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Elegant Solutions Inc., Trend Capital Ltd., Dark Island Industries Inc, Heritage Asset Management, Inc., & Tribune Management, Inc

FTC v. Elegant Solutions, Inc. et al. • Case No. SACV 19-1333JVS (KESx)

They Took Your Loan Payment and Kept It

The Non-Financial Ledger: What the Dollar Figure Doesn’t Capture

Imagine you’re carrying student loan debt. Maybe it’s from a degree that didn’t pan out, or a school you attended because someone told you it would change your life. The monthly payment is crushing. You’re behind on rent. You see an ad, or you get a phone call, from something called “Federal Direct Group” or “Mission Hills Federal” or “National Secure Processing.” The name sounds official. It sounds like the government, or at least like an organization connected to it.

Someone on the phone tells you exactly what you need to hear: your payments can be reduced. Your balance could be forgiven. They’ll handle it. They’ll take over the servicing. You just need to pay a monthly fee and hand over access to your account, including your FSA ID, your Social Security number, your loan account credentials.

You give it to them. Because you are desperate, and they sound legitimate, and what they are offering is relief.

Then the months go by. Your loan balance doesn’t move. Your servicer has no record of the payments you’ve been making to “Federal Direct Group.” You call the number. Sometimes someone answers. Sometimes they don’t. You check your credit. Nothing has changed, or it has gotten worse, because the company was not making payments on your behalf in the way it promised. You gave them your FSA ID, the master key to your federal student aid account. You gave them your Social Security number. You trusted them with the financial infrastructure of your adult life.

The court document records the harm in dollar amounts. It says the defendants caused injury of at least $27,584,969. That number represents real people: people who skipped groceries to make payments that vanished, people who believed, month after month, that their loan was shrinking when it was not, people who handed over sensitive identifying information to a telemarketing operation run by executives who, the court found, had actual knowledge the whole thing was fraudulent.

Federal student debt is not like other debt. You cannot discharge it easily in bankruptcy. It follows you for decades. It accumulates interest while you sleep. For the people who called “The Student Loan Group” or “Cosmopolitan Funding Inc.” looking for a lifeline, the betrayal was not just financial. It was the specific cruelty of having your desperation weaponized. The scheme targeted people already at a disadvantage, already carrying a burden the system created, and it extracted more from them while promising the opposite.

The court’s final judgment orders defendants to destroy customer information, including Social Security numbers and FSA IDs collected during the scheme. That order does not undo the exposure. It does not answer the question of where that data went during the years the operation ran. It does not give back the months of payments. And it does not account for the people who, because they thought their loans were being managed, stopped paying attention to their actual loan servicer, and whose balances grew silently in the background while the defendants banked the fees.

Legal Receipts: What the Court Actually Said

These are verbatim findings from the Final Judgment entered by U.S. District Judge James V. Selna on July 17, 2020, Case No. SACV 19-1333JVS (KESx). The document speaks for itself.

  • This finding establishes the core fraud. All three promises (lower payments, money going to loans, taking over servicing) were either provably false or had zero evidence behind them when made to consumers. The court did not find this to be a compliance failure or a misunderstanding. It found the representations were “false or not substantiated.”
  • This constitutes a violation of Section 5(a) of the FTC Act, the primary federal prohibition against deceptive acts or practices in commerce.
  • This finding confirms the advance fee collection that violates the Telemarketing Sales Rule (TSR) Section 310.4(a)(5)(i). The TSR specifically prohibits debt relief companies from charging fees before they have actually delivered a result. These defendants collected money first, in violation of clear federal law.
  • The phrase “numerous instances” appears throughout the judgment. This is the court’s way of documenting that the conduct was not an isolated incident. It was the operating model.
  • The $31.1 million figure represents the total collected. The $408,089 in refunds is approximately 1.3% of total revenue: a rounding error. The $3.1 million actually forwarded to loan servicers is roughly 10.1% of total revenue. That means nearly 89% of what consumers paid went somewhere other than their student loans.
  • The net consumer injury of $27,584,969 is the court-determined harm after giving credit for those small fractions. This is the number the final monetary judgment was set at, held jointly and severally against all defendants.
  • “Actual knowledge” is the critical phrase. This is not the court saying these executives should have known, or were negligent, or failed to supervise properly. The court found they knew. They formulated, directed, and controlled a scheme they knew was built on false representations.
  • This finding is why individual liability attached. Each named person faces the full $27,584,969 judgment, jointly and severally, meaning the FTC can collect the entire amount from any one of them.
“Because these Corporate Defendants have operated as a common enterprise, each of them is jointly and severally liable for the acts and practices set forth in Findings 7 to 11 above.”

