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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 CHELSEA 

CARBONNEAU IN SUPPORT OF 

FEDERAL TRADE COMMISSION’S 

MOTION FOR PRELIMINARY 

INJUNCTION

Case 4:18-cv-00806-SBA Document 27 Filed 03/02/18 Page 1 of 5

DECLARATION OF CHELSEA CARBONNEAU IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

 4:18-CV-00806-SBA
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DECLARATION OF CHELSEA CARBONNEAU

1. My name is Chelsea Carbonneau. I am a surgical nurse and a graduate student,

living in Land O’ Lakes, Florida. The following statements are within my personal knowledge 

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

2. Sometime around July 2015, I received a mailer from American Financial

Benefits Center (“AFBC”). In it, AFBC asserted it was affiliated with the U.S. Department of 

Education. The mailer also mentioned that I might qualify for a ten-year loan forgiveness 

program. 

3. On or about August 17, 2015, I called AFBC and spoke with an AFBC agent

(“agent”). The agent stated that I might qualify for a ten-year loan forgiveness program and for a 

lower monthly payment during those ten years. I was initially skeptical, so I ran a quick Google 

search while on the phone with the agent. I came across AFBC’s website and saw that AFBC 

was accredited by the Better Business Bureau. Further, the agent reiterated that AFBC was 

affiliated with the Department of Education. I felt assured that AFBC was a legitimate company.

4. I provided my personal information to the agent, including my social security

number. The agent asked about my annual income and the number of dependents I had. I told 

the agent I did not have any dependents. But, the agent said AFBC calculated dependents 

differently. According to him, a dependent could include family and close friends if I provided 

them with financial support—even as little as $10—or I had given them a gift. Based on the 

information I provided him, the agent informed me that I actually had nine dependents. He 

seemed knowledgeable about how to calculate the number of dependents, so I did not question 

his conclusion that I had nine dependents. 

5. The agent told me that I qualified for the loan forgiveness program. Under the

program, my new monthly payments would be $149.00 per month for thirteen months and 

$99.00 per month thereafter. The agent informed me that AFBC would automatically draft the 

amount from my bank account and forward the payment to my loan servicer. The agent also 

informed me that AFBC would assume responsibility for any communications with my loan 

Case 4:18-cv-00806-SBA Document 27 Filed 03/02/18 Page 2 of 5
Carbonneau Declaration - Page 2 

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servicer. The agent did not tell me about any document preparation or service fees. I understood 

that the monthly drafts were payments to my loan servicer and nothing else. 

6. I agreed to work with AFBC to lower my monthly loan payments, and I did not 

reach out to AFBC for any other purpose. The agent prepared all my paperwork and I signed 

everything via an electronic program called DocuSign while on the phone with the agent. 

Attached as Carbonneau Attachment A is a true and correct copy of my agreement with AFBC 

with my personal information redacted. I provided AFBC with my loan servicer username and 

login information, and the agent instructed me to forward any future communications from my 

loan servicer to AFBC, including any notices regarding missed payments. 

7. On or about September 16, 2015, AFBC began automatically drafting $149.00 

from my bank account. On or about October 18, 2016, AFBC began automatically drafting 

$99.00 from my bank account. 

8. In the fall of 2016, I started a graduate program. On or about October 4, 2016, I 

called AFBC to ask whether I qualified for deferment since I had enrolled in school. The agent 

told me they would contact my loan servicer on my behalf to see if I qualified for deferment. I 

did not hear back from AFBC regarding this matter, but AFBC continued to draft monthly 

payments from my bank account. I assumed I did not qualify for deferment and did not take 

further action. 

9. On or about May 25, 2017, my loan servicer notified me that I had to renew my 

income-based repayment plan (“IBR”). I called my loan servicer and informed their employee 

(“employee”) that AFBC was handling my loan. I told the employee that my loan servicer 

should contact AFBC directly since they were responsible for all my communications. The 

employee said she did not know who AFBC was. I told her that I had worked with AFBC to 

lower my monthly payments and enroll in a loan forgiveness program, and that I was making 

monthly payments through AFBC. The employee informed me that my loans had been placed in 

deferment and that they had received no payments since about September 2015. This was news 

to me because the agent that enrolled me in AFBC’s program assured me AFBC would forward 

my monthly payments to my loan servicer. 

Case 4:18-cv-00806-SBA Document 27 Filed 03/02/18 Page 3 of 5
Carbonneau Declaration - Page 3 

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10. After speaking with her supervisor, the employee told me that AFBC was a 

middleman and was likely charging fees to perform unneeded tasks. She instructed me to freeze 

my bank accounts, file a report with the credit agencies and the police department, and file a 

complaint with the U.S. Federal Trade Commission (“FTC”). 

