Analysis of Proposed Consent Order to Aid Public Comment

In the Matter of Shop Tutors, d/b/a LendEDU, et al., File No. 182 3180

The Federal Trade Commission (“Commission”) has accepted, subject to final approval, 

an agreement containing a consent order from Shop Tutors Inc., d/b/a LendEDU (“LendEDU” or 

“the Company”); its co-founder and Chief Executive Officer, Nathaniel Matherson; its cofounder and Chief Technology Officer, Matthew Lenhard; and the Vice President of Product, 

Alexander Coleman (collectively, “Proposed Respondents”).

The proposed consent order has been placed on the public record for thirty (30) days for 

receipt of comments by interested persons. Comments received during this period will become 

part of the public record. After thirty (30) days, the Commission will again review the 

agreement and the comments received, and will decide whether it should withdraw from the 

agreement and take appropriate action or make final the agreement’s proposed order.

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

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

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

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

“objective,” “honest,” “accurate,” and “unbiased.” Contrary to their claims, Respondents have 

provided financial services companies with higher numerical rankings or star ratings and higher 

positions on rate tables based on compensation. Respondents also have added or removed 

companies from their content based on compensation.

In addition, Respondents have touted positive consumer reviews about their company and 

website that, in fact, were written by LendEDU employees or their friends, family members, and 

associates. Of 126 reviews of LendEDU on the third-party review platform Trustpilot, 90% were 

written or made up by LendEDU employees or their family, friends, or other associates. 

Respondents also have reposted and touted the Trustpilot reviews on LendEDU’s website, as 

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

The proposed order will prevent Proposed Respondents from engaging in similar acts or 

practices. Part I would prohibit Proposed Respondents from making the challenged and related 

misrepresentations. Part II would require Proposed Respondents to disclose the influence of 

compensation on representations made on its website and to disclose material connections among 

the Proposed Respondents and the various parties represented on the website. Part III would 

require Proposed Respondents, jointly and severally, to pay to the Commission $350,000 within 

8 days of the effective date of the Order.

Part IV sets out additional requirements related to the monetary relief. Part V requires 

Proposed Respondents to provide sufficient customer information to enable the Commission to 

efficiently administer consumer redress. Part VI is an order distribution provision that requires 

Proposed Respondents to provide the order to current and future principals, officers, directors,

and LLC managers and members, as well as current and future managers, agents and 

representatives who participate in certain duties related to the subject matter of the proposed 

complaint and order, and to secure statements acknowledging receipt of the order. Part VII
requires Proposed Respondents to submit a compliance report one year after the order is entered. 

It also requires Proposed Respondents to notify the Commission of corporate changes that may 

affect compliance obligations within 14 days of such a change.

Part VIII requires Proposed Respondents to maintain and upon request make available 

certain compliance-related records, including accounting records and unique websites. Part IX

requires Proposed Respondents to submit additional compliance reports within 10 business days 

of a written request by the Commission. Part X is a provision “sunsetting” the order after twenty 

(20) years, with certain exceptions.

The purpose of this analysis is to aid public comment on the proposed order. It is not 

intended to constitute an official interpretation of the complaint or proposed order, or to modify 

in any way the proposed order’s terms.