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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 ERICA BUFANO

IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR 

PRELIMINARY INJUNCTION

Case 4:18-cv-00806-SBA Document 26 Filed 03/02/18 Page 1 of 4

DECLARATION OF ERICA BUFANO IN SUPPORT OF FEDERAL TRADE 

COMMISSION’S MOTION FOR PRELIMINARY INJUNCTION

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

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DECLARATION OF ERICA BUFANO 

1. My name is Erica Bufano 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. From approximately March 2015 to March 2016, I worked in the Sales and 

Operations Departments of American Financial Benefits Center (“AFBC”) and AmeriTech 

Financial (collectively “the company”). The descriptions of the company’s policies and 

procedures in this declaration are based on my personal experience and things I observed while 

working at the company. I left the company because its practices were completely wrong. 

3. In early 2015, AFBC’s owners, Brandon Frere and Cameron Henry, interviewed 

me for a sale position. Mr. Frere did not believe that I had a six-figure income at a prior job and 

demanded that I provide him with my W-2 employment record to prove my salary. Even though 

I felt uncomfortable, I gave Mr. Frere my W-2 and he hired me. 

4. I worked in the company’s Rohnert Park office. Mr. Frere had an office in the 

company’s headquarters and managers would frequently come to him with questions. 

5. AFBC sent flyers and postcards to consumers promising to reduce their student 

loan payment or get their student loan forgiven. Consumers I spoke with who called AFBC told 

me that the company’s name was not on the mailers. AFBC managers never showed me the 

mailers, but I found them on google. 

6. My first position at AFBC was answering calls from consumers inquiring about 

student loan assistance. Mr. Henry and Tyler Colt gave me a sales script to follow and trained 

me on how to sell the company’s services. They also coached me on how to convince clients to 

inflate their family size on their student loan payment reduction applications. Mr. Henry and Mr. 

Colt instructed me to tell clients that nearly anyone could count as a family member on a student 

loan payment reduction application, including people they gave Christmas presents to. AFBC’s 

owners and managers knew the company was submitting student loan payment reduction 

applications to lenders that contained false information. 

Case 4:18-cv-00806-SBA Document 26 Filed 03/02/18 Page 2 of 4
Bufano Declaration - Page 2 

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7. My base salary as a sale representative was approximately $14 per hour. If I 

signed up more than nine clients a week, I could earn a commission. It was challenging for sales 

staff to meet their weekly quota and some employees worked 12-hour days to get their 

commission. Many AFBC clients cancelled after they realized they could modify their student 

loans for free with their lenders. 

8. AFBC charged consumers several hundred dollars to enroll them in federal 

student loan assistance programs. AFBC also charged consumers a recurring monthly fee for a 

financial education membership. Consumers I spoke with were confused about the AFBC’s 

payment structure and thought their monthly payments were going towards their student loan. 

9. Many employees at AFBC did not understand student loan applications. For 

example, AFBC employees did not tell clients that they would have to pay taxes on any loan 

amount forgiven by the federal government. In addition, AFBC was improperly calculating 

clients’ incomes by multiplying their bi-weekly salary by 24 weeks instead of the proper 26 

weeks. 

10. Consumers who called AFBC did not always sign up for the company’s services. 

AFBC instructed sales representatives to obtain a google account on their personal phone and 

text consumers who contacted AFBC, but did not complete the enrollment process. I did not text 

potential clients because AFBC did not have permission to text these consumers and I was 

concerned that sending unwanted text messages was illegal. 

11. After approximately six months, I transferred to AFBC’s Operations Department, 

which processed clients’ files. There were not enough people in the Operations Department to 

handle all the client files and applications. As a result, AFBC left many clients’ loans in 

forbearance while it was supposedly working on their loan payment reduction applications. 

Many people paid AFBC money and the company did nothing for them. 

12. In late 2015, AFBC changed its name to AmeriTech Financial. My manager told 

me and other employees in the Operations Department to stop working on AFBC client files and 

to focus on AmeriTech clients because they were paying more. After the name change, hundreds 

Case 4:18-cv-00806-SBA Document 26 Filed 03/02/18 Page 3 of 4
Bufano Declaration - Page 3 

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of AFBC client files just sat there, ignored. I raised concerns with my manager, but he 

discouraged me from asking questions. 

13. My manager and several AFBC employees told me that AFBC paid the Better 

Business Bureau to keep AFBC’s rating an A+, despite consumer complaints. 

14. AFBC and AmeriTech are shady companies. They scam people by making it 

seem like clients’ monthly payments are going towards their student loans, when in fact all the 

funds go to the company. 

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

on February 28, 2018, in California. 

_________________________ 

Erica Bufano

Erica Bufano 

Case 4:18-cv-00806-SBA Document 26 Filed 03/02/18 Page 4 of 4