11. On or about May 26, 2017, I filed a complaint with the FTC. That same day, I 

also emailed and called AFBC to ask why my loan was in deferment and why my loan servicer 

had not received any payments since about September 2015. Attached as Carbonneau 

Attachment B is a true and correct copy of my email to AFBC, dated May 26, 2017, with my 

personal information redacted. The agent said my loan was in deferment because I was in 

school, but that before then I had qualified for a $0 IBR. As such, since about September 2015, I 

did not have to make monthly payments to my loan servicer. The agent further said that AFBC’s

monthly drafts were for a service fee. This was the first time I had heard of a service fee. AFBC 

had repeatedly told me the monthly drafts were loan payments. 

12. I told the agent I no longer wanted AFBC’s services. But, the agent did not want 

to cancel my account. Instead, the agent made another sales pitch and said I could remain with 

AFBC and continue to enjoy their services, but waive the $99.00 service fee while I was enrolled 

in school. But, the agent did not clearly or adequately describe what services AFBC would 

provide while I was in school or whether I would have a separate payment to my loan servicer in 

addition to the $99.00 service fee. Each time I told the agent that I no longer wanted AFBC’s 

services, he gave me a new pitch. At one point, the agent claimed that AFBC actually forwarded 

all the money they collected as fees to my loan servicer at the end of the ten-year period. It 

became clear to me that AFBC was only interested in collecting fees from me, not in helping 

reduce the burdens caused by my student loan debt. 

/ / /

/ / /

/ / /

/ / /

/ / /

Case 4:18-cv-00806-SBA Document 27 Filed 03/02/18 Page 4 of 5
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13. From September 2015 to May 2017, AFBC drafted $2,580 from my bank account 

for their so-called document preparation and service fees. Though I successfully canceled my 

enrollment with AFBC, I was unable to s~cure a refund. Instead, AFBC promised to issue a 

check for that amount to my loan servicer. Almost two months have passed since I requested a 

refund and AFBC has yet to refund any portion of my money. 

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

on July3\ , 2017 in Land O'Lakes, Florida. //'"J <=~Y-/ . -/.) . 

(_~ __ / ? ·;~-~c0-> 

/ Chelsea Carb

Declarant 

~ 

Carbonneau Declaration - Page 4 

Case 4:18-cv-00806-SBA Document 27 Filed 03/02/18 Page 5 of 5
Carbonneau Attachment A

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 1 of 13
, FBC -------·-------- American Financia l Benefits Center 

311 Professional Center Drive Suite 200

Rohnert Park, CA  94928

 

 

 Telephone: (800) 488-1490 

Fax: (707) 222-5200 

Website: www.afbcenter.com 

Documents: income.doc@afbcenter.com 

E-mail: info@afbcenter.com 

 

 

 

Name: Chelsea Carbonneau Client #: 

Address: Home Phone: 

City, State, Zip • Other Phone: 

Date: 8/17/2015 

 

Thank you for contacting American Financial Benefits Center. Based on the information you have 

provided to our company, we believe that you may qualify for one or more student loan assistance 

programs offered by the U.S. Department of Education. American Financial Benefits Center (“AFBC”) 

is a privately owned company that helps consumers like you identify programs that may be suitable for 

their situation, gather their relevant application documents, then assist them by preparing those documents 

for review and submission. AFBC also offers its own great programs to further assist with you with your 

financial situation. To begin, we need the following information from you: 

1. Please carefully read the enclosed Agreement, and make sure that all pages are signed and 

dated where indicated. 

2. Please provide your National Student Loan Data System federal student identification aid 

(“FSA ID”) login information, and / or your most current student loan servicer account 

statement(s). 

3. Please provide a copy of a voided check, along with the attached ACH Authorization Forms, 

signed by the account holder who is remitting the program payment. 

4. After you have faxed your documents, or provided your FSA ID login, please contact AFBC 

at 1-800-488-1490 ext. 0 and speak to a Client Services Representative to verify all 

documentation has been received. You may also email your documentation to: 

income.doc@afbcenter.com

5. Be sure to retain a copy of all documents for your records. 

Due to the importance of this material and so we may start working for you as soon as possible, return 

these documents and provide your FSA ID login to American Financial Benefits Center via secure fax, 

email, or mail to 311 Professional Center Drive #200, Rohnert Park, CA 94928, as soon as possible. 

If you have any questions when reviewing the attached documents, please feel free to contact your 

American Financial Benefits Center Client Services Representative at 1-800-488-1490. 

Client Signature:_________________________________________ Date:______ 8/17/2015 ______________ 

DocuSign Envelope ID: 

l;

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DocuSigned by: 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 2 of 13
DocuSign Envelope ID: 

American Financial Benefits Center Document Preparation and Service Agreement ID:- 2 Sedion 1: Client Information C !Agreement Date: lient E7I77 0IS I

Client First Name: Che 1 sea Client Last Name: Carbonneau 

Client Middle Initial: Fonner Last Name 

Street Address: City, State, Zip: • 

Client Email: Client Phone: 

Set:tion 2: Client's Estimated Summary of Current Federal Student Loans 

The basis of this summary is derived from the input provided by the client. 