β€” Finding No. 12, Final Judgment
  • The five corporate defendants were not independent businesses that happened to operate in the same space. They shared owners, officers, employees, office space, and pooled money. The multiple brand names were a structural feature, making it harder for regulators and victims to trace the enterprise and creating the false appearance of variety and legitimacy.
  • Commingling of funds is a red flag that courts use to pierce the corporate veil and hold each entity liable for the actions of all. That is exactly what happened here.
Where the $31.1 Million Actually Went: Revenue Breakdown $31M $25M $17M $8M $0 $31.14M Total Collected $27.58M Net Consumer Injury (88.6%) $3.15M Paid to Loan Servicers (10.1%) $408K Refunded to Consumers (1.3%)

The Timeline: How Long This Ran Before Anyone Stopped It

The court record establishes a clear sequence of events. Elapsed time between key moments reveals how long this enterprise operated before legal accountability arrived.

Case Timeline: FTC v. Elegant Solutions, Inc. et al. Prior to July 2019 Scheme operates: consumers targeted via telemarketing with false promises of loan forgiveness and reduced payments; advance fees collected Ongoing July 8, 2019 FTC files complaint. Court enters ex parte Temporary Restraining Order with asset freeze and appointment of Receiver Thomas McNamara 9 days July 17, 2019 Stipulated Preliminary Injunction entered, continuing asset freeze and receivership terms (Dkt. No. 52) ~8 months March 9, 2020 FTC moves for summary judgment on all counts against all defendants ~4 months July 17, 2020 Final Judgment entered. $27,584,969 monetary judgment. Permanent bans on debt relief sales and telemarketing. Asset seizure from 12 bank accounts.

The Enterprise Web: Five Companies, Seven Names, Four People

This was a single operation disguised as multiple independent businesses. The court found common ownership, officers, employees, office locations, and commingled funds across all five corporate entities.

Corporate Relationship Map: The Common Enterprise INDIVIDUAL DEFENDANTS β€” ACTUAL KNOWLEDGE, DIRECTED SCHEME Mazen Radwan (aka Michael / Mike Radwan) Rima Radwan Labiba Velazquez (aka Labiba Radwan) Dean Robbins formulated, directed, controlled β€” actual knowledge COMMON ENTERPRISE Shared owners, officers, employees, offices, commingled funds Elegant Solutions, Inc. dba Federal Direct Group Trend Capital Ltd. dba Mission Hills Federal Dark Island Industries, Inc. dba Federal Direct Group / Cosmopolitan Funding Inc. Heritage Asset Management, Inc. dba National Secure Processing Tribune Management, Inc. dba The Student Loan Group collected advance fees CONSUMERS $27,584,969 net injury | SSNs and FSA IDs harvested

What You Were Told vs. What Was Actually Happening

The court established a direct gap between the representations made to consumers and documented reality. Every core sales promise was either false or unsubstantiated.

The Lie vs. The Reality: Core Sales Claims WHAT YOU WERE TOLD THE REALITY CLAIM 1: REDUCED PAYMENTS / FORGIVENESS
Your monthly payments will be reduced to a specific lower amount, or your loan balance will be forgiven in whole or in part.
COURT FINDING:
These representations were “false or not substantiated at the time Defendants made them.” (Finding No. 8)
CLAIM 2: YOUR MONEY GOES TO YOUR LOANS
Most or all of your monthly payments to us will be applied directly toward your student loans.
WHAT ACTUALLY HAPPENED:
Of $31.14M collected, only $3.15M (10.1%) reached loan servicers. 88.6% was kept as injury to consumers.
CLAIM 3: WE WILL SERVICE YOUR LOANS
We will assume responsibility for the ongoing servicing of your student loans.
COURT FINDING:
Representation was false. The court found it a deceptive act under FTC Act Section 5(a) and TSR Section 310.3(a)(2)(x).
CLAIM 4: LEGITIMATE GOVERNMENT-AFFILIATED PROGRAM
Brands: “Federal Direct Group,” “Mission Hills Federal,” “National Secure Processing,” “The Student Loan Group” β€” implying government affiliation.
WHAT THEY ACTUALLY WERE:
Five private for-profit California companies with a shared ownership group and commingled funds. No government affiliation. Permanently banned from all debt relief and telemarketing.

