CFA joined a coalition of organizations in response to their request for information about employer-driven debt. The groups urged the CFPB to utilize existing authorities to protect consumers from Training Repayment Agreement Provisions (TRAPs). TRAPs are a form of shadow student debt— employment contract provisions that require a consumer to pay large fees for on-the-job training or orientations if the consumer decides to leave before an arbitrarily determined date, essentially indebting the consumer to the employer. TRAPs are often found buried deep within employee contracts for low-paying jobs with poor working conditions and are essentially used to trap the employee in the job with threats of high interest rates, attorney and collection fees to collect the money owed, or withholding of other benefits, like pay and retirement balances, should they leave before the predetermined date.