Troutman Pepper State Attorneys General Monitor — November 30, 2023

State attorneys general increasingly impact businesses in all industries. Our nationally recognized state AG team has been trusted by clients for 20 years to navigate their most complicated state AG investigations and enforcement actions.

State Attorneys General Monitor analyzes regulatory actions by state AGs and other state administrative agencies throughout the nation. Contributors to this newsletter and related blog include attorneys experienced in regulatory enforcement, litigation, and compliance.

Contact our State AG Team at StateAG@troutman.com.

Regulatory Oversight Podcast

Game On: Navigating the Legal Landscape of Sports Wagering

By Stephen C. Piepgrass, Gene Fishel, and Michael Lafleur

In the latest episode of Regulatory Oversight, Gene Fishel and Mike Lafleur welcome Pat Moore and Jared Rinehimer from the Massachusetts Attorney General’s (AG) Office to discuss online sports wagering. They cover the recently enacted Massachusetts Sports Wagering Act, the associated role of the Massachusetts Gaming Commission, related rules addressing advertising and data privacy, and the overall concerns of the AG’s office.

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State AG Updates

Delaware Bankruptcy Court Enters $30M Stipulated Judgment Over Deceptive Student Loan Practices

By Troutman Pepper State Attorneys General Team

On November 20, Delaware Attorney General (AG) Kathy Jennings, along with the Consumer Financial Protection Bureau (CFPB) and 11 other states, announced a settlement in excess of $30 million with Prehired LLC and affiliated debt collection companies. This settlement resolves allegations of unlawful practices in originating, servicing, collecting, and enforcing Income Sharing Agreements (ISAs) in violation of the Consumer Financial Protection Act of 2010, the Truth in Lending Act, and its implementing Regulation Z, and the Fair Debt Collection Practices Act. Specifically, regulators alleged in a July 2023 complaint that the ISAs were unlawful, and that Prehired and its affiliates made false promises of job placement and resorted to abusive debt collection practices when borrowers could not pay. As part of the stipulated final judgment entered by the Delaware bankruptcy court, Prehired is required to cease all operations, pay $4.2 million in redress to students who made loan payments between 2019 and 2023, pay $1 million to the CFPB victims relief fund, and void all of its outstanding ISAs, which are valued at nearly $27 million.

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Stephanie Kozol, Senior Government Relations Manager – State Attorneys General, also contributed to this newsletter.