Estimated Total Federal Loan Balance: $ Loan Status (cWTent, delinquent, default, consolidated): 

Approximate CWTent Monthly Payment: $ 168 .00 Federal Loan Types (Single, Multi): -

Estimated New Loan Payment: $ 6. 00 New Loan Payment Validation Tenn:-

Estimated Payment Adjusted After (Months): CWTent Loan Servicer(s): 

Set:tion 3: Required Consolidation Application Information 

ClientSSN: - -• - Client DOB (MM-DD-YYYY): -

DL / ID Number & State: • FSA ID & Code: 

Employer Name

---I 

: Occupation: -

Employer Street Address: 

-

Employer City, State, Zip: • 

Employer Phone: Client Stated Family Size: 9 

Client Marital Status: Client Stated Tax Filing Status: Single 

-

CWTent Annual Income: $ Form of Documented Income Submitted: 

Spouse First Name: Spouse Last Name: 

SpouseSSN: Spouse DOB: 

Spouse Employer Name: Spouse Work Phone: 

Spouse Annual Income: $ PSLF Candidate (:{es/ No): Yes 

References: 2 Persons with different addresses, PO Boxes ue NOT acceptable, not residing in the same home (for example, a spouse) or anyone living outside the U.S. 

Reference 1 Full Name: Permanent Address: 

Reference 1 Phone: Relationship to Client: 

Reference 2 Full Name: 

- Permanent Address: 

Reference 2 Phone: Relationship to Client: 

Set:tion 4: AFBC Document Preparation and Service Agreement Program Payment 

American Financial Benefits Center Payment/Fees ue sepuate of loan costs and /or payments made by Client 

AFBC Program Payment/Fee Amount: $ 600 .00 AFBC Program Payment Amount: $ 50 . 00 

First Program Payment Date: 2015-10-16 Payment Term (months): 12 

Set:tion 5: Client Payment Information 

Bank Name: Account Number: 

Account Type (Checking / Savings): Routing Number: 

Notes: 

This Service Agreement is made and entered into, the date of signing, by and between American Financial 

Benefits Center ("AFBC"), and Client, as stated in Section 1, hereinafter refened to as ("Client") residing at 

address as stated in Section 1. Subject to, and conditioned upon, the following for the Client Student Loan 

Document Preparation and Service Agreement. All information above is provided by the Client. 

Client Signature~4--

F2cA01s 1c 12a422 ... 

Date: 8/17/2015 

Carbonneau Attachment A - 2 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 3 of 13
American Financial Benefits Center 

Privacy Policy

American Financial Benefits Center (hereinafter "Company") is dedicated to protecting your privacy and 

providing you with the highest level of service. This Policy explains what Company does to keep 

information about you private and secure. This Policy covers only information that you provide to 

Company or that it obtains about you from companies that you have chosen to do business with. Please 

read this Policy carefully and contact us if you have any questions. 

Personal Information We Collect

The personal information we collect about you comes from the following sources: 

 Information we receive from you, such as your name, address, and telephone number, or 

other information that you provide to us over the phone or in documents or applications, 

 Information about your transactions, such as your account balances with your creditors, 

payment histories, account activity, and all other information that may be contained in your 

credit card statements or other reports relating to your debt, and 

 Information we receive from consumer reporting agencies and other sources, such as your 

credit bureau reports, collection agency reports or other communications, and other 

information relating to your payment histories, creditworthiness, annual income, or ability to 

satisfy your obligations. 

We reserve the right to, and will, sell or transfer your personal information to third parties for any purpose 

in our sole discretion. We prohibit the sale or transfer of personal information to non-affiliated entities for 

their use without giving you the opportunity to opt-out. We may disclose such information in order to 

effect or carry out any transaction that you have requested of us or as necessary to complete our 

contractual obligations with you. We may also share your information with service providers that 

perform business operations for us, companies that act on our behalf to market our services, or others only 

as permitted or required by law, such as to protect against fraud or in response to a subpoena. We may 

also share or transfer our information in the event we transfer or sell your account or our business assets 

to another provider. 

By carrying out those services, we may disclose your information, as we see fit and as permitted by law, 

to your creditors, credit card companies, collection agencies, banks, and other entities and individuals 

specifically necessary to effect, administer and perform our services. 

Your Choices / Opt-out 

We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for 

certain purposes. By providing information to Company you are consenting to the collection, use and 

disclosure of such personal information in the manner described in this privacy policy. We provide you 

the opportunity to withdraw your consent when such information is collected. 

