After paying either the initial fee or both fees, the consumer eventually discovers that he or she will not be getting a loan. In numerous instances, in connection with offers to provide debt consolidation loans to consumers, Defendants have made material representations, expressly or by implication, that consumers will receive a debt consolidation loan in return for the payment of a fee. In truth and in fact, after paying the requested fee to the Defendants, consumers do not receive a debt consolidation loan or any other type of loan. In numerous instances, in connection with offers to provide services to consumers, Defendants have represented, expressly or by implication, that the initial fee is the total cost to receive the Defendants' services. In truth and in fact, the initial fee is not the total cost to receive the Defendants' services.
Defendants charge consumers additional fees before providing their services.
Consumers throughout the United States have suffered and continue to suffer substantial monetary loss as a result of the Defendants' unlawful acts or practices. In addition, the Defendants have been unjustly enriched as a result of their unlawful acts or practices. Absent injunctive relief by this Court, the Defendants are likely to continue to injure consumers, reap unjust enrichment, and harm the public interest. This Court, in the exercise of its equitable jurisdiction, may award other ancillary relief to remedy injury caused by the Defendants' law violations.