On September 24th, 2026, the CFPB filed its appellate brief in the Seventh Circuit defending a judgment it won against a student loan debt relief operation and the individual who founded it. The underlying judgment came out of the Northern District of Illinois in May 2025 and carries roughly $2.1 million in restitution plus about $41 million in civil money penalties. The appeal asks the court to send the whole case back to square one, mostly on the argument that the default judgment entered against the corporate defendant back in February 2022 was void for bad service and should never have been the foundation for anything that followed.
The CFPB’s response is about as unforgiving as an appellate brief gets. It argues the individual has no standing to challenge a judgment entered against a company he has repeatedly said he no longer owns or controls, that he sat on the issue for three years before raising it, and that relief under Rule 60(b) is reserved for extraordinary circumstances that simply are not present. On the service question, the CFPB points out that the company was served personally through its then president, which satisfies Rule 4, and that Illinois corporate service statutes do not displace the federal rules in federal court. The dissolution argument fares no better, since an Illinois corporation remains suable for five years after dissolution and suit was filed within two months.
There has not been much noise out of the CFPB lately, and a lot of people in this industry have read that silence as the end of the story. This filing suggests otherwise. The agency is still staffed well enough to defend a five year old enforcement action through a full appellate briefing cycle, and it is doing so with familiar theories that have not softened at all. Advance fees and unsupported results claims remain the core of the case. Individual liability under the CFPA continues to track actual control rather than the name on the ownership documents, which matters for anyone who has stepped back on paper while continuing to run marketing or sales. And the legal versus equitable restitution distinction is not academic, because it is the difference between paying back net profits and paying back everything consumers handed over.