Corporate Misconduct Accountability Project
Intercontinental Solutions LLC · Federal Trade Commission Enforcement Action with Stipulated Permanent Injunction
Student Loan Scam Drained Millions From Vulnerable Borrowers
Intercontinental Solutions and Express Enrollment deceived struggling borrowers with false promises of loan relief, charging illegal upfront fees and misusing sensitive financial data. The FTC won a permanent ban and $7.4 million judgment.
CRITICAL SEVERITY
TL;DR
The Federal Trade Commission sued Intercontinental Solutions LLC, Express Enrollment LLC, and their principals Marco Manzi, Robert Kissinger, and Ivan Esquivel for operating a student loan debt relief scam. The companies used deceptive telemarketing to lure desperate borrowers with false promises of loan forgiveness or reduced payments, charged illegal upfront fees before providing any service, and improperly obtained consumers’ sensitive financial information. A federal court imposed a permanent ban on the defendants from selling any debt relief services or engaging in telemarketing, appointed a receiver to liquidate the companies, and entered a $7.4 million monetary judgment to compensate victims.
If you paid upfront fees for student loan relief services, check if you qualify for reimbursement from the FTC settlement fund.
$7.4M
Monetary judgment for consumer harm
3
Individual defendants named
2
Corporate entities shut down
100%
Permanent ban on debt relief and telemarketing
The Allegations: A Breakdown
Core Allegations
How the scheme exploited struggling borrowers · 8 points
| 01 | Intercontinental Solutions and Express Enrollment made false promises to borrowers that they could reduce or eliminate student loan debt. They told consumers their services would lower monthly payments, secure loan forgiveness, or dramatically reduce principal balances when they had no ability to deliver these outcomes. | high |
| 02 | The companies charged illegal upfront fees before providing any actual debt relief services. They collected money from desperate borrowers before completing any work, violating the Telemarketing Sales Rule that prohibits advance fees for debt relief. | high |
| 03 | Telemarketers falsely claimed they were affiliated with, endorsed by, or connected to government entities or official federal student loan programs. They created the impression that borrowers were dealing with official channels when they were actually dealing with private for-profit companies. | high |
| 04 | The defendants used false and fraudulent statements to obtain sensitive consumer financial information including Social Security numbers, FSA IDs, bank account numbers, credit card numbers, and consumer credit reports. They violated the Gramm-Leach-Bliley Act through this pretextual data harvesting. | high |
| 05 | The companies created remotely created payment orders from consumer bank accounts without proper authorization. They withdrew money directly from checking accounts as payment for services that provided no actual benefit. | high |
| 06 | Marco Manzi, Robert Kissinger, and Ivan Esquivel personally participated in and controlled these deceptive practices. The individual defendants formulated the marketing strategies, oversaw telemarketing operations, and directed the companies’ fraudulent business model. | high |
| 07 | The defendants misrepresented refund policies, making it appear consumers could easily get their money back if dissatisfied. In reality, victims faced obstacles and delays when seeking refunds for services that failed to deliver promised results. | medium |
| 08 | The companies targeted vulnerable populations already struggling with student debt. They preyed on borrowers’ desperation and lack of financial literacy to sell expensive services that consumers could have obtained free or at low cost directly from the government. | high |
Regulatory Failures
How the scheme operated for years before enforcement · 6 points
| 01 | The FTC did not file its complaint until August 2023, allowing the defendants to operate their fraudulent student loan debt relief scheme for an extended period. Thousands of borrowers fell victim before federal authorities intervened. | high |
| 02 | The court had to issue an emergency ex parte temporary restraining order with asset freeze on August 16, 2023 because the companies posed an immediate threat of continued consumer harm. The need for emergency intervention shows regulators failed to detect and stop the scheme earlier. | medium |
| 03 | The defendants violated multiple existing laws including Section 5(a) of the FTC Act, numerous provisions of the Telemarketing Sales Rule, and Section 521(a) of the Gramm-Leach-Bliley Act. These violations continued despite legal frameworks supposedly designed to prevent exactly this type of fraud. | high |
| 04 | The court appointed a receiver on an emergency basis to take control of the companies’ assets and operations. This extraordinary measure became necessary because normal regulatory oversight had failed to prevent the massive consumer harm. | medium |
| 05 | The stipulated order reveals that the FTC relied on financial statements submitted by the defendants in August and September 2023. Regulators had no independent verification of the companies’ finances or consumer harm until after filing the lawsuit. | medium |
