Our Response to the AG’s Complaint

It’s big news: The NM Attorney General has filed a complaint against TTSI. The complaint makes several spectacular claims, certainly, but there’s more to the story than told in the media. We’re setting the record straight.

We ask that out of fairness and integrity, before assuming that the AG’s complaint has any merit, please read our response, too. You’ll find that there is another side to the story.

The information below is a summary of the complaint and our response. Go here to read the full complaint and the full response.


Before a client ever gets a J-1 visa and comes to teach in the U.S., TTSI typically works for more than a year on that client’s behalf, sometimes two or three years. What does TTSI collect for fees during this time? $399. Almost all of this is paid to the New Mexico Public Education Department for the client’s teaching license application and to a company that conducts a background check. Nothing else is collected from the client, and TTSI doesn’t earn anything for its services during this time.

Clients pay for TTSI services after they come to the U.S. to teach. Several months after they begin receiving their salary, they start paying monthly installments on the placement fee.

This works fine for most clients, but some clients take advantage of TTSI’s willingness to wait for payment. TTSI had a group of clients who suddenly stopped paying their installments. After months and months of trying to get them to resume payments, we finally filed against 8 teachers in small claims court. They responded by counter-filing against TTSI.

Then, apparently, they went to the AG’s office, shared their counter-suit, and the AG also issued a complaint. In fact, much of the language in the AG’s complaint reads word-for-word from the teachers’ complaint. Obviously, the teachers’ complaint is biased because they are suing TTSI and don’t want to pay their fees for services they received. The AG seems to taken their claims as truth and never verified whether their claims had merit.

The AG’s Complaints

The major claims fall into two categories: Finances and False Representations.

The AG’s office claims that fees for placement services are too high and that TTSI misrepresents costs. From the complaint: “TTSI charges exorbitant and excessive fees for the placement services they provide, averaging about $15,000 per teacher, in excess of the advertised 10% of the teaching salary.”

No client with a J-1 visa pays $15,000. Many of the items in the complaint are based on this mistaken amount.

So where does this amount come from? Early clients had contracts in which they agreed to pay $15,000. In 2019, we lowered the fees for incoming clients. To be fair, we also lowered the fees retroactively for existing clients, reducing their fees from $15,000 to $9,990. This is more than a $5,000 discount for every J-1 teacher client, a huge loss for TTSI. Now, none of them are paying $15,000. Sure, they had valid contracts for the higher amount, but lowering the fees seemed like the right thing to do.

Even those teachers who had already stopped paying (and who eventually filed a complaint against TTSI) had their fees lowered by this amount, saving them 33.4%. Every single one of them knew their fees were lowered because we notified them directly and provided account statements with the lower amount! This makes us wonder why they informed the AG’s office that they were expected to pay $15,000, knowing it to be false.

Interestingly, the first complaint from the teachers noted that TTSI did, indeed, lower their fees. Their amended complaint said TTSI only claimed to lower their fees. The AG’s complaint just says we charge $15,000. We don’t. We charge $9,990 for placement services and not a penny more. (We even issued a refund to one client who overpaid his final installment.)

At the same time, in spite of the AG’s complaint stating teachers are required to make monthly payment of $403, the monthly installment was lowered from $403 to $333. So, is a teacher able to make a monthly payment of $333? Of course they can…if they choose to. Nearly 100% of clients are making $50,000 or more per year, and almost 50% are making $60,000 or more per year. Like everyone else, like every single teacher in New Mexico, if they don’t get exorbitant with their spending and they stick to their budgets, they should have no trouble paying this amount.

Fortunately, most of our clients are making their payments successfully on-time, and some make larger-than-required payments. We even have clients who make double payments each month. Each month, a few more fully complete their entire payment. So, yes, it can be done.

The AG’s office states that $15,000 creates a “gross disparity” between value and cost. TTSI cannot say whether or not this opinion is true. It’s an opinion. Value is a subjective decision that each person must make for himself or herself, but at some point the teachers seemed to think it was an acceptable amount and voluntarily signed the agreements. And then we reduced the cost by a third anyway. Even so, it’s irrelevant for two reasons—the teachers agreed to the amount and signed the contract, and the AG’s office is basing its opinion on the wrong amount.

The AG’s complaint also indicates that there is no way we can make the claim that fees are less than 10% of a teacher’s salary because “many applicants do not know their future salary when they sign the financing agreement.” Yes, we can absolutely make that claim.

We might not know the exact amount, but we do know the minimum amounts a teacher might possibly make—because minimum salaries are set by law. If teachers make the minimum legal salary for their teaching level, they will pay 5.5% to 7.9% of their salary for placement services they already received, depending on their license level. 98% of teachers are paying between 5.5% and 6.7% of the minimum salary amounts. If teachers make more than the minimum, the percentage is lower. Even if you add in the fees they pay to a federal visa sponsor, they still pay less than 10%. It’s simple math.

