Comments to the Federal Trade Commission Regarding Proposed Rulemaking on Deceptive or Unfair Earnings Claims

The Federal Trade Commission (FTC) is considering proposing a rule to address deceptive or unfair marketing using earnings claims. On May 10, 2022, New America, the Association of Young Americans, David Halperin, the National Consumer Law Center, Ohio State Student Association, Stephanie Hall of The Century Foundation, the Student Borrower Protection Center, The Institute for College Access and Success, Veterans Education Success, and Young Invincibles submitted public comments that highlighted the ways that misleading earnings claims can negatively impact students. In our comments, we discuss the extensive history of deceptions at institutions under the FTC's jurisdiction, why short-term programs and coding bootcamps are particular areas of concern, and how private lenders use misleading claims to entice students to take out burdensome loans.