Consumer complaint received 2020-05-26
Product: Student loan — Federal student loan servicing
Issue: Dealing with your lender or servicer — Trouble with how payments are being handled
Company: AES/PHEAA (MD)

COMPLAINT HEREIN IS GIVEN BY XXXX XXXX XXXX/STUDENT LOAN BORROWER ( HEREINAFTER, BORROWER ) UNDER OATH/PENALTY OF PERJURY AGAINST FEDLOAN SERVICING/PENNSYLVANIA HIGHER EDUCATION ASSISTANCE AGENCY ( PHEAA ) XXXX XXXX XXXX , PHEAA PRESIDENT AND CHIEF EXECUTIVE OFFICER ( CEO ), ET AL. ( HEREINAFTER, FEDLOAN ), XXXX ADMITTED AGENT ( S ) OF DEPARTMENT OF EDUCATION AND UNITED STATES SECRETARY OF EDUCATION, XXXX XXXX XXXX, FOR KNOWING AND WILLFUL REPEATED STUDENT LOAN REPAYMENT FALSE REPRESENTATIONS TO U.S. GOVERNMENT RECORDS ( NATIONAL STUDENT LOAN DATA SYSTEM, NSLDS ) AND TO XXXX, XXXX, XXXX, ( HEREINAFTER, CREDIT REPORTING AGENCIES, CRAS ) BORROWERS CREDIT REPORTS TO GAIN MORE THAN {$100000.00} STUDENT LOAN PAYMENT NOT OWED. 

FEDLOAN EXPRESS ADMISSIONS RE XXXX XXXX FEDLOAN GROUPED-SEVEN-LOAN ACCOUNT. 

Under Standard Loan Repayment Plan ( 120 fixed equal monthly payments to paid-in-full ), from XX/XX/XXXX through and including XX/XX/XXXX, borrower made 99/120 timely, monthly, as billed/equal payments of {$1000.00}, total repaid to date about {$100000.00}, total six-loans-grouped-account current outstanding, about {$17000.00}, ( EXHIBIT 1., EXHIBIT 2., and EXHIBIT 4. pages 2-3. ). A seventh loan, listed by FedLoan in NSLDS, was never disbursed to borrower, balance : XXXX. 

COMPLAINT : FEDLOANS ONGOING PATTERN-OF-PRACTICE SCHEME TO COLLECT APPROXIMATELY DOUBLE PAYMENT AMOUNT OWED. 

FedLoans actions complained herein occurred from about XX/XX/XXXX-Present-XX/XX/XXXXongoing. 

FedLoans pattern-of-practice scheme of false repayment representations began after borrower, account in good standing, had completed about 70/120 payments ( XXXX, EXHIBIT 5. ) and 99/120 payments ( XXXX, EXHIBIT 6. and EXHIBIT 7. ). FedLoans false representations, left unchallenged, increase borrowers XXXX outstanding debt by about {$100000.00}, and in XXXX, {$120000.00} ( debt not owed ) ; and increase by 8-10 years borrowers repayment term ( EXHIBIT 5. Terms [ each of six loans ] : 132 Months-147 Months ), i.e. an increase from 120 months/10 years ( Standard Loan Repayment Plan ) to 18-20 years repayment total. 

THE TWO ISSUES OF HEREIN COMPLAINT ARE : I. FEDLOANS FALSE REPRESENTATION ( S ) REPAYMENT RECORDS, EXPRESS DEMAND FOR BORROWER TO REPAY DEBT NOT OWED. 
TIMELINE FEDLOANS WILLFUL AND KNOWING FALSE REPAYMENT REPRESENTATIONS THROUGH PRESENT-XX/XX/XXXX. 