The other major topic in the AG’s complaint has to do with TTSI mis-representing itself as being able to process J-1 visas for teachers. From the complaint, “TTSI’s advertising makes unsupported, inaccurate, and ambiguous assertions regarding their ability to help teachers obtain teaching credentials and J-1 Visas.” No, that is simply not true. First, with our help, 100% of teachers obtained their New Mexico licenses before coming to the U.S. Second, we believe that the AG’s office does not understand how the J-1 process works.

This is apparent from further statements in the complaint: “While the responsibility to acquire such a visa is that of the potential employer, TTSI fails to explain this and refers the teachers to another company in order to obtain the J-1 Visa….” Let’s be clear here. In the J-1 program, the only way to get a J-1 visa is through a federally authorized visa sponsor, which is the other company.

What TTSI does is connect a teacher to a visa sponsor after he or she receives a letter of intent to hire by a school district, which is exactly what we tell teachers we will do. It’s in the contracts; it’s on the web site; and it’s in our communications with clients. There is no other way to get the J-1 visa. Without “another company,” teachers cannot get the visa. TTSI can’t acquire it for them, and neither can the employer.

(As an aside, the AG’s complaint has a strange line in this section: “Upon information and belief, at various times TTSI indicated they would be able to submit the application on behalf of the Plaintiff’s to obtain the J-1 license while being incapable of doing so.” The plaintiff in the AG’s complaint is the State of New Mexico. In this line, “Plaintiffs” can only be the teachers who sued TTSI, which means this text is copied from the teachers’ complaint or their documents and is not based on any investigation by AG’s office. And there is no such thing as a J-1 license.)

This leads to another misunderstanding. The AG’s office notes that TTSI does not have a No Objection Letter from the NM PED. That’s true. However, TTSI doesn’t need that letter. The AG’s complaint says, “TTSI could not process the application as a J-1 Visa, since they did not receive a Letter of No Objection from the NM Public Education Department and TTSI was not allowed to operate in New Mexico for those purposes.”

Again, let’s be clear. TTSI does not operate in New Mexico “for those purposes,” meaning process J-1 visa applications. The AG could have just as easily stated that TTSI staff are not allowed to provide nursing services, cut hair, or re-wire your house because TTSI is not licensed for those purposes, either. Permission from the NM PED is irrelevant because TTSI isn’t in that business. We couldn’t do it, letter or no letter, because TTSI is not a federally authorized visa sponsor.

On the other hand, according to the federal program regulations, visa sponsors are required to get a No Objection Letter in order to issue J-1 program documents for teachers in a particular state, but that doesn’t apply to TTSI. TTSI helps teachers get jobs, and the visa sponsors take care of the visa requirements.

Our Reaction to the AG’s Complaint

Once you understand the actual costs charged and learn how the J-1 program actually works, once you learn how TTSI has operated and what we have actually done for teachers, the complaint falls apart. Of course, the main problem with the AG’s complaint is that they apparently didn’t critically examine the teachers’ claims, don’t know what the fees are, and don’t understand the J-1 program. As far as TTSI can tell, the AG’s office never considered whether or not its claims were valid and based on accurate information.

Really, they could have just asked us! We would have given them the contracts, the billing records, and a copy of the federal regulations. We would have given them copies of emails showing two or three years of work for no compensation. Anything they wanted to help them consider information provided by a small number of teachers who are refusing to pay for the services they received and benefited from. But no one from the AG’s office ever asked for any information.

Do you know what is really upsetting about all this? We worked for years for teachers without earning anything. We helped them get their teaching licenses, prepare for interviews and fill out applications, acquire jobs, and complete visa requirements so they could come to the U.S. If needed, we helped them find housing and travel to their new communities. We gave furniture and household goods to many teachers for free—even some of the teachers who sued TTSI got free furniture, and we paid their initial rent deposits out of our own pockets.

If they got in trouble on the job and let us know, we did what we could do to help them solve their problems. When they had babies or got sick, we suspended their payments. We reduced our own income by lowering their fees by $5,000. They thanked us repeatedly for our help, they wrote emails saying “God Bless TTSI,” and even some of the teachers suing TTSI referred their friends and former colleagues to TTSI.

Do we do everything right? No, of course not. Did we sometimes need to change plans or correct mistakes. Certainly. But at the end of the day, we always tried to do the right thing for the teachers, even at our own expense.

But, apparently, that’s not enough for some people, and they found a sympathetic ear in the AG’s office who would believe their biased claims and never even ask, “Is this true?”