Such consent may be withdrawn by calling the telephone number provided below or may be done in 

writing/email and sent to our customer service department at the following physical address or email 

address: 

DocuSign Envelope ID: 

Carbonneau Attachment A - 3

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 4 of 13
American Financial Benefits Center 

311 Professional Center Drive Suite #200 

Rohnert Park, CA 94928 

If by email: info@afbcenter.com 

If by phone: 1-800-488-1490 Extension: 0 

How We Protect Your Information

We train our employees to protect all customer information. We maintain physical, electronic and 

procedural controls that comply with government standards. We authorize our employees, agents and 

contractors to get information about you only when they need it to do their work with us. You can help to 

maintain the security of your online transactions by not sharing your personal information or password 

with anyone. Remember, no method of transmission over the Internet, or method of electronic storage, is 

100% secure. 

This Policy applies to current and former customers. If you have any questions, please contact American 

Financial Benefits Center at 311 Professional Center Drive Suite 200, Rohnert Park, CA 94928 

Client Signature:_________________________________________ Date:______ 8/17/2015 

______________ 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

DocuSign Envelope ID: 

Carbonneau Attachment A - 4

l;

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DocuSigned by: 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 5 of 13
National Student Loan Data System Access 

Purpose: As part of the federal student loan consolidation application process American Financial 

Benefits Center requests access to my student loan Information from government databases. 

Reason: To obtain accurate information relating to my student loans for such application purposes. 

What I Need to Do: As the debtor who is responsible for these loans, you need to create an online user 

name and password. The U.S. Department of Education recommends that you keep your user name and 

password secure to prevent any fraudulent use. The purposes of the user name and password is to permit 

you access to various government websites and allow you to sign electronically on any applications. 

There are other purposes as well, so please keep your information secure. 

Why We Request Your User Name and Password: With your permission and instruction, we need to 

carry out the application services that you have requested of us. We will keep your user name and 

password secure, and we will never share it with third parties. We need this information to complete our 

contracted services, including gathering the relevant, pending loan information pertaining to you, and 

completing the applications that you qualify for. While the government does not encourage such sharing 

because they want to prevent fraud and abuse, with your consent and instruction we are permitted to 

review and assist you with the services you have requested of us. 

Authorization: As part of the federal student loan assistance application process, it will be necessary for 

American Financial Benefits Center (hereinafter “Company”) to access your student loan information 

within the student loan data system located online at www.nslds.ed.gov.

The data system contains a complete list of your federal education loans, along with current estimated 

balances and servicer details, information that is required to complete your application(s). 

By enrolling in the company program, you are agreeing to allow company and its authorized agents to 

access your profile and all the data contained within that profile. In order to allow this access, you may 

need to provide company with your user name and password. 

Please note that all information that company obtains from the student loan data system will be used 

expressly for the purposes of confirming information and assisting in the preparation of applications. 

Acknowledgment:

I, _____________________________, hereby acknowledge that I have read, understood, and agree to the 

above statements regarding access to my data system profile. I understand that any information received 

or accessed will be used solely for the purposes as stated above. Upon completion of company services, I 

understand that I should log back in and change my user name and password so that at all times I maintain 

control over my account. 

By signing this acknowledgment, I instruct, agree, and expressly permit company to access the student 

loan data system and my personal profile as explained above. 

 

Client Signature:_________________________________________ Date:____________________ 

DocuSign Envelope ID: 

Chelsea Carbonneau

8/17/2015 

Carbonneau Attachment A - 5

l;

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DocuSigned by: 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 6 of 13
Required Documentation and Instructions 

*(All Forms Located in “Document Package” PDF) 

 Please return the following documents to AFBC as soon as possible. 

 Failure to return documents in a timely manner will result in processing delays. 

 ONLY sign the provided forms – do not date forms unless otherwise instructed. 

 Please do not fill out any additional information on the signature forms. 

Return the following documents to AFBC within 2 weeks: 

1) Income Based (IBR) Federal Form 

a. Your signature is required on Page 2. DO NOT DATE 

2) General Forbearance Request Federal Form

a. Your signature is required on bottom of page 2. DO NOT DATE

3) Paystubs – For the most recent month 

a. Paystub date range needs to cover at least 30 days of pay, and must be within the 

most recent 30 days 

4) 1040 Tax Return

a. For most recent filed year - please send a FULL copy of your return. 

Return the following documents to AFBC within 6 months: 

1) Employment Certification for Public Service Loan Forgiveness (PSLF) Federal Form 

a. This form only applies if you work for a non-profit 501(c)3 or government entity. 

i. Step 1: Provide this form to your HR department to complete. 

ii. Step 2: Your signature and date (date required for this special form) is required at 

the bottom of page 2. 

iii. Step 3: Return to AFBC. 

