Westwood College Borrower Defense Executive Summary Pursuant to 34 C.F.R. §685.222(e)(3), the Department of Education (“Department”) is charged with conducting a fact-finding process to determine whether each borrower defense application states a basis for a borrower defense. In adjudicating each individual borrower defense application, the Department must consider not only the borrower’s application and accompanying evidence, but also any relevant information in records in the possession of the Department and in submissions from the school, as well as any other information obtained in connection with the fact-finding process. The Borrower Defense Group (“BDG”) has completed a review of the evidence within the Department’s possession relating to Westwood College (“Westwood”) as it relates to four issues: 1) Westwood’s operational and procedural history; 2) Westwood’s aggressive recruitment practices; 3) Westwood’s misrepresentations about borrowers’ employment prospects in law enforcement in Illinois if enrolled in Westwood’s Criminal Justice program; and 4) Westwood’s misrepresentations about the transferability of Westwood’s credits. Additional summaries regarding specific types of borrower claims are forthcoming and will be submitted for approval separately. Westwood operated campuses in six states and operated an online program. In 2010, Westwood enrolled approximately 19,190 students. To date, the Department has received over 5,000 borrower defense applications relating to Westwood. Applying a preponderance of the evidence standard, BDG has prepared a series of summaries of the evidence relating to Westwood. Together, these summaries form a common statement of facts that will be applied in the individual adjudication of borrower defense applications from Westwood borrowers that are adjudicated pursuant to 34 C.F.R. §685.206(c), 685.206(d), and/or 685.206(e) based on the dates of the loans relating to the borrowers’ claims. Westwood’s Operational and Procedural History This section describes Westwood’s scope of operations; investigations by the Colorado and Illinois Attorneys General into Westwood’s recruiting and enrollment practices; and accreditation history, including its attempt to gain regional accreditation and its transition from one national accrediting agency to another. This section provides an overview of additional investigations conducted by various state and federal agencies into Westwood. Westwood Trained Admissions Representatives in Aggressive Sales Tactics and Pressured Them to Enroll as Many Students as Possible This section describes how Westwood trained employees to implement aggressive sales tactics and cultivated a high-pressure sales environment where recruiters made false or misleading statements to prospective students to persuade them to enroll. It establishes by a preponderance of the evidence that Westwood engaged in the following conduct on a widespread basis: • Westwood’s admissions representatives were trained to build a rapport with prospective students, which allowed them to identify and manipulate the prospective students’ motivations or emotional “drivers” to persuade them to enroll; • Admissions representatives presented Westwood to prospective students as a selective institution, creating a sense of urgency for students to enroll during the initial call or meeting with the admissions representative, before classes filled up; • Admissions representatives rushed students through the process of filling out their enrollment paperwork, and did not explain or provide students time to read any disclosures included in the paperwork; and • Westwood trained its admissions representatives not to take “no” for an answer, instead providing them with scripted responses for any reason a prospective student might offer for not wanting to enroll on the spot. Westwood Misled Prospective Students to Believe That Its Criminal Justice Degree Would Make Them Eligible to Work as Police Officers in Illinois This section explains that from May of 2004 to November of 2015, Westwood misrepresented to prospective Illinois Criminal Justice students that they would be able to obtain employment as police officers in Illinois, particularly in the Chicago area. Westwood made these representations through its television advertising, internet marketing, and through the direct statements of its admissions representatives during telephone calls and in-person meetings with prospective students on a widespread basis. In fact, major law enforcement employers in the Chicago area, including the Chicago Police Department and the Illinois State Police, required candidates for police officer positions to possess a minimum number of credit hours or a degree from a regionally accredited college. Westwood knew that this regional accreditation requirement applied to most police officer jobs in Illinois, particularly in the Chicago area. Westwood was never regionally accredited; instead, it was nationally accredited. Thus, Westwood graduates were not eligible for most police officer jobs in the Chicago area. Even though Westwood graduates may have possessed the minimum stated requirements for some police officer positions (for example, in 2010, the Chicago Police Department changed its job requirements to state that candidates with credit hours from nationally accredited institutions would be considered), such a small percentage of Westwood graduates gained employment in police officer positions that Westwood’s representations that they could become police officers were still misleading. Westwood Misled Prospective Students Across All Westwood Campuses from 2002 through 2015 Regarding the Transferability of Westwood’s Credits This section discusses several ways that Westwood misrepresented the transferability of its credits to other institutions. The evidence in BDG’s possession relating to this conduct establishes by a preponderance of the evidence that: • Westwood’s academic credits rarely transferred to other institutions, and Westwood knew its credits rarely transferred. • Between at least 2002 and 2015, Westwood made widespread misrepresentations to prospective students exaggerating the transferability of its credits. Westwood mischaracterized the effect of its national accreditation on transferability; falsely equated the transferability of Westwood credits with the transferability of credits from other institutions; and told prospective students that Westwood credits would transfer to other institutions. • Between at least 2002 and 2015, Westwood’s misrepresentations were consistent over time and across its multiple campuses and online programs. Westwood’s transfer of credit exaggerations consistently left borrowers with the false impression that they would be able to transfer their credits to other institutions. BDG continues its work on the Westwood Statement of Common Facts and will update this summary memoranda when appropriate. .