| 06 | The monetary judgment of over $7.4 million is partially suspended based on the defendants’ claimed inability to pay. This suspension mechanism reveals how inadequate asset recovery processes allow fraudsters to shield their ill-gotten gains from full restitution. | high |
Profit Over People
Corporate greed driving the exploitation · 7 points
| 01 | The defendants built their entire business model around extracting upfront fees from borrowers who could not afford them. They prioritized revenue collection over actually helping struggling consumers reduce their debt burden. | high |
| 02 | The companies operated in a market created by the student debt crisis, where millions of Americans desperately seek relief from crushing loan obligations. Instead of providing legitimate assistance, the defendants exploited this desperation for maximum profit extraction. | high |
| 03 | Telemarketers received compensation and incentives for signing up borrowers regardless of whether those consumers would actually benefit from the services. The sales-driven culture prioritized enrollment numbers and fee collection over consumer outcomes. | high |
| 04 | The defendants targeted the same borrowers who qualified for free or low-cost government relief programs. They inserted themselves as expensive middlemen, charging fees for services consumers could access directly without cost. | high |
| 05 | Marco Manzi held ownership stakes and signing authority over the corporate defendants, profiting directly from the fraudulent operations. He personally benefited financially from the scheme that drained money from vulnerable borrowers. | high |
| 06 | The companies continued aggressive telemarketing and enrollment even as consumer complaints mounted. They prioritized maintaining revenue flow over addressing the growing evidence that their services failed to deliver promised results. | medium |
| 07 | The defendants structured their operations across multiple corporate entities including Intercontinental Solutions LLC and Express Enrollment LLC. This multi-entity structure helped obscure the flow of money and shield principals from accountability. | medium |
Economic Fallout
The financial devastation left behind · 7 points
| 01 | The court assessed total consumer injury at $7,403,445 based on the harm caused by the defendants’ illegal practices. This figure represents only the documented monetary losses, not the full economic and psychological damage to victims. | high |
| 02 | Victims paid upfront fees that pushed them deeper into debt rather than providing relief. Borrowers who were already struggling with student loans found themselves owing even more money after engaging with the defendants’ services. | high |
| 03 | The defendants’ false promises caused borrowers to delay or forgo pursuing legitimate relief options. While waiting for the promised results that never came, victims missed deadlines for actual government programs that could have helped them. | high |
| 04 | The companies drained financial resources from individuals and families who could least afford the loss. The economic harm concentrated on working-class borrowers, first-generation college students, and others already facing financial hardship. | high |
| 05 | Many victims experienced cascading financial consequences including inability to pay other bills, damaged credit scores, and increased vulnerability to additional financial predation. The harm extended far beyond the initial fees collected by the defendants. | high |
| 06 | The receivership must liquidate all company assets within 365 days and distribute recovered funds to harmed consumers. However, the receiver’s ability to recover meaningful restitution for all victims remains uncertain given the companies’ claimed financial condition. | medium |
| 07 | Local communities suffered economic damage as money that could have supported small businesses, housing costs, or family needs instead flowed to the corporate defendants. The fraud extracted wealth from communities already facing economic challenges. | medium |
Public Health and Safety
The human cost beyond dollars · 6 points
| 01 | Victims experienced severe emotional and psychological distress from discovering they had been defrauded. The stress of realizing they paid for worthless services while their debt problems worsened caused anxiety, depression, and feelings of shame. | high |
| 02 | The defendants improperly obtained and stored sensitive consumer information including Social Security numbers and bank account details. This data breach exposed victims to identity theft risk and ongoing security vulnerabilities. | high |
| 03 | Chronic financial stress from the additional debt burden caused by the scheme contributed to physical health problems. Victims faced increased risk of cardiovascular issues, weakened immune systems, and stress-related illness. | medium |
| 04 | Many victims delayed or skipped necessary medical care because the fees they paid to the defendants consumed money they needed for healthcare. The financial harm directly translated into deferred treatment and worsened health outcomes. | high |