Societal Impact Mapping: Who Gets Hurt and How

Public Health

Financial exploitation targeting student debt holders produces documented downstream harm to mental and physical health. The people in this scheme’s crosshairs were already under significant economic stress.

  • Student loan debt is a documented source of chronic stress, anxiety, and depression. People who believed their debt was being managed, then discovered it was not, faced a compounded crisis: the original debt load plus months or years of payments lost to the scheme, plus the psychological damage of betrayal by a company that sounded like it was there to help.
  • Exposure of sensitive personal data compounds the harm. The defendants collected Social Security numbers and FSA IDs from borrowers. An FSA ID is the master credential for a person’s entire federal student aid profile. That exposure carries the potential for identity theft and financial fraud extending far beyond the original scheme, creating an ongoing threat to the health and financial security of victims.
  • People who thought their loans were being handled stopped monitoring their actual servicer accounts. During that time, interest accumulated, balances grew, and delinquency notices may have gone unread. The psychological burden of discovering this, potentially years later, represents a real and ongoing harm to wellbeing.
“Of those revenues, they have refunded approximately $408,089.00… Defendants have therefore caused consumer injury in the amount of at least $27,584,969.00.”

β€” The court put a number on it. The personal cost of discovering you were robbed while believing you were being helped has no line item.

Economic Inequality

Student loan debt relief scams are a mechanism for extracting wealth from people who already have less of it. This enterprise functioned as a direct transfer of money from stressed borrowers to a small group of executives.

  • Student loan borrowers are disproportionately lower and middle income. The telemarketing model used here specifically reaches people who are actively searching for relief, meaning the scheme’s victim pool skewed toward those already in financial distress.
  • The advance fee model is designed to extract the most money from people before they realize the service is fraudulent. Borrowers paid monthly fees for a service that was producing no results. The longer they waited, hoping their situation would improve, the more they lost.
  • The $27.58 million net injury figure represents real purchasing power removed from working people and deposited into the accounts of four named individuals and their network of five companies. That money did not circulate in communities. It was frozen by a federal court and targeted for seizure.
  • The scheme’s use of government-sounding names specifically exploited people’s trust in public institutions. Names like “Federal Direct Group” and “National Secure Processing” were chosen to create the impression of official legitimacy. This is a tactic that targets people who believe that something called “Federal Direct” must be real because the government would not allow a private company to misuse that label. That trust was weaponized.
  • Victims who cannot be located or identified for the redress fund will receive nothing. The judgment allows the FTC to apply remaining money to other consumer remedies or deposit it to the U.S. Treasury if direct restitution is impracticable. The people who lost the most may be the hardest to find, particularly if they moved, changed numbers, or gave up trying to recover.

Anatomy of the Fee: Where Your Money Actually Went

Consumers paid a monthly fee believing it covered loan payments and service delivery. The court’s financial findings reveal what that payment was actually composed of.

Breakdown Diagram: What a Consumer’s Monthly Payment Actually Funded YOUR MONTHLY PAYMENT “Debt Relief Service Fee” β€” as presented to consumers To Loan Servicers ~10.1% of total ($3,147,885) Retained by Defendants ~88.6% of total ($27,584,969 net injury) Refunded ~1.3% of total ($408,089) Telemarketing Operations Advance fees collected before any debt relief service was rendered Individual Defendant Accounts Funds at Wescom, JP Morgan Chase, OCCU, CalWest, Edward Jones, etc. CLAIMED: “Most or all of your payments go toward your student loans”

The “Cost of a Life” Metric: What the Numbers Mean in Human Terms

The court quantified the harm. Here is what those numbers translate to in everyday reality.

