Enforcement Action (Ejudicate, Inc., d/b/a Brief)

On October 10, 2024, the Bureau issued an order against Ejudicate, Inc., d/b/a Brief, a company based in Los Angeles, California. Ejudicate is a private arbitration company that offers an online dispute resolution platform. In April 2022, Ejudicate commenced arbitration proceedings against consumers who had not agreed to be subjected to Ejudicate's authority. These arbitration proceedings related to consumers' alleged default on income share loans that had been extended by Prehired, LLC (Prehired), which operated an online training program. Prehired was the subject of a separate Bureau law enforcement action. The Bureau found that Ejudicate engaged in unfair acts and practices in violation of the Consumer Financial Protection Act of 2010 (CFPA) by commencing arbitration proceedings without consumers' consent. In fact, Ejudicate knew it did not have jurisdiction over Prehired's claims because none of the income share loans contained an arbitration clause permitting arbitration by Ejudicate. The Bureau also found that Ejudicate committed deceptive acts and practices in violation of the CFPA by misrepresenting Ejudicate's neutrality, the nature of the arbitration proceedings, and the consequences of consumers' actions or inactions in the Ejudicate forum. For example, Ejudicate falsely represented itself as a neutral and impartial forum for consumer debt arbitrations and failed to disclose that Ejudicate had financial interests aligned with the creditor, Prehired, which filed the claim against the consumer. Finally, the Bureau found that Ejudicate engaged in unfair acts and practices in violation of the CFPA by unlawfully attempting to bind consumers to Ejudicate's terms of service and platform rules, which infringed on consumers' ability to defend themselves against the claims lodged against them. The order permanently bans Ejudicate from arbitrating disputes that concern a consumer financial product or service. The order also prohibits Ejudicate from making misrepresentations to consumers in connection with any consumer financial product or service. Ejudicate must pay a civil money penalty of $1, an amount that accounts for Ejudicate's inability to pay more based on sworn financial statements that it provided to the Bureau.

Related documents

Consent Order

Stipulation

Press release

CFPB Takes Action Against Arbitration Platform Ejudicate for Deceiving Student Borrowers

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