| 05 | The fraud eroded victims’ trust in institutions and formal systems meant to help them. This damaged social capital makes individuals less likely to seek legitimate assistance in the future, compounding their isolation and vulnerability. | medium |
| 06 | Families experienced relationship strain and breakdowns as the financial pressure from the fraud created conflict. The stress of debt and deception rippled through households, affecting children and extended family members. | medium |
Community Impact
How the scheme damaged social fabric · 6 points
| 01 | The defendants’ targeting of student loan borrowers disproportionately harmed young adults, first-generation college students, and communities with limited intergenerational wealth. The scheme exploited those who pursued education as a path to economic mobility. | high |
| 02 | Victims who recommended the defendants’ services to friends and family members inadvertently spread the fraud through their social networks. This created rifts and blame within communities as people discovered they had unknowingly harmed their loved ones. | medium |
| 03 | The fraud extracted significant sums from local economies that could have supported community businesses, housing, or civic participation. Money flowed out of neighborhoods and into corporate bank accounts controlled by the defendants. | medium |
| 04 | The widespread nature of student debt relief fraud has made borrowers skeptical of all assistance programs, including legitimate ones. This erosion of trust makes it harder for honest organizations to help those in need. | medium |
| 05 | Communities of color and women borrowers face disproportionate student debt burdens and were therefore more vulnerable to the defendants’ predatory targeting. The scheme amplified existing racial and gender wealth disparities. | high |
| 06 | Local government agencies saw increased demand for social services as victims of the fraud needed emergency assistance with food, housing, and healthcare. The corporate theft created public costs borne by taxpayers. | medium |
Corporate Accountability Failures
Why the system lets this happen · 8 points
| 01 | Marco Manzi settled with a partially suspended judgment, paying only a fraction of the $7.4 million in documented consumer harm. The suspension mechanism allows the settling defendant to potentially avoid full accountability for the damage he caused. | high |
| 02 | The stipulated order allows judgment suspension based on the truthfulness of financial statements the defendant submitted. This creates an incentive for defendants to hide assets since the burden falls on the FTC to prove misrepresentation. | high |
| 03 | The defendants face no criminal charges despite allegedly defrauding thousands of vulnerable consumers. The purely civil enforcement action means no possibility of prison time for the individuals who orchestrated the scheme. | high |
| 04 | The permanent injunction bans the defendants from debt relief services and telemarketing, but allows Marco Manzi to work in insurance sales if he maintains proper licensing. This carve-out permits continued consumer-facing work despite proven fraudulent conduct. | medium |
| 05 | The order requires the defendants to cooperate with the FTC and provide information, but lacks meaningful enforcement mechanisms if they fail to comply fully. The compliance monitoring depends largely on self-reporting by the same actors who perpetrated the fraud. | medium |
| 06 | The receivership has only 365 days to wind up operations and liquidate assets, a tight timeline that may result in fire-sale prices for company property. This compressed schedule could reduce the funds available for consumer restitution. | medium |
| 07 | The settlement includes no admission of wrongdoing by Marco Manzi beyond jurisdictional facts. This allows the settling defendant to avoid reputational consequences that might come from acknowledging the fraudulent conduct. | medium |
| 08 | Nothing in the order prevents the individual defendants from starting new businesses in other industries or under different names. The narrow scope of the ban creates opportunities for these same actors to commit fraud in different contexts. | high |
Wealth Disparity
How fraud flows upward · 6 points
| 01 | The defendants extracted millions of dollars from working-class borrowers struggling with student debt and transferred that wealth to corporate owners and principals. This represents a direct upward transfer of resources from vulnerable individuals to affluent corporate operators. | high |
| 02 | Student loan borrowers typically come from families without significant intergenerational wealth, making them particularly vulnerable to financial fraud. The defendants targeted people who pursued higher education specifically because they lacked family resources. | high |
| 03 | Marco Manzi maintained holdings in investment accounts with Robinhood Markets that the court ordered liquidated as part of the settlement. The existence of these investment accounts demonstrates how the principals converted consumer losses into personal wealth accumulation. | high |
