffi~:·:;J":-s. ~,m; 

Read Intro Script 

Read intro script exactly as provided. Did 

not answer client's questions with 

compliant/provided responses. 

Read intro script exactly a.s provided. Answered 

client's questions with compliant/provided 

responses. 

Read Family Size Definition, 

Followed FS Process 

Read Family Size as scripted. Gave a 

personal example, but not approved. Got 

the client's FS number. 'Helped' client 

increase FS number. 

Read Family Size as scripted. Gave an approved 

personal example. Got the client's FS number. Did 

not coach client to increase family size. 

T-8ox: Had client write 

down figures 

Has client write down T-Box and figures, but 

doesn't follow saipt for explanation. 

Has client write down all T-box figures, and follows 

script for explanation. In full control of the T-Box 

portion of the conversation. 

Followed AGI 

Determination process 

Did not try and get AGI from FSA/IRS. 

Skipped to 'Statement of Income' steps 

instead. 

Got AGI through FSA/IRS. If not, got client to 

provide tax returns (image attached to file). If not, 

got info from paystubs. If not, got stated 

information. Correctly selected Income Proof type 

in SF. 

(If PSlF) Disclosed must 

work 30+ hours, and job 

challge could affect 

program 

X Disclosed must work 3o+ hours, and Job change 

could affect program. 

Explained Annual Renewal 

Process 

Disclosed that client will need to recertify 

for their program each year. Did not get 

client's acknowledgement that they 

understand. 

Disclosed that client will need to recertify for their 

program each year. Got client's acknowledgement 

that they understand. 

Followed provided script and explained eact Followed provided script and explained each page page of the contract. Did not Complete Contract Review of the contract. Correctly, and compliantly, correctly/compliantly, responsed to client 

responsed to any client questions. questions. 

Disclosed that in pr01ram, Ensures that client understands that they Ensures that client understands that they need to client needs to make need to make payments directly to servicer. 

make payments directly to servicer. Got client's payments directly to Did not get client's acknowledgement that 

acknowledgement that they understand. Servicer they understand. 

Followed Referral Script. Sent Confirmation Followed Referral Script. Sent Confirmation Email. Referral Program Email. Got T&C Box Checked. Got T&C Box Checked. Client Logged in and Shared. 

Followed Servicer Business Practices 

Followed Servicer Business Practices Explaination - Servicer Buslenss Practices Explaination - Supplimental Script. Did not ·supplimental Script. Got client's acknowledgement Rebuttal -Explanation get client's acknowledgement that they that they understand. understand. 

Effective 10/3/2016 Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 14 of 18
)BNJMUPO "UUBDINFOU "  

tification Exam Questions (25) 

1.Student Loan Consolidations 

r J have no restictions on eligibilty 

"1 allows borrowers to combine all of their federal student loans into one new loan with one lender 

need state approval 

C,1 can only accept 3 existing loans 

2. With the "Standard Repayment Plan" 

·- The borrower needs a full time job 

A Visa or Mastercard 

• the payment is calculated based on the size of the loan and the term of the loan 

- A Spouse 

3. With the "Standard Repayment Plan" the borrower 

..__, must be still in school 

CJ cannot owe money to more than 2 lending institutions 

'"J is required to not ever change marital information before repayment 

1 ~ will pay less interest than they will under the graduated payment plan 

4. Student Loan Repayment Options include 

• Standard Repayment 

Graduated Repaymen 

- Income Contingent Repayment 

- Income Based Repayment 

._fJ All of the above 

5. With a "Graduated Repayment Plan" 

-t> payments start lower and then increase later in repayment 

....J interest is doubled 

.._1 results in repossession of books 

·, causes bad debt. placed for collection 

6. Eligibility is determined by the Department of Education . 

. J True 

C False 

7. "Income Sensitive Repayment" Plans must at least cover the interest that accrues each month. 