1. FedLoans billing not fixed not equal monthly payments, unquestionable breach of Standard Loan Repayment ( 120 months fixed equal payments to paid in full, EXHIBIT 4. Page 3 ). 
FedLoan billed {$150.00} outstanding interest, paid by borrower XX/XX/XXXX, check number XXXX. 
Loans entered repayment XX/XX/XXXX : FedLoan billed {$1200.00} monthly payment grouped-six-loans account paid by borrower XX/XX/XXXX, check number XXXX. 
FedLoan billed {$1000.00} monthly payment, paid by borrower on XX/XX/XXXX, check number XXXX. 
FedLoan billed {$0.00} due XX/XX/XXXX. 
FedLoan billed {$690.00} monthly payment, paid by borrower on XXXXXX/XX/XXXX, check number XXXX. 
Fedloan monthly billed {$1000.00} ( EXHIBIT 4. FedLoan letter page 3 ), XX/XX/XXXX through and including XX/XX/XXXX. Payment allocations to each of six loans ( EXHIBIT 4. FedLoan Letter, page 3, Table ) are reflected in EXHIBIT 1. from XX/XX/XXXX through and including XX/XX/XXXX. 
2. FedLoans knowing and willful payments misallocation ( EXHIBIT 1. ). FedLoan, thereby, engineers fictitious underpayment representation ( s ). 
FedLoan knowingly and willfully misallocated borrowers monthly payment of {$1000.00} among the six loans in repayment so that loans were simultaneously overpaid- and remaining loans were underpaid ; then the next month FedLoan alternating the loans to make prior overpaid loans underpaid and prior underpaid loans overpaid, repeating for XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, XX/XX/XXXX, and XX/XX/XXXX ( EXHIBIT 1. ). The net result was that despite borrowers timely {$1000.00} monthly payments all five said months, most/if not all six individual loans falsely represented underpayment one or more times during these five months misallocations time period. 
3. FedLoan ( EXHIBIT 5. XXXX, CRAs example ) falsely represents to CRAss borrowers credit reports : Terms extension from 50/120 monthly payments remaining to 132-147 monthly payments outstanding ; Status Deferred, payments begin XX/XX/XXXX ( contradicted by EXHIBIT 1. FedLoans account review showing 70/120 Standard Loan Repayment payments made timely, as billed/equal payments of $ XXXX/month ) ; and Comment : Account in Forbearance. ( No Forbearance requested or consented to by borrower, per se unlawful. ) 4. FedLoans knowing and willful monthly billing underpayment amounts in clear violation of Standard Repayment Plan ( $ XXXX/month, EXHIBIT 4., page 3 ), absent legally required express notification to borrower. 
XX/XX/XXXX- {$900.00} billed/ {$1000.00} paid ; XX/XX/XXXX- {$980.00} billed/ {$1000.00} paid ; XX/XX/XXXX- {$1000.00} billed/ {$1000.00} paid ; XX/XX/XXXX- {$1000.00} billed// {$1000.00} paid ; ( EXHIBIT 2. ). 
XX/XX/XXXX-Present-XX/XX/XXXXbilled {$1000.00}, borrower paid {$1000.00} every month ( EXHIBIT 2. ). ( EXHIBIT 4. FedLoan letter, page 3, Standard Loan Repayment is $ XXXXmonth/120 months to paid-in-full ) 5. FedLoan knowingly and willingly falsely represents to NSLDS ( EXHIBIT 6. ) on or shortly after XX/XX/XXXX : Borrowers six loans entered repayment XX/XX/XXXX. Yet, FedLoan ADMITS loans entered repayment XX/XX/XXXX, EXHIBIT 1., EXHIBIT 2. and EXHIBIT 4. ) borrowers account shows 99/120 payments from XX/XX/XXXX through and including XX/XX/XXXX. 
Borrowers six loans are Repayment Progress 82 % -94 %, yet inexplicably in NSLDS FedLoan falsely represents borrower XX/XX/XXXX has {$120000.00} Amount Remaining, after borrower made 99/120 monthly payments, total repayment of about {$100000.00} through and including XX/XX/XXXX ( EXHIBIT 1. and EXHIBIT 2. ). Further, FedLoan ADMITS ( EXHIBIT 2., page 1 ) borrowers outstanding debt, after XX/XX/XXXX payment is credited, is about {$17000.00} ( EXHIBIT 2., page 1 ). 
6. Fedloan knowingly and willingly falsely represents to CRAs borrowers credit reports ( EXHIBIT 7. XXXX, example ) XX/XX/XXXX : High Balance of six loans original unpaid amount from XX/XX/XXXX to XX/XX/XXXX for each of borrowers six student loans, thereby, FedLoan denies borrowers 99/120 months loans repayment through XX/XX/XXXX. Yet, FedLoan ADMITS 99/120 payments completed EXHIBIT 1. and EXHIBIT 2. 
Terms paid monthly for 120 months for each of borrowers six student loans, thereby, FedLoan denies borrowers 99/120 months loans repayment through XX/XX/XXXX. Yet, FedLoan ADMITS 99/120 payments completed EXHIBIT 1. and EXHIBIT 2., and only about 17/120 months, $ XXXX/month repayment outstanding. 
In summary, FedLoan represents in monthly billing to borrower ( EXHIBIT 1. and EXHIBIT 2. ) good standing loans repayment ; while FedLoan knowingly and willingly simultaneously falsely represents to U.S. government database, NSLDS ( EXHIBIT 6. ), and to CRAs borrowers credit reports ( EXHIBIT 5. XXXX, example. and EXHIBIT 7. XXXX, example. ) borrowers alleged nonpayment/underpayment. 

