e. uniformly providing false or misleading information about job placement opportunities and salary expectations; f. uniformly misrepresenting the percentage of students employed in their field of study after graduation; g. uniformly overstating the salaries students obtain after graduation; h. uniformly misrepresenting and omitting critical information about the true quality and value of Westwood’s national accreditation; i. uniformly misrepresenting and omitting critical information about the true quality and value of Westwood’s candidacy for regional accreditation; j. uniformly omitting that Westwood had failed to attain regional accreditation; k. uniformly misrepresenting that the national accreditation granted to Westwood is equal to or greater than regional accreditation; l. uniformly misrepresenting or omitting the true value of credits obtained at a nationally-accredited institution, as judged by the transferability of the credits to a regionally-accredited institution; m. uniformly misrepresenting and omitting the role and qualifications of admissions representatives; n. uniformly designating as “admissions representatives” employees whose primary job duties were to recruit students in a manner that misleads prospective students or the public regarding the authority or qualifications of such employees; o. uniformly omitting that the “admissions representatives” were actually sales people who are incentivized to enroll as many students as possible in order to meet quotas and receive financial rewards and promotions; and p. uniformly and materially misleading or deceiving prospective students and the public regarding current practices via their websites and through information provided by admissions representatives. 117.
Section 6.01.05(H) of the Colorado Department of Education policies, in and
through the Degree Authorization Act, provides that it is a deceptive trade practice for a school
{00331880.DOC3}
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