DocuSign Envelope ID: 

Carbonneau Attachment A - 6

--- American Financia•·--l Benefits Center 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 7 of 13
DocuSign Envelope ID: 

, ______ FBC ,.. _____ _ Americon Finonciol Benefils Cenler 

Instructions: How to Return Required Documents 

1) Option 1: Email (*Preferred* } 

a. Attach required documents and email to: 

Income.doc@atbcenter.com 

*Do not email documents to your Account Representative 

*Only email files in PDF format 

2) Option 2: FAX 

a. Fax securely to: 1-707-222-5200 

b. Alternative fax: 1-888-334-6281 

3) Option 3: Mail 

a. Mail a physical copy of your documents to: 

AFBC 

~ Documents 

311 Professional Center Dr. STE# 200 

Rohnert Park, CA 94928 

l;DocuSigned by: 

~ 4-

Carbonneau Attachment A - 7 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 8 of 13
DocuSign Envelope ID: Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 9 of 13 PUBLIC SERVICE LOAN FORGIVENESS (PSLF): 0MB No. 1845-0110 

Form Approved EMPLOYMENT CERTIFICATION FORM Exp. Date 12/31/2017 

William D. Ford Federal Direct Loan (Direct Loan) Program 

WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on any 

accompanying document is subject to penalties that may include fines, imprisonment, or both, under the U.S. Criminal 

Code and 20 U.S.C. 1097. 

SECTION 1: BORROWER IDENTIFICATION 

Please enter or correct the following information. 

D Check this box if any of your information has changed. 

SSN - -• -- Date of Birth 

Name chel sea Carbonneau 

Former Name (if any) 

Address ------------------

City, State, Zip Code 

Telephone - Primary 

Telephone -Alternate 

E -ma i I (optional) ---------------

------------------ SECTION 2: BORROWER AUTHORIZATIONS, UNDERTANDINGS, AND CERTIFICATIONS 

Before signing, carefully read the entire form. For more information about PSLF, visit StudentAid.gov/publicservice. 

I authorize: 

1. My employer or other entity having records about the employment that is the basis of my request to make 

information from those records available to the U.S. Department of Education (the Department) or its agents or 

contractors. 

2. The Department (and its agents or contractors) to contact me regarding my request or my loan(s), including 

repayment of my loan(s), at the telephone number that I provide on this form or any future number that I provide 

for my cellular telephone or other wireless device using automated telephone dialing equipment or artificial or 

prerecorded voice or text messages. 

I understand that: 

1. To qualify for PSLF, I must make 120 qualifying payments on my Direct Loan(s) while employed full-time by a 

qualifying employer or employers. Neither the 120 qualifying payments nor employment have to be consecutive. 

2. To qualify for PSLF, I must be employed fu ll-time by a qualifying employer or employers when I apply for PSLF and 

when my loan is forgiven. 

3. If I qualify for forgiveness, only the remaining balance on my Direct Loan(s) will be forgiven. 

4. By submitting this form, my student loan(s) held by t he Department will be transferred to Fedloan Servicing. 

5. The Department may request supplemental documentation substantiating my employment. 

6. The Department will notify me in writing or electronically of the number of qualifying payments I have made while 

employed full-time by a qualifying employer or employers and the remaining number of qualifying payment s I 

must make before I am eligible to apply for PSLF. 

7. The Department will notify me in writing or electronically if the form that I submit is incomplete, or if it 

determines that my employment or payments do not qualify for PSLF. The Department will explain the reason for 

the determination and the steps I need to take to correct the form or make qualifying payments. 

8. The Department will retain this certification form until I submit my application for forgiveness. 

I certify that all of the information I have provided on this form and in any accompanying document is true, complete, 

and correct to the best of my knowledge and belief. 

D Check this box if you cannot obtain certification from your employer because the organization is closed or because 

the organization has refused to certify your employment. The Department will follow up to assist you in getting 

documentation of your employment. Complete section 3, but do not complete Section 4. 

Borrower Signature ____________________ Date 

Page 1 of 6 Carbonneau Attachment A - 8 
DocuSign Envelope ID: 

Carbonneau Attachment A - 9

Borrower Name: Borrower SSN: ------------------

SECTION 3: EMPLOYMENT INFORMATION (TO BE COMPLETED BY THE BORROWER OR EMPLOYER) 

1. Employer Name: 

2. Federal Employer Identification Number (EIN): 

Your employer's EIN may be found on your Wage and 

Tax Statement (W-2). 

3. Employer Address: 

4. Employer Website (if any): 

5. Employment Begin Date: 

6. Employment End Date: 

OR 

D Still employed. 

7. Employment Status: D Full-Time D Part-Time 

8. Hours Per Week (Average): ---------

Include vacation, leave time, or any leave taken 

under the Family Medical Leave Act of 1993. If your 

employer is a 501(c)(3) or a not-for-profit 

organization, do not include any hours you spent on 

religious instruction, worship services, or 

proselytizing. 

