- Top Notch Funding, two individuals, lied to consumers awaiting legal settlements.
- Marketed to those entitled to payment from lawsuit or victim-compensation fund.
- Firm owner Rory Donadio marketed loans with John Cavalli his business associate.
- Consumers included ex-National Football League players suffering re neurological
disorders, victims of Deepwater Horizon oil-rig disaster, and 9/11 first responders.
- Deceived consumers into thinking that firm was a lender, that could provide loans.
- It was actually a broker for others, taking commission when transaction complete.
- Lied on loan cost, told consumers they could get loan with low 2% APR or 1% rate.
- Every loan that firm brokered was more expensive, carried rate greater than 20%.
- Told consumers they could get funds almost immediately, in many cases, one hour.
- Lied that company had attorneys and accountants on staff, and offices in 50 states.
- In reality, company had no such office and no attorneys or accountants in its staff.
- Settlement required Top Notch, Donadio, and Cavalli to stop offering this loan-type.
- Company, Donadio, and Cavalli to pay $70k, company and Donadio $60k penalties.
- Cavalli to pay $10k to CFPB penalty fund; low due to the defendant inability to pay.