II. FEDLOANS ARBITRARY UNILATERAL PER SE UNLAWFUL FORBEARANCES AND -DEFERMENT TO OBFUSCATE FEDLOANS FALSE REPAYMENT REPRESENTATIONS, TWO OF FOUR FORBEARANCES APPLIED TO BORROWERS ACCOUNT RETROACTIVELY. 

Second, to obfuscate FedLoans willful and knowing false repayment representations ( Issue I. ), FedLoan unilaterally imposed numerous Forbearances ( two, in the last three weeks, XX/XX/XXXX-XX/XX/XXXX on borrowers grouped-six-loan-account, EXHIBIT 3. ). A legal definition of Forbearance is given 34 C.F.R. 682.211 ( a ) ( 1 ) : Forbearance means permitting the temporary cessation of payments, allowing an extension of time for making payments, or temporarily accepting smaller payments than previously were scheduled. Thereby, per se unlawful ( imposed absent borrowers request or consent ) Forbearance ( s ), FedLoan willfully and knowingly represents false borrowers default or nonpayment or underpayment when neither default nor untimely, nor nonpayment, nor underpayment exists. ( EXHIBIT 1 and EXHIBIT 2, FedLoan ADMITTED XX/XX/XXXX through XX/XX/XXXX, 99/120 timely, monthly, equal-/as billed payments of {$1000.00}, total to date about {$100000.00} repaid, total six-loans-grouped-account current outstanding, about {$17000.00}, Standard Loan Repayment-120 fixed equal monthly payments to paid-in-full ). 

FEDLOANS FORBEARANCES AND DEFERMENT ARE PER SE UNLAWFUL AND MUST BE EXPUNGED. 

To lawfully place a Forbearance on borrowers account FedLoan must : ( i ) 34 C.F.R. 682.211 ( b ) ( 1 ) prior have the borrowers consent ( oral and/or written ) ; ( ii ) 34 C.F.R. 682.211 ( a ) ( 1 ) borrowers account is in default, or nonpayment, or delinquent ; ( iii ) 34 C.F.R. 682.211 ( e ) ( 1 ) when Forbearance is granted and placed on borrowers account FedLoan must expressly specify the terms of the Forbearance to borrower ; ( iv ) 34 C.F.R. 682.211 ( e ) ( 2 ) ( vi ) at any time upon borrowers request FedLoan must cancel Forbearance. 