9. Is your employer a governmental organization? 

A governmental organization is a Federal, State, local, 

or Tribal government organization, agency, or entity, 

a public child or family service agency, a Tribal 

college or university, or the Peace Corps or 

AmericCorps. 

D Yes - Skip to Section 4 

D No - Continue to Item 10 

10. Is your employer a tax-exempt organization under 

section 501(c)(3) of the Internal Revenue Code? 

D Yes - Skip to Section 4. 

D No - Continue to Item 11. 

11. Is your employer a not-for-profit organization? 

D Yes - Continue to Item 12. 

D No - Your employer does not qualify. 

12. Is your employer a partisan political organization? 

D Yes - Your employer does not qualify. 

D No - Continue to Item 13. 

13. Is your employer a labor union? 

D Yes - Your employer does not qualify. 

D No - Continue to Item 14. 

14. Does your employer provide any of the below 

services? 

D Yes - Select all the services your employer 

provides and then continue to Section 4. 

• D Emergency management 

• D Military service (see Section 6) 

• D Public safety 

• D Law enforcement (see Section 6) 

• D Public interest legal services (see Section 6) 

• D Early childhood education (see definition of 

"public service organization" in Section 6) 

• D Public service for individuals with disabilities 

• D Public service for the elderly 

• D Public health (see definition of "public 

service organization" in Section 6) 

• D Public education 

• D Public library services 

• D School library services 

• D Other school-based services 

D No - Your employer does not qualify. 

SECTION 4: EMPLOYER CERTIFICATION (TO BE COMPLETED BY THE EMPLOYER) 

15. D I certify that the information in Section 3 is true, complete, and correct to the best of my knowledge and belief 

and that I am an authorized official (see Section 6) of the organization named in Section 3. Complete Items 16-21. 

Note: If any of the information is crossed out or altered in Section 3, you must initial those changes. 

16. Authorized Official's Name: 19. Authorized Official's Phone: 

17. Authorized Official's Title: 20. Authorized Official's Email: 

18. Authorized Official's Signature: 21. Date: 

Page 2 of 6 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 10 of 13
DocuSign Envelope ID: 

Income-Based (IBR) / Pay As You Earn / Income-Contingent (ICR) Repayment Plan Request 0MB No. 1845-0102 

William D. Ford Federal Direct Loan (Direct Loan) Program I Federal Family Education Loan (FFEL) Program FOffll Appro,.,d 

Exp. Date 11-3M015 

Use this form to (1) request an available repayment plan based on your income, (2) provide the required information for the annual reevaluation .._ ____ ....., 

of your payment amount under one of these plans, or (3) request that your loan holder recalculate your monthly payment amount. 

IBR/PAYE/ICR WARNING: Any person who knowingly makes a false statement ot misrepresentation on lhis fonn or on any accompanying document is subject to penalties that may include mes, 

imprisonment, or both, under the U.S. Criminal Code and 20 U.S.C. 1097. 

I SECTION 1: BORROWER /DENT/FICA TION 

Please enter or correct the following information. 

D Check this box if any of your information 

SSN I• I I· l

Name Chel sea Carbon

•

has changed. 

I I· - I 

neau 

Address - --

City, State, Zip Code 

Telephone - Primary 

Telephone - Alternate --( ) - -••--------

E-mail Address (Optional) 

I SECTION 2: REPAYMENT PLAN REQUEST 

Before completing this form, carefully read the entire form, particularly Sections 7, 8, and 9. Type or print using dark ink. If you need help completing 

this form, contact your loan holder(s). Return the completed form and any required documentation to the address shown in Section 10. You may be 

able to complete your request online by visiting studentloans.gov. Information about repayment plans and calculators are available at studentaid.gov. 

Other repayment plans, such as extended or graduated, may be available and may offer a lower monthly payment amount. In addition, payment under the IBR, 

Pay As You Earn, or ICR plans may result in your paying more interest over time and may result in federal income tax liability on any loan amount that is forgiven 

under these plans. 

1. Please select the reason that you are completing this request by checking box a, b, or c, below. 

a. D I am requesting a repayment plan based on my income - Check the plan(s) you are requesting below and then continue to item 2. 

Direct Loan Program Loans• FFEL Program Loans• 

IBR ~ 

Pav As You Earn 

• 

• Not Available 

ICR • Not Available 

I request that my loan holder determine which of the 

above plans I am eligible for, and place me on the Only IBR will be considered • for FFEL Program loans olan with the lowest monthlv Mvment amount. 

• Not all loan types under the FFEL and Direct Loan Programs are eligible for these plans (see Section 8). 

