Under Donoghue's leadership, the Office of Federal Student Aid (FSA) introduced a program called the "Secret Shopper" to target recruitment, enrollment, financial aid, and other practices. The Biden administration claims it is to ensure compliance with Title IV regulations and prevent so called deceptive school recruitment practices. However, this program is part of the Office of Enforcement which unfairly targets Christian and non-traditional colleges. It's clear that this could give traditional, left-leaning colleges an undue advantage, skewing the playing field against institutions that uphold conservative values.

“Federal Student Aid (FSA) on Tuesday announced that it will utilize secret shoppers to evaluate recruitment, enrollment, financial aid, and other postsecondary program practices, in order to ensure that schools are not conducting predatory or deceptive practices in violation of Title IV regulations.”

“The launch of this monitoring program is a part of the Department of Education’s (ED) Office of Enforcement, which is housed within FSA, and was re-launched during the Biden administration in an effort to strengthen oversight and enforcement actions against colleges and universities.”

“Secret shopping is another tool in FSA’s toolbox as we expand our oversight work to hold predatory schools accountable,” said Richard Cordray, the chief operating officer of FSA. “Our focus — as always — is to ensure that students, borrowers, families, and taxpayers are not being preyed upon to make a quick buck.”

“Schools that engage in fraud or misconduct are on notice that we may be listening, and they should clean up accordingly,” said Kristen Donoghue, FSA’s chief enforcement officer. “But schools that treat current and prospective students fairly and act lawfully have nothing to fear from secret shopping.”

(Source)

Given the priorities of the Department of Education during the Biden Administration, the “Secret Shoppers” program could easily be weaponized against career colleges and Christian schools.

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After developing a "sue and harass" model at the Consumer Financial Protection Bureau (CFPB), where he used the heft of the federal government and its allies to bring disfavored industries to heel, former CFPB Director Richard Cordray worked to implant the same system at Joe Biden's Department of Education's Office of Enforcement, and brought his old CFPB deputy Kristen Donoghue to help him do it.

Donoghue served as Director of Enforcement at the CFPB, and now serves as the Chief Enforcement Officer at the Federal Student Aid office, where she works to help Cordray turn the office into a mini version of the CFPB.

Documents show that Cordray explicitly told AGs that as part of his enforcement partnerships with them that “We have instituted a similar process for information requests from the Consumer Financial Protection Bureau(CFPB).” Cordray sought to create an enforcement office where the aggressive rhetoric of Senators Warren and Sanders is supercharged with the manpower, subpoenas, and lawsuits of a federal agency all toward the goal of shutting down career colleges.

(Source)