To lawfully place a Deferment on borrowers account FedLoan must : ( i ) 34 C.F.R. 685.204 ( a ) ( 4 ) ( i ) the borrower must request the deferment andprovide the Secretary with all information and documents required to establish eligibility for the deferment. 
( i ) 34 C.F.R. 685.204 ( a ) ( 5 ) ( iii ) If the Secretary grants a deferment, the Secretary notifies the borrower that the deferment has been granted and that the borrower has the option to cancel the deferment and continue to make payments on the loan. 
None of said four requirements for Forbearance ( 34 C.F.R. 682.211 Forbearance. ) or two requirements for Deferment ( 34 C.F.R. 685.204. Deferment. ) exist from 03 XXXX XXXX-Present ( XX/XX/XXXX ) for borrowers group-six-loan-account serviced by FedLoan ( EXHIBIT 3. Table 1. List of Forbearances and Deferment since XXXX XX/XX/XXXX ). Further, borrower finds no provision in 34 C.F.R. 682.211 or borrowers Master Promissory Notes ( MPNs ) contract for FedLoan lawfully to retroactively ( XXXX XX/XX/XXXX express notice ) unilaterally to apply Forbearance ( effective XXXX XX/XX/XXXX ) to nonconsenting borrowers account in good standing during which retroactive-Forbearance three monthly payments ( $ XXXX XXXX, $ XXXX XXXX, $ XXXX XXXX, EXHIBIT 2 ) have already been billed by FedLoan and timely paid by borrower ( EXHIBIT 2. pages 1-6 ) to FedLoan. FedLoan never provided legally required, 34 C.F.R. 685.204 ( a ) ( 5 ) ( iii ), notice retroactive Deferment ( EXHIBIT 5. ) existed to borrower, borrower being monthly billed by FedLoan and paying uninterrupted {$1000.00} monthly ( EXHIBIT 1. ) throughout said fictitious CRAs borrowers credit reports published Deferment, ending XX/XX/XXXX ( EXHIBIT 5. XXXX, CRAs example, XXXX XX/XX/XXXX, Status. ). 

FEDLOANS PER SE UNLAWFUL FORBEARANCES AND DEFERMENT XXXX FOLLOW BORROWERS COMPLAINTS OF FEDLOANS FALSE REPAYMENT REPRESENTATIONS ( EXHIBIT 3. Table 1. Forbearances and Deferment List. ). 

See, Consumer Financial Protection Bureau, CFPB, complaints : XXXX, submitted XX/XX/XXXX ; XXXX, submitted XX/XX/XXXX ; XXXX, submitted XX/XX/XXXX. ) Said XXXX CFPB complaints reflect replicated intentional fraud as herein XXXX complaint fraud-/extortionate process. ( EXHIBIT 7. Last page, borrowers 100-word dispute statement in XXXX. ) FedLoan via per se unlawful Forbearances and Deferment scheme, herein described, willfully and knowingly and repeatedly ( XXXX ) represents false borrower nonpayment/underpayment/default and by said fictitious unpaid-debt reports repeatedly attempts to justify unjustifiable false representations to obtain approximately double repayment amount ( EXHIBIT 5., EXHIBIT 6., and EXHIBIT 7. ), from borrower, in clear violation of Master Promissory Note ( s ) contract ( s ). Said FedLoan express allegation ( s ) of nonpayment/underpayment/default by insertion of about four per se unlawful Forbearances and one per se unlawful Deferment in less than three years in NSDLS and CRAs borrowers credit reports clearly will be deemed libel per se to extort from borrower more than double repayment owed. 

All four Forbearances FedLoan placed on borrowers account from XXXX XXXX and Deferment FedLoan through XXXX reported XXXX XX/XX/XXXX are per se unlawful and must be expunged, failing compliance with 34 C.F.R. 682.211 and 34 C.F.R. 685.204. prerequisites/requirements and borrowers MPNs, latter, unambiguous breach of contract by FedLoan . 

BORROWERS STATEMENT. 

BorrowerXXXX XXXX XXXX reiterates under penalty of perjury that after borrowers student loans serviced by FedLoan entered repayment on XX/XX/XXXX : ( i ) Borrower never requested- nor by any means ( oral or written ) assented to any Forbearance or Deferment ; ( ii ) Borrower never deviated from-, or modified-, or assented to any modification from Standard Loan Repayment ( 120 equal monthly payments, $ XXXX/month, to paid-in-full, now through XX/XX/XXXX, 99/120 payments completed, about {$100000.00} paid, as of XX/XX/XXXX, borrower owes about {$17000.00} total to paid-in-full for six ( a seventh loan was never disbursed/canceled, {$0.00} owed ) loans grouped account ( EXHIBIT 1 and EXHIBIT 2 ) ; ( iii ) In EXHIBIT 1., EXHIBIT 2. compare payments amount ( $ XXXX/month ) and dates paid with XXXX Deferment and XXXX Forbearances dates listed in EXHIBIT 3. Borrower made every monthly payment ( grouped-, six loans account ) uninterrupted, timely, as billed/equal payment, and continued uninterrupted equal $ XXXXmonth payment timely every month throughout all FedLoans per se unlawful Forbearances ( XXXX-XXXX  about four Forbearances in less than 3 years, and, throughout the CRAs borrowers credit reports fictitious Deferment ( EXHIBIT 5. XXXX, example, dated XXXX XXXX XXXX, showing unlawful pop-up/absent borrowers request or consent, and, absent Deferment terms and conditions notice to borrower ) ; ( iv ) Every monthly payment was made by paper check, bank records verification showing date and amount paid/withdrawn ( EXHIBIT 2., last three pages, examples ), and check, sent via US mail FedLoan receipt signature-required ( proves timely receipt by FedLoan ) ; and ( v ) Borrower retains original executed copies of Master Promissory Notes ( MPNs ) for student loans serviced by FedLoan . 

