ITT Educational Services, Inc. (ITT) (defendant) was a for-profit college. Many ITT students had limited financial means and had to obtain tuition funding through federal student loans to attend. However, even with this assistance, some ITT students still needed additional revenue for tuition. ITT offered these students short-term, no-interest loans called temporary credit. Students had to pay back the temporary credit at the end of the academic year. Unfortunately, when the time for repayment arrived, many students could not pay back the temporary credit. Accordingly, ITT established a private-loan program and encouraged students to take out private loans so that they could pay back the temporary credit. Students relied on ITT’s guidance and claimed they did not fully understand the ramifications of taking out private loans. ITT assisted students in the process of taking out the loans and helped them complete the requisite forms. Consumer Financial Protection Bureau (Bureau) (plaintiff) filed a lawsuit against ITT. Bureau alleged that ITT violated the Consumer Financial Protection Act (CFPA), 12 U.S.C. §§ 5531(a), 5564(a) and 5565. The Bureau also maintained that ITT violated the Truth in Lending Act (TILA), 15 U.S.C. §§ 1601 et seq. ITT moved to dismiss.