For Direct Loan borrowers, your request will apply to all of your loans that are eligible for the plan you choose. For FFEL borrowers, 

you can exclude eligible loans if you request IBR prior to July 1, 2013. If you are a FFEL borrower and request IBR on or after July 

1, 2013, you must repay all loans eligible for IBR under that plan. For all borrowers, you will need to choose a different repayment 

plan for loans that are not eligible for a repayment plan based on income or they will be placed on the standard repayment plan. 

b. D I am submitting annual documentation for the recalculation of my monthly payment amount under my current repayment plan - Continue to item 2. 

c. D I am requesting that my loan holder recalculate my current monthly payment amount because my circumstances have changed - Continue to item 2. 

2. D Check this box if you owe eligible loans to more than one loan holder. You must submit a separate request to each holder of the loans you want 

to repay under the IBR, Pay As You Earn, or ICR plan. 

You must promptly submit to your loan holder(s) this completed form and acceptable documentation of your Adjusted Gross Income (see Section 4), 

or, if applicable, alternative documentation of your current income (see Section 5). 

I SECTION 3: SPOUSAL INFORMATION 

Complete this section if any of the following apply to you: 

• You file a joint federal income tax return with your spouse and your spouse has eligible loans. Enter information about your spouse, below. 

• You have a joint Direct or FFEL Consolidation Loan that you obtained with your spouse. Enter information about the co-borrower of the loan. 

• You and your spouse have Direct Loans and both of you want to repay those loans under the ICR Plan. Enter information about your spouse, below. 

3. Spouse's SSN I I I I - I I I · I I I I I 

If you file a joint federal income tax return with your spouse, your loan 

4. Spouse's Name holder(s) .,;n base your ei gibility detennination and monthly payment 

amount on your and your spouse's combiled income regardless of 

whether your spouse has eligible federal student loans. However, if yotr 5. Spouse's Date of Birth ............ ___.I - I ..... ............. I - I ..... ......._....__ ............ spouse does not have eligible student loans, you do not need to 

complete this section. 

6. D My spouse and I wish to repay our Direct Loans jointly under the ICR Plan. 

If you complete this section, your spouse is also required to sign this form. By signing, your spouse is authorizing the loan holde«s) to access information 

about his or her federal student loans in the National Student Loan Data System (NSLDS). In addition, if the Department is not your loan holder and your FFEL 

loan holder(s) does not service at least one of your spouse's loans, your loan holder(s) will need detailed information about all of your spouse's loans to accurately 

evaluate your eligibility and payment amount. Your spouse should log into NSLDS at nslds.ed.gov to give your loan holde«s) access to his or her loan information. 

To obtain the organization code needed for authorization on NSLDS or for other options to provide the loan details needed on your spouse's loans, contact your 

loan holder(s). Carbonneau Attachment A - 10 

Page 1 of 5 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 11 of 13
3DJH  RI 

SECTION 4: FAMILY SIZE AND FEDERAL TAX INFORMATION 

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SECTION 5: ALTERNATIVE DOCUMENTATION OF INCOME 

To be completed if (1) you did not file a federal income tax return for the two most recently completed tax years, (2) your AGI from your most recently 

filed federal income tax return does not reasonably reflect your current income (due to circumstances such as the loss of or change in employment),

or (3) your loan holder(s) informed you that alternative documentation of income is required. 

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SECTION 6: BORROWER REQUEST, UNDERSTANDINGS, AGREEMENT, AUTHORIZATION, AND CERTIFICATION 

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Borrower’s Signature Date 

Spouse’s Signature (if required) Date 

Note <RXU VSRXVH¶V VLJQDWXUH LV UHTXLUHG LI \RX FRPSOHWHG 6HFWLRQ  DQGRU FRPSOHWHG ,WHP 

DocuSign Envelope ID: 

Carbonneau Attachment A - 11

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 12 of 13
DocuSign Envelope ID: 

GENERAL FORBEARANCE REQUEST 0MB No. 1845-0031 

William D. Ford Federal Direct Loan Program Form Approved 

Elip. Date 12/31/2015 

WARNING: Any person who knowingly makes a false statement or misrepresentation on this form or on any accompanying document 

will be subject to penalties which may include fines, imprisonment, or both, under the U.S. Criminal Code and 20 U.S.C. 1097. 

GFB 

I SECTION 1: BORROWER IDENTIFICATION 

Please enter or correct the following information. 

0 Check 

Name 1

this box if any of your infonnation has changed. 

SSN Chelsea • 1 Carbonnea I I - 1• u I I - • 

..._ __ .._ __ ..___. _ __. 

Telephone - Primary 

Telephone - Alternate ( 

E~ail Address (Optional) 

I SECTION 2: FORBEARANCE REQUEST 

Before completing this form, carefuly read the entire form, including the instructions and other information in Sections 3, 4, and 5. 

