U.S. CFPB Loan Broker Deception

On 19 September, CFPB acted against loan brokers for deceptive practices.

  • 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.

Alleged Violations

  • 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.