What Now? The Watchlist and Your Next Move

This operation has been shut down and banned, but the architecture that allowed it to exist is still in place. Here is who to watch, who to contact, and what to do if you or someone you know was targeted.

The Defendants to Watch

The following individuals are under 20-year compliance monitoring, permanent bans on debt relief sales and telemarketing, and must report any change in name, alias, address, business activity, or ownership interest within 14 days:

  • Mazen Radwan (aka Michael or Mike Radwan): Former principal of the common enterprise, subject to asset seizure at Orange County’s Credit Union (accounts xxxx8000 and xxxx3156) and JP Morgan Chase (accounts xxxx7434 and xxxx7906).
  • Rima Radwan: Individual defendant, subject to asset seizure at CalWest Bank (account xxxx3941), JP Morgan Chase (account xxxx1828), and Computershare (account xxxx5169, ordered liquidated).
  • Labiba Velazquez (aka Labiba Radwan): Individual defendant, jointly and severally liable for the full $27,584,969 monetary judgment.
  • Dean Robbins: Individual defendant, subject to asset seizure at Wescom (accounts xxxx9841 and xxxx5924), JP Morgan Chase (account xxxx5760), Edward Jones (account xxxxxx4015), and Golden 1 Credit Union (account xxx9685).

Regulatory Watchlist

These are the agencies with jurisdiction over the conduct documented in this case. If you encounter a similar scheme, these are your reporting channels:

  • Federal Trade Commission (FTC): Primary enforcer in this case. File consumer complaints at reportfraud.ftc.gov. This agency monitors compliance in this specific case at DEbrief@ftc.gov (Subject: FTC v. Elegant Solutions, et al., X190036).
  • Consumer Financial Protection Bureau (CFPB): Jurisdiction over student loan servicer abuse and debt relief scams. Submit complaints at consumerfinance.gov/complaint. The CFPB also tracks patterns of predatory telemarketing in financial services.
  • Federal Student Aid (FSA) / U.S. Department of Education: If your FSA ID was shared with any third party, change it immediately at studentaid.gov. Report unauthorized access to your federal student aid account directly to FSA.
  • State Attorney General: California’s AG and the AG in your home state have concurrent jurisdiction over consumer fraud. Many have student loan ombudsman programs specifically designed to handle debt relief scam complaints.
  • CFPB Student Loan Ombudsman: A specific office within the CFPB that handles complaints related to student loan servicer misconduct and unauthorized third-party access to loan accounts.

Grassroots Resistance and Mutual Aid

Structural change requires more than individual complaint filings. Here is how to turn this case into community protection:

  • If you or anyone you know paid fees to any of these trade names (Federal Direct Group, Mission Hills Federal, National Secure Processing, The Student Loan Group, Cosmopolitan Funding Inc.), document the payments in detail and contact the FTC. You may be eligible for restitution from the receivership fund.
  • Share this article, the case number (SACV 19-1333JVS), and the list of trade names in student debt relief forums, social media groups, and local community organizing spaces. People who were victimized years ago may not know a judgment exists or that a restitution process may be available.
  • Connect with Student Debt Crisis Center (studentdebtcrisis.org), the National Consumer Law Center (nclc.org), or your local legal aid society for free guidance on student loan rights and how to identify legitimate vs. fraudulent debt relief services.
  • If you receive an unsolicited call from any company offering student loan debt relief in exchange for upfront fees, hang up. Legitimate federal repayment programs (Income-Driven Repayment, Public Service Loan Forgiveness) are free and administered directly through studentaid.gov. Any company charging a fee to access them is a scam.
  • Organize locally: bring this case to tenant unions, labor groups, community centers, and mutual aid networks as a concrete example of how financial predators specifically target people under economic pressure. The names sounded official on purpose. That is a tactic your neighbors need to recognize.

The source document for this investigation is attached below.

sources from the source: https://www.ftc.gov/legal-library/browse/cases-proceedings/192-3105-elegant-solutions-inc-mission-hills-federal

https://www.ftc.gov/system/files/documents/cases/192_3105_mission_hills_complaint_7-11-19.pdf

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Aleeia
Aleeia

I'm Aleeia, the creator of this website.

I have 6+ years of experience as an independent researcher covering corporate misconduct, sourced from legal documents, regulatory filings, and professional legal databases.

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