The Consumer Financial Protection Bureau (CFPB) has filed a complaint against Future Income Payments, LLC (FIP), Scott Kohn, and related entities, alleging that the defendants violated the Consumer Financial Protection Act of 2010, 12 U.S.C. § 5536(a)(1)(B), according to a press release. The complaint alleges that the defendants represented that their pension-advance products were not loans, were not subject to interest rates, and were comparable in cost to, or cheaper than, credit card debt when, in actuality, the pension-advance products were loans, and were subject to interest rates that were substantially higher than credit card interest rates. Additional related entities include FIP, LLC; BuySellAnnuity Inc.; Cash Flow Investment Partners LLC; Pension Advance LLC; Cash Flow Investment Partners East LLC; Cash Flow Investment Partners MidEast LLC; Lumpsum Pension Advance Atlantic LLC; Lumpsum Pension Advance Southeast LLC; Lumpsum Settlement West LLC; PAS California, LLC; PAS Great Lakes, LLC; PAS Northeast LLC; PAS Southwest LLC; Pension Advance Carolinas LLC; Pension Advance Midwest LLC; and Pension Loans South LLC. The lawsuit, filed in federal district court in the Central District of California, also alleges that the defendants violated the Truth in Lending Act (TILA), 15 U.S.C. § 1638(a)-(b), by failing to disclose a measure of the cost of credit, expressed as a yearly rate.
