For Immediate Release             


Aniela Szymanski, Senior Director of Legal Affairs and Military Policy | [email protected]

June 24, 2020

Veterans Education Success Petitions the Federal Trade Commission to Investigate For-Profit Colleges and Controversial Lead Generators

Submits two petitions against lead generating website that seek to mislead prospective veterans and military-connected students

Washington, DC – Veterans Education Success submitted two petitions to the U.S. Federal Trade Commission (FTC) to counter predatory schools’ use of abusive lead generators. 

The first petition requests that FTC investigate schools that used the services of Sunkey Publishing, Inc., Sun Key Publishing LLC, and LLC, companies that operated a series of websites that were disguised as official recruiting channels for the United States Armed Forces.  These websites, including Army.Com, Air-Force.Com, NavyEnlist.Com, ArmyEnlist.Com, AirForceEnlist.Com, MarinesEnlist.Com, NationalGuardEnlist.Com, and AirGuardEnlist.Com “appeared to be official recruiting websites affiliated with the U.S. military,” according to the FTC, and claimed to offer patriotic Americans the opportunity to enlist in the Armed Forces, but failed to share citizens’ contact information with the Armed Forces and instead sold their contact information to for-profit colleges.  This interfered with Americans’ ability to serve their country in uniform and disrupted America’s military readiness, which relies on an all-volunteer force.  In particular, FTC found that Army.Com diverted potential recruits by telling them that “the military is currently downsizing. wants you to know that there are more ways for you to serve your country . . . If you had a college education you could contribute through engineering, science, law, health care, and more.” In reality, the Army had been experiencing recruiting declines and was in great need of new volunteers. 

Upon urging by Veterans Education Success and other veterans organizations, the FTC shut down these websites in September 2018. Military and veterans organizations wrote to the FTC in November 2018, requesting that it release the names of the colleges that supported and partnered with these websites, and Veterans Education Success filed a FOIA request seeking the names of the schools. The FTC denied the request because of its ongoing legal work. Thereafter, the FTC sued Career Education Corporation for partnering with these websites. The FTC alleged that Career Education Corporation utilized lead generation companies that falsely represented that its schools were affiliated with, or recommended by, the military and induced people to submit their information under the guise of providing job or benefits assistance. Career Education Corporation agreed to pay $30 million to settle the charges.

Today’s petitions filed by Veterans Education Success requests the FTC investigate and take action against the other schools that partnered with these websites, just as it did against Career Education Corporation.  Some of the schools are known because they were publicly listed as “partner schools” on the Army.Com website, which Veterans Education Success published in a report in August 2019, “ List of Partner Schools Exposed.” Many of the “partner schools” are for-profit colleges with a history of law enforcement action for defrauding students, as documented in our “Factsheet: Schools with Repeat Law Enforcement Settlements” and our list, “Law Enforcement Actions Against Predatory Colleges

The second petition requests that FTC investigate lead generation websites operated by QuinStreet, Inc., and Reach Network, Inc., as well as the schools that used their lead generation services. These companies operated lead generation websites that appear to have accepted payments from schools in exchange for promoting the schools higher on search results despite the fact that the schools were not the best match for the consumers performing the searches and apparently without adequately disclosing to consumers the companies’ paid relationship to the schools promoted. In addition, the websites specifically asked about military affiliation and then showed search results leading military-connected students to schools with poor student outcomes that likely had a financial interest, because of the 90/10 loophole, in paying for such leads to gain access to the GI Bill and military education benefits, which most for-profit colleges utilize to offset the cap on Title IV funds the schools otherwise face. 

“When prospective students discover low-quality schools that pay to be promoted in search results under the guise of unbiasedness and trustworthiness, all consumers are unfairly victimized by this con and clear violation of the law,” said Aniela Szymanski, Senior Director of Legal Affairs and Military Policy. “I’ve looked at these websites myself and I can honestly say that I would be deceived by them as well. So, it’s not a matter of prospective students not being careful in their research, it’s a matter of these sites blatantly misrepresenting themselves. That’s why we are asking the FTC to act once again, to protect service members and their families and not let these companies continue preying not only on our military and veterans, but also on taxpayers.”

Veterans Education Success has historically exposed deceptive lead generators as detrimental to veterans as far back as 2016 with its report, “Lead Generators: A Case Study: Victory Media’s ‘Military Friendly Schools.’” The FTC sued Victory Media in 2017 for failing to disclose its paid relationship to the schools it promoted as “Military Friendly Schools,” for which Veterans Education Success thanked FTC and urged it to strengthen the settlement terms. 

Deceptive lead generation companies was further explored in 2019 when Veterans Education Success joined the Student Borrower Protection Center in an essay, The Predatory Underworld of Companies that Target Veterans for a Buck, that shared the behind-the-scenes machinations these companies take to generate leads to prospective students, “through any means necessary.” 


About Veterans Education Success

Veterans Education Success is a veteran advocacy organization whose mission is to advance higher education success for veterans, service members, and military families, and to protect the integrity and promise of the GI Bill and other federal education programs. The organization offers free legal services, advice, and college and career counseling to service members, veterans, their survivors, and families using federal education benefits – and helps them participate in their democracy by engaging with policymakers. Veterans Education Success also provides policy expertise to federal and state policymakers and conducts non-partisan research on issues of concern to student veterans, including student outcomes and debt levels. Additional information is available at