BORROWERS PRIOR NOTICE TO FEDLOAN AND SECOND UNLAWFUL NONCONSENSUAL FORBEARANCE UNILATERALLY BY FEDLOAN XX/XX/XXXX. 

Borrower orally/by phone : XXXX, provided notice and request for correction to FedLoan of herein false student loans repayment representations in NSLDS and CRAs borrowers credit reports and nonreceipt of US mail XX/XX/XXXX billing for monthly payment due XX/XX/XXXX : XXXX XXXX XXXX about XXXX XXXX XXXX employee ID, XXXX ; XX/XX/XXXX about XXXX XXXX XXXX, ID, XXXX, transferred about XXXX to XXXX , ID, XXXX ; XX/XX/XXXX about XXXX XXXX XXXX , ID, XXXX ; XX/XX/XXXXabout XXXX XXXX XXXX  , ID XXXX ; XX/XX/XXXX about XXXX XXXX XXXX , ID, XXXX. On XX/XX/XXXX, after borrower reported said fraudulent repayment reporting and XX/XX/XXXX-XX/XX/XXXX unlawful Forbearance, XXXX stated XX/XX/XXXX that as a result of borrowers phone call borrowers grouped FedLoan account would undergo Administrative Review purportedly resulting in a second Administrative Forbearance, now, two fraudulent Forbearances ( XX/XX/XXXX and XX/XX/XXXX ) unilaterally FedLoan imposed on borrowers grouped-six-loans-account in the past three ( 3 ) weeks. XXXX received neither request nor consent from borrower to impose said Forbearance, no notice of terms and conditions of said Forbearance has been received by borrower to date-XX/XX/XXXX. On XXXX XX/XX/XXXX about XXXX XXXX XXXX, ID XXXX stated in error XX/XX/XXXX retroactive Forbearance had been expunged from NSLDS on XXXX XX/XX/XXXX ; denied knowledge of false XX/XX/XXXX repayment start date in NSLDS and also, denied knowledge of outstanding [ six-loans ] balance of {$120000.00}. Borrower reiterated that said false representations were extortionate and borrower would file formal complaint unless all was corrected within next 24 hours ( borrower having provided prior notice from XX/XX/XXXX to no avail ). 

FEDLOANS KNOWING AND WILLFUL HARM TO BORROWER FOLLOWING BORROWERS COMPLAINTS RE FEDLOANS PER SE UNLAWFUL ONGOING ACTS. 

As licensed attorney, borrowers professional license is predicated on financial responsibility mandated by ethics rules and state law ( Mass. Gen. XXXX XXXX. Ch. XXXX ). Here, FedLoan knowing that said outstanding debt express representation of about {$120000.00} was false ( EXHIBIT 1. and EXHIBIT 2. ), willingly repeatedly ( XXXX-XXXX  ) falsely represented to the US government National Student Loan Data System, NSLDS, and CRAs, for publication as fact that borrower owes ( EXHIBIT 5., EXHIBIT 6., EXHIBIT 7. ) over {$100000.00} and via numerous unlawful Forbearances and -Deferment false representations ( XXXX-XXXX  ) borrower ( a licensed attorney ) delayed/defaulted/underpaid six student loans repayment ( EXHIBIT 3. ). 