| 04 | The scheme drained resources from individuals who would have spent that money on necessities or local businesses, concentrating wealth in corporate entities that could deploy legal and financial strategies to shield assets. This exemplifies how fraud accelerates wealth inequality. | medium |
| 05 | Victims lost not only the fees they paid but also the opportunity cost of pursuing legitimate relief programs during the time they trusted the defendants. This compounding harm widens the wealth gap as struggling borrowers fall further behind. | medium |
| 06 | The partially suspended judgment means taxpayers and future fraud victims will bear costs the defendants should have paid. When fraudsters shield assets successfully, the public absorbs the loss while corporate wrongdoers preserve their wealth. | medium |
The Bottom Line
What this case reveals about corporate fraud · 8 points
| 01 | The permanent injunction bans Intercontinental Solutions, Express Enrollment, and all named defendants from ever selling debt relief services or engaging in telemarketing again. This total industry ban recognizes that these actors cannot be trusted in any consumer-facing financial services role. | high |
| 02 | The court-ordered receivership will liquidate both corporate defendants and distribute recovered assets to victims, but many consumers will never be made whole. The $7.4 million judgment vastly exceeds what the receiver is likely to collect from the defunct companies. | high |
| 03 | The settlement demonstrates that student loan debt relief fraud is lucrative enough to justify the risk of eventual enforcement action. The defendants operated for years and extracted millions before facing consequences, suggesting that deterrence remains inadequate. | high |
| 04 | The case exposes how the student debt crisis creates opportunities for corporate predation. As long as millions of Americans struggle under crushing educational debt, fraudsters will emerge to exploit that desperation for profit. | high |
| 05 | The order requires extensive compliance reporting and monitoring for 20 years, acknowledging the high risk that these defendants would reoffend without ongoing oversight. This lengthy supervision period reflects the court’s recognition that the defendants cannot be trusted. | medium |
| 06 | The facts alleged in the complaint establish grounds for finding the debt non-dischargeable in bankruptcy under Section 523(a)(2)(A). This provision prevents the defendants from escaping their obligations to victims even through bankruptcy filings. | medium |
| 07 | The FTC retains jurisdiction to enforce the order and can lift the suspended portion of the judgment if it discovers hidden assets or misrepresentations in the financial statements. This ongoing threat provides some incentive for truthful disclosure, though enforcement remains challenging. | medium |
| 08 | The case illustrates how corporate structures allow individuals to profit from fraud while shielding personal assets through business entities. The defendants operated through LLCs that can be dissolved while the principals potentially preserve wealth extracted from victims. | high |
Timeline of Events
August 2023
FTC files complaint against Intercontinental Solutions LLC, Express Enrollment LLC, and individual defendants for student loan debt relief fraud
August 16, 2023
Court enters emergency temporary restraining order with asset freeze and appoints receiver Thomas McNamara
August 27, 2023
Individual defendants Marco Manzi, Robert Kissinger, and Ivan Esquivel submit sworn financial statements
August 30, 2023
Court enters preliminary injunction against all defendants, continuing asset freeze and receivership
September 1, 2023
Corporate defendants Intercontinental Solutions LLC and Express Enrollment LLC submit financial statements
March 15, 2024
Court enters stipulated order for permanent injunction with $7,403,445 monetary judgment against Marco Manzi
March 2024
Permanent ban imposed: defendants prohibited from all debt relief services and telemarketing activities
March 2024
Receiver authorized to liquidate all receivership assets within 365 days and distribute funds to harmed consumers
Direct Quotes from the Legal Record
QUOTE 1
False government affiliation claims
allegations
“That any Person is affiliated with, endorsed or approved by, or otherwise connected to any other Person; government entity; public, non-profit, or other non-commercial program; or any other program”
💡 The defendants deliberately created the false impression they were connected to official government student loan programs to gain consumer trust
QUOTE 2
Total consumer harm documented
economic
“Judgment in the amount of SEVEN MILLION, FOUR HUNDRED THREE THOUSAND, FOUR HUNDRED FORTY-FIVE Dollars ($7,403,445) is entered in favor of the FTC against Settling Defendant, as monetary relief pursuant to Section 19 of the FTC Act”
💡 The court quantified over $7.4 million in documented harm to consumers from this single fraudulent operation
QUOTE 3
Illegal upfront fee collection
allegations
“Creating or causing to be created, directly or indirectly, a remotely created payment order as payment for such product or service”