\Ji True 

u False 

8. With a "Pay As You Earn" Plan 

----------- --------

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 15 of 18
)BNJMUPO "UUBDINFOU "  

-

1 - you will, ~'-~ eaure the client reports only estimated Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 16 of 18 income information 

~ _, you will calculate your client's reduced monthly payments by using their gross income and family size " 

., forgiveness is granted after 30 years of qualifying payments 

The lender must report information to the state government 

9. With an "Income Based Repayment" Plan 

Payment is based on your client's adjusted gross income 

C Payment may be less than the interest that accrues each month 

Payments are recalculated annually 

f All of the Above 

10. With an "Income Contingent Repaymenr Plan 

4 It requires your client to provide documentation annually 

Rules are there to protect the previous lenders 

Guidelines are established for Collection Agencies 

' Guidelines set out the rules for applying for credit by a borrower 

11 . The "Income Sensitive Repayment Plan•. 

•~ The payment must at least cover the interest that accrues each month 

.._, Only applies to married borrowers 

.J Only applies to single borrowers 

1""" Interest is not considered 

12. A benefit of Student Loan Consolidation is. 

Loans will have a fixed interest rate 

New payment will be lower 

Y( Client will have one convenient payment per month to one lender • 

All of the above 

13. Eligible "FFEL" Loans included in the "Income Sensitive Repayment" Plan include. 

Stafford Subsidized 

Stafford Un-subsidized 

Student PLUS 

, Parent PLUS 

• All of the above 

14. The "Income Contingent Repayment" Plan calculates the borrowers payment two different ways, and then gives 

them the lower of the two payments. 

True 

• False 

15. Some disadvantages of Student Loan Consolidation are. 

Borrowers may be making payments for a longer time 

J For older loans, they may lose some deferment option 

t l May increase the amount of interest they pay over the long term 

--.
)BNJMUPO "UUBDINFOU "  

u All Qf the-above--f 

,.::.---- Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 17 of 18

16. Eligible loans under the "Standard Repayment Plan" include. 

Stafford Subsidized 

Stafford Unsubsidized 

Student PLUS 

f' All of the above 

17. FFEL loans are Federal Family Education Loans 

1

! 1 True 

C False 

18.With the "Pay As You Earn" Plan. 

Your client must not have a partial financial hardship 

' If they're married must not file a joint tax return 

, Repayment period is up to 30 years 

•• None of the above 

19. The Student Loan Consolidation Process includes. 

0 Determining your client's current financial situation 

C.i Identifying which program maximizes your client's savings 

CJ Submition to the Department of Education 

i! All of the above 

20. The Consumer Financial Protection Bureau estimates that one-fourth of the American workforce may be eligible for 

Student Loan repayment or loan-forgiveness programs. 

·• True 

False 

21 . With "Pay As You Earn" Repayment Plans. 

(./ Payments are usually 10% of their discretionary income 

l.; It is only available for recent borrowers. If your client took out their first federal loan on or after October 1, 2007 

C They make payments for 20 years, then any remaining balance is forgiven 

• All of the above 

22. "Income Sensitive Repayment Plans" are an alternative to "Income Contingent Repaymenr Plans 

I True 

' False 

23. With "Loan Rehabilitation". 

(J The payments must be "rea.sonable and affordable" based on total financial circumstances 

0 Payments must be voluntary 

0 A borrower cannot rehabilitate a loan that has been reduced to a judgment 

i 1 All of the above 
)BNJMUPO "UUBDINFOU "  

24. A guaranty agr.....----:y. 

Case 4:18-cv-00806-SBA Document 34-1 Filed 03/02/18 Page 18 of 18

Is a consumer collection agency 

---.. Guarantees that a consolidation loan is approved 

~ Submits the application to the Department of Education 

• Is a state agency or a private, nonprofit organization that administers FFEL Program loans 

25. A lender may grant a "forbearance" if a borrower is willing but unable to make loan payments. 

-f True 

False 

Important: I certify that I am the person whose name is included on this examination 

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