FedLoans said knowing and willful false representations of {$120000.00} borrowers outstanding debt XXXX ( EXHIBIT 6. ) : ( i ) directly caused material harm to borrowers ability to obtain credit upon rational terms ; ( ii ) expressly placed borrowers professional ethics, re financial responsibility in question in official government records and CRAs credit reports used by financial institutions and prospective employers ; thereby ( iii ) FedLoan knowingly and willingly actually putting borrowers professional license, in jeopardy ; and ( iv ) literally taking-by-fraud unpaid months of borrowers professional effort ( from profitable endeavor ) to challenge FedLoans XXXX-XXXX repeated per se libel for monetary per se extortion of about double repayment owed by MPNs contract ( s ). Borrower respectfully asserts FedLoans knowing and repeated false representations published ( willfully disclosed to third parties ) in government records and credit reports meet the definition of libel for per se extortion. 28 U.S.C. 4101 ( 1 ) states : In this chapter : ( 1 ) Defamation. 
The term defamation means any action or other proceeding for defamation, libel [ written ], slander, or similar claim alleging that forms of speech are false, have caused damage to reputation or emotional distress, have presented any person in a false light, or have resulted in criticism, dishonor, or condemnation of any person. 
( https : XXXX, last viewed XX/XX/XXXX. ) 18 U.S.C. 872. Extortion by officers or employees of the United States. 
Whoever, being an officer, or employee of the United States or any department or agency thereof, or representing himself to be or assuming to act as such, under color or pretense of office or employment commits or attempts an act of extortion, shall be fined under this title or imprisoned not more than three years, or both ; but if the amount so extorted or demanded does not exceed {$1000.00}, he shall be fined under this title or imprisoned not more than one year, or both. 
( https : XXXX, last viewed XX/XX/XXXX ) To argue FedLoans repeated false representations to collect double monetary repayment were good faith mistakes ( EXHIBIT 1. and EXHIBIT 2. FedLoans ADMISSION of borrowers good standing repayment ) lacks modicum of rational credibility. 

REMEDY REQUESTED. 

In accordance with both federal and state law, XXXX XXXX XXXXstudent loan borrower respectfully requests that FedLoan be required : ( i ) to permanently expunge extortionate/false current {$120000.00} outstanding debt, reported on or after XX/XX/XXXX-Present-XX/XX/XXXXto NSLDS, CRAs credit reports, and all other records of XXXX XXXX/borrowers FedLoan student loan account ; ( ii ) to permanently expunge all per se unlawful Forbearances and Deferment ( s ) dating from XX/XX/XXXX-Present-XX/XX/XXXXfrom borrowers NSLDS account, CRAs credit reports, and all other student loan repayment records that may exist for XXXX XXXX XXXX ; ( iii ) Per the Coronavirus Aid, Relief, and Economic Security Act ( H.R. 748 ), CARES Act 3513, signed into law XX/XX/XXXX, FedLoan credits 100 % borrowers payments XX/XX/XXXX through and including XX/XX/XXXX to payment of principal in accordance with Department of Education guidance : During the period of 0 % interest ( XX/XX/XXXX, through XX/XX/XXXX ), the full amount of your payments will be applied to principal once all the interest that accrued prior to XX/XX/XXXX is paid ( https : //studentaid.gov/announcements-events/coronavirus, last viewed XXXX XX/XX/XXXX ) ; ( iv ) In accordance with federal and state law, FedLoan make all monthly repayment representations accurately/factually/timely in NSLDS and in CRAs borrowers credit reports and all other student loan repayment records that may exist for borrower/XXXX XXXX XXXX, specifically including correction of every monthly repayment misallocation ( XXXX XXXX-XX/XX/XXXX, and XX/XX/XXXX through XX/XX/XXXX, EXHIBIT 1. ) resulting in under- or overpayment of borrowers six loans in repayment ( EXHIBIT 4. FedLoan Letter, Table, page 3, shows amount of fixed equal {$1000.00} monthly payment apportioned to each of six loans ) ; ( v ) Only one, the valid repayment start date, XX/XX/XXXX, be shown in NSLDS and CRAs borrowers credit reports and all other false representations of more recent repayment start date ( s ) be permanently expunged in NSLDS and CRAs debtors credit reports and any other existing repayment records for borrower ; ( vi ) Per FedLoans Standard Loan Repayment express XXXX agreement ( EXHIBIT 4. FedLoan letter. ) FedLoan bills borrower timely ( lawfully, 20 days ahead of each payment due date, XXXX day of each month ) by U.S. mail for $ XXXX/month grouped-six-loans-account until paid-in-full. FedLoan ADMITS borrowers grouped six-loans-account outstanding is about {$17000.00} ( approximately 17 months ) repayment remaining ( EXHIBIT 2. page 1, also including payment of {$1000.00} FedLoan received XX/XX/XXXX, page 4. ). 