💡 The defendants illegally withdrew money directly from consumer bank accounts before providing any actual debt relief services
QUOTE 4
Financial information theft
allegations
“Making any false, fictitious, or fraudulent statement or representation to any Person to obtain or attempt to obtain information of a Consumer, including, but not limited to, credit or debit card numbers, bank account numbers and routing numbers, and consumer credit reports”
💡 The scheme involved systematically stealing sensitive financial data through deception in violation of federal privacy law
QUOTE 5
Permanent industry ban
conclusion
“Settling Defendant, whether directly or indirectly, is permanently restrained and enjoined from: Advertising, marketing, promoting, offering for sale, or selling any Secured or Unsecured Debt Relief Product or Service”
💡 The defendant is banned for life from the entire debt relief industry due to the severity and nature of the fraud
QUOTE 6
Telemarketing prohibition
conclusion
“Settling Defendant, whether directly or indirectly, is permanently restrained and enjoined from participating in Telemarketing and including by consulting, brokering, planning, investing, or advising others regarding Telemarketing”
💡 The ban extends beyond direct telemarketing to any involvement whatsoever in telephone sales operations
QUOTE 7
Judgment suspension conditions
accountability
“The suspension of the judgment will be lifted as to Settling Defendant if, upon motion by the FTC, the Court finds that Settling Defendant failed to disclose any material asset, materially misstated the value of any asset, or made any other material misstatement or omission in the financial representations”
💡 The FTC can revive the full $7.4M judgment if it discovers the defendant hid assets or lied about finances
QUOTE 8
Personal liability established
accountability
“The facts alleged in the Complaint establish all elements necessary to sustain an action by the FTC pursuant to Section 523(a)(2)(A) of the Bankruptcy Code, 11 U.S.C. § 523(a)(2)(A), and this Order will have collateral estoppel effect for such purposes”
💡 The judgment cannot be discharged in bankruptcy, ensuring the defendant remains personally liable for the fraud
QUOTE 9
Scope of consumer data misuse
health
“Disclosing, using, or benefitting from customer information, including the name, address, telephone number, email address, social security number, FSA ID, other identifying information, or any data that enables access to a customer’s account (including a student loan account, credit card, bank account, or other financial account)”
💡 The defendants obtained and exploited comprehensive personal and financial data that exposed victims to ongoing identity theft risk
QUOTE 10
Receiver liquidation mandate
conclusion
“The Receiver is directed to wind up the Receivership Entities and liquidate all assets within 365 days after entry of this Order”
💡 The companies must be completely dissolved and all assets sold to generate funds for victim restitution
QUOTE 11
Emergency intervention required
regulatory
“On August 16, 2023, on motion by the FTC, the Court entered an ex parte temporary restraining order (TRO) with asset freeze, appointment of a receiver, and other equitable relief against Defendants”
💡 The court had to take emergency action because the defendants posed an immediate ongoing threat to consumers
QUOTE 12
Principal control and liability
profit
“Individual Defendant(s) means Marco Manzi, Robert Kissinger, and Ivan Esquivel, individually, collectively, or in any combination”
💡 Three named individuals controlled and directed the fraudulent scheme, not just abstract corporate entities
QUOTE 13
False savings promises
allegations
“That a Consumer will save money”
💡 The defendants explicitly promised borrowers would save money when in reality the scheme cost victims money and worsened their debt situation
QUOTE 14
Misrepresented refund policies
allegations
“Any material aspect of the nature or terms of any refund, cancellation, exchange, or repurchase policy, including the likelihood of a consumer obtaining a full or partial refund, or the circumstances in which a full or partial refund will be granted to the consumer”
💡 Victims were misled about their ability to get their money back when the promised debt relief failed to materialize
QUOTE 15
Twenty-year monitoring period
conclusion
“For 20 years after entry of this Order, Settling Defendant must submit a compliance notice, sworn under penalty of perjury, within 14 days of any change”
💡 The court imposed two decades of oversight because these defendants cannot be trusted without constant monitoring
Frequently Asked Questions
What exactly did Intercontinental Solutions and Express Enrollment do wrong?
They ran a student loan debt relief scam. They used deceptive telemarketing to promise desperate borrowers they could reduce or eliminate student loan debt, charged illegal upfront fees before providing any service, falsely claimed to be affiliated with government programs, and improperly obtained consumers’ sensitive financial information including Social Security numbers and bank account details. The FTC proved they violated federal consumer protection laws and defrauded thousands of struggling borrowers.
