They Promised to Kill Your Student Debt. They Just Took Your Money.

BCO Consulting Services, Inc. built a business on one of the most reliable raw materials in the American economy: desperation. Student loan borrowers, already ground down by a system designed to profit from their education, were targeted, charged fees, and handed nothing in return except the hollow feeling of having been played. The Federal Trade Commission filed suit. A federal court in California entered a permanent injunction. Now you get to read exactly what they did, what they admitted to, and what the system allowed them to keep.

The Non-Financial Ledger

There is a specific kind of hope that lives in a student loan borrower who picks up the phone when someone claims they can help. It is not naive hope. It is the hope of someone who has already done the math a hundred times and knows the numbers do not add up. It is the hope of someone who skips dinner so they can make a minimum payment that barely touches the principal. It is the hope of someone who went to college because they were told that was the way forward, and who now carries the debt as proof that the people who told them that were not the ones who would be paying for it.

BCO Consulting found those people. The company used telemarketing to reach them, which means someone called them, probably on an afternoon when they were tired and already calculating. The caller had a script. The script was designed to sound like the borrower was about to get real help from real professionals who understood the system. The caller may have implied government affiliation or special expertise. According to the FTC complaint, the company misrepresented material facts about what it was selling, who it was, and what consumers could expect.

The people who answered those calls paid money they did not easily have. They gave over sensitive financial information, including FSA IDs, which are the keys to a federal student loan account. They trusted that something would happen on their behalf. And then, in the way that student loan scams work, time passed. Nothing changed. The debt was still there. The interest was still compounding. The borrower was now also out whatever fee BCO had collected.

What gets lost in a settlement document is the weight of that specific sequence of events. There is no line item for the three months a borrower stopped looking at their loan balance because they thought someone was handling it. There is no dollar figure for the shame of realizing you had been conned at a moment when you were already financially vulnerable. The FTC’s number, $5,882,072.04, is the total consumer injury alleged. It is measured in dollars because that is what courts measure. But the actual cost of this scam was also measured in the time borrowers lost, the decisions they made based on false information, and the trust they extended to an industry that has spent years proving it cannot be trusted.

The people targeted by BCO were not wealthy. The settlement documents show that Clores and Bhakta’s liquidated personal assets, including cars and investment accounts, barely scratched the surface of what they owed. That gap between the judgment and what was actually collected is itself a statement about who absorbs the cost of financial fraud. It is not the defendants. It is the borrowers, who will never see full restitution, and who were already carrying debt they could not afford before the company ever called them.

The Gramm-Leach-Bliley Act violation matters here beyond the legal technicality. The FTC charged BCO with obtaining customer information by false pretenses. That means someone working for or connected to this operation accessed or attempted to access bank account routing numbers, account numbers, or login credentials by lying to consumers or to financial institutions. For a student loan borrower, your FSA ID is your entire connection to your federal loan history, your repayment status, your income-driven plan eligibility. Handing it over to someone who lied to get it is a harm that compounds over time in ways that a court-ordered settlement does not fully address.

Legal Receipts

The following quotes are drawn verbatim from Case 8:23-cv-00699-JWH-ADS, Document 66, filed October 5, 2023 in the United States District Court for the Central District of California. These are the words of the court order, not characterizations.

“The Complaint charges that Defendants participated in deceptive acts or practices in violation of Section 5(a) of the FTC Act, 15 U.S.C. § 45(a), the Telemarketing Sales Rule (the ‘TSR’), 16 C.F.R. Part 310, and Section 521 of the Gramm-Leach-Bliley Act (the ‘GLB Act’), 15 U.S.C. § 6821, in the deceptive marketing and sale of student loan debt relief services.”

• This sentence establishes that three separate bodies of federal law were violated. The FTC Act covers general deceptive practices; the Telemarketing Sales Rule specifically governs deceptive phone-based sales; the Gramm-Leach-Bliley Act covers the fraudulent acquisition of personal financial information. Three violations means BCO was not an edge-case or gray-area operation.
• The phrase “deceptive marketing and sale” is the court’s language describing what BCO actually did, not just a legal theory. The defendants stipulated to enough facts to establish jurisdiction without contesting the core substance of the complaint.

“Judgment in the amount of five million, eight hundred eighty-two thousand, seventy-two Dollars and four cents ($5,882,072.04) is entered in favor of the Commission against Settling Defendants, jointly and severally, as monetary relief.”