( vii ) If these reasonable and lawful remedies, permanently to expunge all false/inaccurate, per se unlawful student loan repayment and credit report ( s ) representations, are not completed with express proof of all corrections completion provided XXXX XXXX/borrower within 15 calendar days of herein CFPB Complaint, borrower will initiate formal state and federal proceedings against all parties involved in said per se libel-for-extortion scheme to include, but be not limited to : FedLoan Servicing/Pennsylvania Higher Education Assistance Agency/PHEAAXXXX XXXX XXXX, PHEAA President and Chief Executive Officer, CEO, et al. ; Department of Education ; Department of Education Secretary, XXXX XXXX XXXX ; XXXX, XXXX, XXXX and others propagating said false representations. Allegations will include but not be limited to : U.S. mail fraud ( 18 U.S.C.1341 ), U.S. wire fraud ( 18 U.S.C.1343 ) ; violation of False Statements Accountability Act ( 18 U.S.C. 1001 ) ; Racketeer Influenced and Corrupt Organizations/RICO ( 18 U.S.C. 1961-1968 ) ; and violations of : MD Code Com Law 3 & 4 ; Electronic Funds Transfer Act ( 15 U.S.C. 1693-1693r, implemented through Regulation E, 12 CFR Part 1005 ) ; Fair Credit Reporting Act ( 15 U.S.C. 1681 et seq., implemented through Regulation V, 12 CFR 1022 ) ; Consumer Financial Protection Act of 2010 ( 12 U.S.C. 5511 et seq. ) ; Gramm-Leach-Bliley Act, Pub. L. No. 106-102, 113 Stat. 1338, codified in relevant part primarily at 15 U.S.C. 6801-6809 [ Regulation P, privacy violations ], 6821-6827, prohibiting obtaining customer information of a financial institution by false pretenses ; 28 U.S.C. 4101 ( 1 ) ; 18 U.S.C. 872 ; 18 U.S.C. 242 ; and 42 U.S.C. 1983. 

Borrower will through litigation by a law firm experienced in libel re student loan repayment representation ( s ) and student loan servicer repayment reporting fraud to gain money not due or owing, request all court costs, all attorneys fees, treble damages plus such punitive damages the Consumer Financial Protection Bureau, Federal Trade Commission and/or court shall deem appropriate for FedLoans pattern-of-practice scheme per se to extort about {$120000.00}, thereby knowingly and willfully causing foreseeable material harm to borrowers finances, credit, professional reputation as licensed attorney, and professional time unpaid spent to challenge FedLoans repeated per se unlawful/extortionate acts. 

LIST OF SEVEN ( 7 ) EXHIBITS ATTACHED AS .pdf. 

EXHIBIT 1. FedLoans Account Review, dated XX/XX/XXXX, for Borrowers Grouped-Six-Loans Account. Borrowers repayment history for six loans in repayment from repayment start date, XX/XX/XXXX, uninterrupted timely repayment to XX/XX/XXXX. [ Thirty ( 30 ) pages. ] EXHIBIT 2. FedLoans Monthly Billing Showing Borrowers Account Status from XX/XX/XXXX through and including XX/XX/XXXX Payment-XX/XX/XXXX Bill, Includes Three ( 3 ) Bank Statements, XX/XX/XXXX-XX/XX/XXXX ( last 3 pages, one example time period when FedLoan misallocated payments among six loans ). FedLoan expressly ADMITS in every monthly billing statement, XX/XX/XXXX-XX/XX/XXXXtimely, full-amount-due ( $ XXXX/month six loans grouped account payment ), repayment receipt : Total paid since your last statement {$1000.00}, i.e. amount paid the month prior to month date billed. ( See, lower left box of each billing statement XX/XX/XXXX through XX/XX/XXXX ). [ Thirty ( 30 ) pages. ] EXHIBIT 3. TABLE 1. Summarizes FedLoans Per Se Unlawful Forbearances and One Deferment ( EXHIBIT 5. ) From XXXX XXXX-Present. FedLoan EXPRESSLY ADMITS in EXHIBIT 1. and EXHIBIT 2. borrower paid uninterrupted $ XXXX/month, timely, throughout all four said per se unlawful Forbearances and per se unlawful Deferment. 