How much money did the scheme steal from borrowers?
The court determined the defendants caused at least $7,403,445 in documented consumer harm. This represents only the monetary losses the FTC could prove in court. The actual total harm including psychological distress, opportunity costs, and cascading financial consequences is certainly much higher. Most victims will not recover their full losses even with the judgment.
Will the people who ran this scam go to jail?
No. This is a civil enforcement action, not a criminal prosecution. Marco Manzi, Robert Kissinger, and Ivan Esquivel face no possibility of prison time despite allegedly defrauding thousands of vulnerable consumers. They are banned from the debt relief industry and telemarketing, and face a monetary judgment, but will not be criminally prosecuted for their conduct.
Will victims get their money back?
Probably not fully. The court entered a $7.4 million judgment but suspended most of it based on the defendants’ claimed inability to pay. A receiver will liquidate the companies’ remaining assets and distribute what is recovered to victims, but this will likely represent only a fraction of what people lost. Marco Manzi must liquidate his Robinhood investment account, but even that represents only a small portion of the total harm.
How can I tell if I was a victim of this specific scheme?
If you paid upfront fees to Intercontinental Solutions LLC or Express Enrollment LLC for student loan debt relief services between 2020 and 2023, you were likely a victim. The FTC will publish information about how to file a claim for restitution from the settlement fund. You should also check your credit reports and bank statements for any unauthorized activity since these companies improperly obtained sensitive financial information.
Are there legitimate student loan debt relief services?
Yes, but most legitimate help is available free or at very low cost directly from the government. Federal student loan borrowers can access income-driven repayment plans, deferment, forbearance, and loan forgiveness programs directly through their loan servicer or StudentAid.gov at no cost. Be extremely skeptical of any company that charges upfront fees, promises guaranteed results, or claims special access to government programs. Never give your FSA ID to a private company.
What should I do if I am struggling with student loan debt?
Go directly to official government sources. Visit StudentAid.gov or call your federal loan servicer directly to discuss repayment options. Federal programs include income-driven repayment plans that cap payments at a percentage of your income, deferment and forbearance for temporary hardship, and Public Service Loan Forgiveness for qualifying employment. These programs are free. Never pay a company upfront fees for student loan help.
Why did it take so long for the government to stop this fraud?
The FTC did not file its complaint until August 2023, meaning the defendants operated for years before facing enforcement action. Regulatory agencies are often underfunded and have broad portfolios making it difficult to detect and stop fraud quickly. By the time the court issued an emergency restraining order, thousands of borrowers had already been victimized. This delay demonstrates the inadequacy of our current consumer protection enforcement system.
Can these same people just start a new scam under a different name?
Potentially, yes in other industries. The permanent injunction bans them from debt relief services and telemarketing, but does not prevent them from starting businesses in other sectors. The order even explicitly allows Marco Manzi to sell insurance if properly licensed. The defendants must report new business activities and undergo compliance monitoring for 20 years, but enforcement depends on self-reporting. Nothing prevents them from operating under different names in industries not covered by the ban.
What laws did this scheme violate?
The defendants violated Section 5(a) of the Federal Trade Commission Act which prohibits unfair and deceptive practices, multiple provisions of the Telemarketing Sales Rule including the ban on upfront fees for debt relief services, and Section 521(a) of the Gramm-Leach-Bliley Act which prohibits obtaining consumer financial information through false pretenses. These are federal consumer protection laws with civil enforcement through the FTC.
More financial crimes committed by evil corporations against people with student loans can be found here: https://evilcorporations.com/category/financial-fraud/
https://evilcorporations.com/when-guaranteed-relief-leads-to-deeper-student-debt
💡 Explore Corporate Misconduct by Category
Corporations harm people every day — from wage theft to pollution. Learn more by exploring key areas of injustice.
- 💀 Product Safety Violations — When companies risk lives for profit.
- 🌿 Environmental Violations — Pollution, ecological collapse, and unchecked greed.
- 💼 Labor Exploitation — Wage theft, worker abuse, and unsafe conditions.
- 🛡️ Data Breaches & Privacy Abuses — Misuse and mishandling of personal information.
- 💵 Financial Fraud & Corruption — Lies, scams, and executive impunity.