• “Jointly and severally” means each defendant is individually on the hook for the entire amount, not just their share. Clores could theoretically be pursued for all $5.88 million, and so could Bhakta.
• This figure, per the order itself, “represents the consumer injury alleged in the Complaint.” This is the total harm done to borrowers, by the FTC’s own accounting.

“The Commission’s agreement to the suspension of part of the judgment is expressly premised upon the truthfulness, accuracy, and completeness of Settling Defendants’ sworn financial statements and related documents… submitted to the Commission.”

• The near-six-million-dollar judgment was partially suspended based entirely on what the defendants told the FTC about their own finances. If those disclosures are later found to be inaccurate, the full amount becomes immediately due with interest.
• The order lists ten separate rounds of financial documentation exchanged between the defendants’ attorney (Brent Phillips, Phillips Law Corporation) and FTC counsel between May and July 2023. The sheer volume of back-and-forth suggests the FTC was not simply taking their word for it, but the suspension of the judgment still ultimately rests on the accuracy of those sworn statements.

“Settling Defendants are permanently restrained and enjoined from advertising, marketing, promoting, offering for sale, selling, or Assisting Others in the advertising, marketing, promoting, offering for sale, or selling, of any Secured or Unsecured Debt Relief Product or Service.”

• This is a lifetime ban from the debt relief industry, including any indirect involvement. The definition of “Assisting Others” in the order is deliberately broad: it includes customer service, marketing support, payment processing, affiliate marketing, and acting as an owner or officer of any entity in the space.
• The ban extends to telemarketing in any form, including consulting, brokering, planning, investing, or advising others about telemarketing. BCO cannot be rebuilt under a different name by the same people.

“Settling Defendants are permanently restrained and enjoined from… Obtaining, or attempting to obtain customer information of a financial institution (including bank account routing number, account number, or log-in credentials) from a consumer by making false, fictitious, or fraudulent representations to any consumer or financial institution.”

• The fact that this prohibition needed to be explicitly written into the permanent order confirms that BCO, or parties connected to it, was engaged in pretexting: lying to extract sensitive financial credentials from borrowers or banks.
• The specific enumeration of “FSA ID” in the customer information section of the order (Section VIII.B) confirms that federal student loan account access codes were among the data this operation was collecting under false pretenses.

“The facts alleged in the Complaint establish all elements necessary to sustain an action by the Commission 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.”

• This is a bankruptcy-proofing clause. Section 523(a)(2)(A) covers debts obtained by fraud, false pretenses, or false representations. The order pre-establishes that the facts here meet that standard, so if Clores or Bhakta files for bankruptcy, they cannot discharge this debt by arguing the fraud was not proven.
• The inclusion of this clause is significant: it means the FTC anticipated the possibility that the defendants might try to use bankruptcy to escape the suspended judgment, and closed that door in advance.

Societal Impact Mapping

BCO Consulting did not operate in a vacuum. Student loan scams are a systemic product of a broken debt economy, and their damage spreads across multiple categories of real-world harm.

Public Health

Financial fraud targeting student loan borrowers compounds mental health burdens that are already documented and severe in this demographic.

• Student loan debt is consistently linked to elevated rates of anxiety, depression, and stress-related physical illness. Borrowers who believed they were receiving help, only to discover they had been scammed, face an additional trauma layer: the discovery that the system exploited their vulnerability rather than addressing it.
• The specific populations most vulnerable to student loan scams, first-generation college graduates, borrowers from lower-income households, and those with larger debt-to-income ratios, are already at higher risk for financial stress-related health deterioration. BCO’s targeting through telemarketing optimized for reaching these groups.
• Victims who handed over FSA IDs and bank credentials faced compounding anxiety from identity exposure, a documented driver of chronic stress. The unauthorized access or potential misuse of those credentials creates an open-ended threat that does not resolve when the scam is discovered.
• The 20-year compliance monitoring period in this order exists precisely because the FTC recognizes these operators do not simply stop. The ongoing risk of re-victimization by the same or similar operators is a documented public health-adjacent concern in consumer protection enforcement.

Economic Inequality

The economic harm of this scam flows predictably downward, from a company collecting fees to borrowers who could not afford to lose them.