EXHIBIT 4. FedLoan Letterhead Letter Dated XX/XX/XXXX. Fedloan responds to borrowers repeated requests ( XX/XX/XXXX-XX/XX/XXXX ) for FedLoan to bill borrower via Standard Loan Repayment, i.e. equal, fixed, payments 120 months to paid-in-full using US mail billing. FedLoan affirms Standard Loan Repayment of $ XXXXmonth with tabular distribution ( page 3 ) shown among six-loans in borrowers grouped-account. Further, FedLoan explains different amounts/month billed borrower XX/XX/XXXX-XX/XX/XXXX, which bills borrower paid timely as billed. 
[ Four ( 4 ) pages. ] EXHIBIT 5. Borrowers XXXX ( CRAS, Example ) Credit Report Dated XX/XX/XXXX. XXXX report showing FedLoans : ( i ) false representation of six loans repayment term ( s ), here 132-147 months from XX/XX/XXXX, payment extension of 8-10 years, to total of 18-20 years repayment, after borrower already paid about 70/120 months to paid-in-full ; ( ii ) Forbearance [ in effect ], per se unlawful, neither requested nor assented to by borrower ; ( iii ) Deferment [ in effect ], per se unlawful, absent legal notice required by law, and neither requested- nor assented by borrower. Thereby, said repayment term false representation FedLoan reports to NSLDS and CRAs both : ( a ) about eight ( 8 ) years of nonpayment ( directly contradicted by EXHIBIT 1. and EXHIBIT 2. FedLoan express good standing borrowers account admissions ) ; and ( b ) falsely represents borrower has substantive, over {$100000.00}, outstanding debt ( directly contradicted by EXHIBIT 2., page 1. FedLoan admission Current Balance, {$17000.00} after XX/XX/XXXX payment {$1000.00} credited ). [ Five ( 5 ) pages. ] EXHIBIT 6. NSLDS Borrowers FedLoan Six-loans- [ grouped-account ] Report ( s ), on XX/XX/XXXX. As shown in EXHIBIT 5, FedLoan in NSLDS falsely represents said grouped-six-loans-account repayment start date of XX/XX/XXXX. Contrast EXHIBIT 1 and EXHIBIT 4, FedLoans ADMITTED repayment start date of XX/XX/XXXX. Please note EXHIBIT 6. NSLDS, Repayment Details for each of six loans. While each loan shows between 82 % -94 % repaid, the Amount Remaining for each of the six loans is greater than the amount paid off ; summed, the six loans Amount Remaining is {$120000.00}. Contrast FedLoans express ADMITTED amount remaining in EXHIBIT 2, XX/XX/XXXX bill, about {$17000.00} outstanding after borrowers XX/XX/XXXX payment {$1000.00} is credited. FedLoans unquestionably repeated ( EXHIBIT 5. XXXX  ) willful and knowing per se extortion of over {$100000.00} not owed FedLoan. [ Six ( 6 ) pages. ] EXHIBIT 7. Borrowers XXXX Credit Report ( CRAS, Example ) Dated XX/XX/XXXX. FedLoans High Balance line item report for each of borrowers six loans gives the unpaid original balance of each loan as equal the high balance from XX/XX/XXXX to XX/XX/XXXX. Thereby, in said CRAs borrowers credit reports FedLoan expressly denies borrower made continuous monthly payments from XX/XX/XXXX through XX/XX/XXXX of about {$100000.00} ( total six-loans-grouped-account current outstanding, about {$17000.00}, ( FedLoan ADMITS in EXHIBIT 2. page 1 ). Borrowers prior ( XXXX  ) 100-word dispute statement is included at the bottom of the last page.