• I am willing but unable to make my current Direct Loan payments due to a temporary hardship. I am requesting this forbearance because I am experiencing a temporary hardship 

related to one of the folowing situations (check one): 

~ Financial difficulties 

0 Change in employment 

D Medical circumstances 

0 Other (explain): 

• If this forbearance request is approved, I want to (check one): 

0 Temporarily stop making payments; or 

0 Temporarily make smaller payments of$ _____ per month. 

• If this forbearance request is approved, I am requesting that the U.S. Department of Education (ED) grant a forbearance on my loan(s) beginning (MM•DO-YYYY) 

LJ LJ-LJ LJ·LJ LJ LJ LJ alld ending (MM-OD-YYYY) LJ LJ·LJ LJ-LJ LJ LJ LJ for a period not to exceed 12 months. 

I SECTION 3: BORROWER/ENDORSER UNDERSTANDINGS AND CERTIFICATIONS 

• I understand that the following terms and conditions apply to this forbearance request: 

(1) ED will not grant this forbearance request unless this form is completed and any required supporting documentation is provided. 

(2) ED may grant a forbearance on my loans for up to 60 days, if necessary, for the colection and processing of documentation related to my forbearance request. ED will not 

capitalize interest that accrues during this forbearance. 

(3) If I am past due on payments not covered by this forbearance, ED may grant an additional forbearance on my loan(s) to resolve all payments due when my request is 

processed, and all unpaid interest may be capitalized. 

(4) At the end of the forbearance, I may apply to renew the forbearance if I am stil experiencing a financial hardship. 

(5) I wil continue to receive billing statements for my current payment amount, which I must pay until I am notified by my servicer that my forbearance request has been granted. 

(6) During the forbearance period, I am not required to make payments of loan principal and interest, but interest will be charged on al of my loans. 

(7) If I requested to temporarily stop making payments, I will receive an interest notice, and I may pay the interest at any time. If I do not pay the interest that accrues on my 

loan(s), it wil be capitalized at the end of the forbearance period. 

(8) If I requested to temporarily make smal er payments, I wl receive a monthly notice for the requested payment amount until the forbearance ends, and any unpaid interest 

that has accrued during the period will be capitalized at the end of the forbearance period. 

• I certify that: 

(1) The information I have provided on this form is true and correct. 

(2) I will provide any additional documentation to ED, as required, to support my continued forbearance status. 

(3) I will notify ED immediately when the condition that qualified me for the forbearance ends. 

(4) I agree to repay my loan(s) according to the terms of my promissory note, regardless of whether the forbearance is granted. 

• I authoriize the entity to which I submit this request (i.e., the school, the lender, the guaranty agency, ED, and their respective agents and contractors) to contact me regarding my 

request or my loan(s), including repayment of my loan(s), at the number that I provide on this form or any future number that I provide for my celular telephone or other wireless 

device using automated dialing equipment or artificial or prerecorded voice or text messages. 

BORROWER'S OR ENDORSER'S SIGNATURE: DATE: 

Page 1 of 2 

Carbonneau Attachment A - 12 

Case 4:18-cv-00806-SBA Document 27-1 Filed 03/02/18 Page 13 of 13
Carbonneau Attachment B

Case 4:18-cv-00806-SBA Document 27-2 Filed 03/02/18 Page 1 of 2
From:

To:

Subject:

Date:

My email to them

Sent from my iPhone

Begin forwarded message:

From: Chelsea Carbonneau 

Date: May 26, 2017 at 12:08:33 PM EDT

To: Sonya Griffin <sonya.griffin@afbcenter.com>

Subject: Regarding Carbonneau account

Afternoon,

I have chosen to email at this time because I am unavailable by phone and I have

been advised by my loan providers to acquire a paper trail of these discussions.

Back when I signed up for this Loan Forgiveness Program with AFBC in 2015, I

was told that these autodraft payments of $149 (now $99) would be towards my

student loan balance and ultimately would be forgiven after 10 years. A few

months ago, I had notified AFBC that I was back in school and inquired

information whether I qualified for not paying any student loans until I graduated

or I did not because I was in a loan forgiveness program. $99 transactions have

still been taken out of my bank account even though they do not need to be and

nobody has provided me with this information; just required me to sign off on

Income-based documents.

I was notified by Great Lakes Student Loans yesterday on May 25, 2017 that no

communication has been given to them regarding my account and NO payments

have been received by them as your company was presumed to be the "middle

man" and that I am paying AFBC to perform unneeded tasks. $2580 has been

drafted from my account that could have paid down my loans significantly, and

yet they have not. According to them, this is fraud. I will need documentation sent

to me via email or postal mail as to where these $149 and $99 transactions have

been going and why AFBC is continuing to autodraft my account while I am a

student. If these loans are to be forgiven at some point in time in the future, how

can this occur if my Student Loan provider if no company is receiving these

documents?

This email is not to sound rude but I am very stricken by this situation and need

answers.

Thank you

Chelsea Carbonneau

Carbonneau Attachment B - 1

Case 4:18-cv-00806-SBA Document 27-2 Filed 03/02/18 Page 2 of 2