• The total consumer injury of $5,882,072.04 was collected from student loan borrowers, a population already carrying structurally depressed household wealth due to the student debt burden itself. These are dollars extracted from people who have less, transferred to operators who parlayed them into Porsche Caymans, multi-account brokerage portfolios, and real property holdings.
• The suspension of the majority of the judgment means BCO’s principals were not required to disgorge the full amount of harm they caused. The gap between $5.88 million in proven consumer harm and the small cash amounts Clores and Bhakta personally transferred represents wealth that was simply not recovered.
• Student loan debt relief scams disproportionately target borrowers who cannot afford to consult an attorney or financial advisor, making them dependent on cold-call services they have no good mechanism to vet. This information asymmetry is itself a product of economic inequality.
• The defendants’ asset portfolio, documented through Chase, Bank of America, Navy Federal, TD Ameritrade, Webull accounts, plus a Porsche, a BMW (referenced in BMW Financial Services statements), and real property, illustrates the wealth accumulation possible for operators of these schemes. The borrowers they defrauded are statistically unlikely to hold comparable asset portfolios at any point in their financial lives.
• The Gramm-Leach-Bliley pretexting violation carries additional economic inequality weight: low-income borrowers whose bank credentials are compromised often lack the financial buffer to absorb the consequences of unauthorized account access, while high-net-worth individuals can more easily detect and recover from such breaches.
• Consumer restitution under this order is explicitly contingent on practicability. The order states that if the FTC determines direct restitution is “wholly or partially impracticable,” remaining funds go to related relief or the U.S. Treasury. Borrowers may never see a direct payment, even from the amounts that were seized.

The “Cost of a Life” Metric

What Now?

BCO Consulting is wound down, but the conditions that made it possible, an unaffordable student debt system, a telemarketing industry that preys on borrowers, and settlements that let operators keep most of what they took, remain fully intact. Here is who to watch and what to do.

Named Parties Under Permanent Injunction

• Brandon Clores — Individual Defendant, officer of BCO Consulting Services, Inc. Permanent ban on debt relief and telemarketing. Compliance reporting for 20 years.
• Kishan Bhakta — Individual Defendant, officer of BCO Consulting Services, Inc. Same permanent bans and reporting obligations as Clores.
• Gianni Olilang and Allan Radam — Named as Individual Defendants in the complaint but are not settling parties under this order. Their liability was not resolved by Document 66.
• BCO Consulting Services, Inc. and SLA Consulting Services Inc. — Both corporate defendants are under the receivership of Thomas McNamara for liquidation.

Regulatory Watchlist

• FTC Bureau of Consumer Protection — Primary enforcement body in this case. To report student loan scams, contact reportfraud.ftc.gov. Reference case number X230027 when submitting related complaints about these defendants.
• CFPB (Consumer Financial Protection Bureau) — The CFPB holds direct jurisdiction over student loan servicers and debt relief companies. File complaints at consumerfinance.gov/complaint for any company charging upfront fees for student loan help or claiming government affiliation.
• U.S. Department of Education Federal Student Aid (FSA) — If your FSA ID was shared with a third party under false pretenses, contact FSA immediately at studentaid.gov to change your credentials and review account activity. FSA IDs give full access to your federal loan history and repayment options.
• State Attorney General offices — California AG and the AGs of states where BCO operated have concurrent jurisdiction over telemarketing fraud. State-level action can address harms that federal settlements leave unresolved.
• FTC Telemarketing Sales Rule Enforcement — The TSR explicitly prohibits charging upfront fees for debt relief services before any service is delivered. Any debt relief company demanding payment before showing results is operating illegally under federal law.

Mutual Aid, Organizing, and Direct Action

• Share the FTC’s free student loan help resources with your network. The government’s actual student loan programs, including income-driven repayment plans and Public Service Loan Forgiveness, are free to apply for at studentaid.gov. No company needs to charge you to access them.
• Build a local student debt mutual aid group with people in your community. Share information on navigating federal loan programs, IDR applications, and how to spot scams. Peer-to-peer financial literacy is a direct counter to the information asymmetry these operators exploit.
• Document and report every unsolicited debt relief call you receive. The FTC’s Do Not Call registry and complaint database are enforcement tools. Every report is a data point. File at donotcall.gov.
• Connect with organized student debt cancellation movements. Groups like the Debt Collective work to challenge the structural conditions that make scams like BCO’s possible in the first place. Organizing around debt abolition addresses the root cause rather than the symptoms.
• If you were a BCO customer, contact the FTC at DEbrief@ftc.gov and reference case X230027. Redress funds from the seized assets may be administered for consumer relief, but you need to be in the record to access them.