Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 3212 key Trends The CFPB targeted student-loan servicing practices of national banks, including alleged practices such as over- stating amounts due, failing to provide accurate infor- mation, and engaging in illegal debt collection activities. Although only one national bank has reached a consent order with the CFPB to date, two other national banks have disclosed ongoing CFPB investigations. Another focus of federal and state enforcement activity has been for-profit colleges, resulting in consent orders and default judgments exceeding $1 billion. Enforce- ment agencies have been particularly active in target- ing for-profit colleges that allegedly misrepresented job-placement statistics or career services, or pressured students into taking out federal or private student loans. Debt relief and adjustment providers have also been subject to state enforcement actions over the past year, as states such as Washington and New York have ob- tained judgments against companies that overcharged students, charged up-front fees, and promised debt relief services that were never provided. some 2015 Highlights Joint Statement of Principles for Student Loan Servic- ing. In September 2015, the CFPB, Department of Education, and Department of Treasury issued a joint statement of general principles for student loan servic- ing, emphasizing that practices should be consistent, accurate and actionable, accountable and transparent. Student Lending During 2015, Goodwin tracked over a dozen federal and state enforcement actions related to student lending. The actions included investigations, consent orders, and litigation involving for-profit colleges, student lenders, student loan servicers, and student loan debt relief providers. The CFPB initiated over half of these enforcement actions, primarily targeting loan servicers. The CFPB estimates that over a quarter of student loan borrowers are either delinquent or in default, with the entirety of student loan debt estimated at $1.2 trillion—the second largest source of consumer debt. In the absence of a comprehensive statutory or regulatory scheme governing student lending, the CFPB and state enforcement agencies have relied heavily on generic consumer protection statutes in enforcement actions.