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Finance
10 min read
Areas of Expertise :
Data Science, Digital Forensics, Fraud, Business Valuation, Mergers And Acquisitions
Published Date:
Last Modified Date:
Jurisdiction:
Federal. Second Circuit
JPMorgan Chase acquired Frank, a college financial-aid platform, for approximately $175 million in September 2021. During the acquisition process, Frank founder Charlie Javice represented that the company had about 4.25 million users. Federal prosecutors later presented evidence that Frank had closer to 300,000 actual account holders and that artificial records and commercially purchased student information were used to support the larger figure.
Prosecutors accused Javice and former Frank executive Olivier Amar of misleading JPMorgan about the size and source of Frank’s user base. After a six-week trial in the U.S. District Court for the Southern District of New York, a jury convicted both defendants on March 28, 2025, of conspiracy, wire fraud, bank fraud, and securities fraud. Javice was later sentenced to 85 months in prison. Her appeal remained pending before the Second Circuit as of July 21, 2026.
Charlie Javice founded Frank as an online platform designed to help students complete the Free Application for Federal Student Aid, commonly known as FAFSA. The company promoted a simpler process for managing federal financial-aid applications.
People who created Frank accounts supplied information such as their names, email addresses, telephone numbers, and other identifying details. Frank also tracked website traffic, although visitors were not necessarily registered account holders.
Frank entered acquisition discussions with JPMorgan Chase in 2021. During those negotiations, the company stated that it had approximately 4.25 million users who had supplied identifying and contact information. Prosecutors later presented evidence that Frank had closer to 300,000 actual account holders. They alleged that the larger total included records that did not represent people who had registered with Frank.
JPMorgan asked Frank to provide information supporting its reported user count. Prosecutors alleged that Javice and Amar first asked Frank’s director of engineering to create artificial customer records for the review. The director questioned the request and declined to complete the work. Javice then hired an outside data scientist who created a file containing 4,265,085 artificial customer records. The file was submitted to a third-party validator. The validator confirmed the number of entries and reported that specified identifying fields were populated. The review did not authenticate the listed identities or confirm that the entries represented registered Frank users.
JPMorgan and Frank signed the merger agreement on August 8, 2021, and completed the transaction on September 14, 2021. JPMorgan purchased Frank for approximately $175 million. Javice received more than $21 million through her ownership interests and related trusts and became eligible for an additional retention payment. She also joined JPMorgan after the transaction closed. The government later alleged that the reported user total formed part of the information supplied during the acquisition review.
Around the time the artificial file was created, Amar arranged for Frank to purchase information concerning approximately 4.5 million students for $105,000. Frank also obtained additional contact information from another provider. After the acquisition, JPMorgan requested customer information for marketing purposes. Records were supplied to the bank on January 21, 2022, and again in early February 2022.
The purchased dataset contained names and address information concerning approximately 4.5 million students. About 2.46 million entries included email addresses, while approximately 2.04 million did not. Neither group contained telephone numbers. Frank later used another provider to obtain or append additional email and telephone information. Prosecutors alleged that the records were supplied without being identified as commercially acquired data and that the listed individuals were not registered Frank users.
According to JPMorgan’s later civil complaint, the bank used approximately 400,000 contacts from the supplied records in a July 2022 test email campaign. JPMorgan alleged that about 28 percent of the messages were delivered and that only 1.1 percent of the delivered emails were opened. The bank then reviewed historical Frank emails and data transferred during the acquisition. According to the SEC’s amended complaint, JPMorgan found communications concerning the artificial dataset and the commercially purchased student list. The bank terminated Javice’s employment for cause on or about November 4, 2022.
JPMorgan filed a civil lawsuit against Javice and Amar in the U.S. District Court for the District of Delaware. The bank alleged that false statements about Frank’s user base induced it to complete the acquisition. The Delaware case was separate from the federal prosecution later filed in New York. The SEC also pursued a civil enforcement action arising from the transaction.
Federal prosecutors unsealed a complaint against Javice on April 4, 2023. She had been arrested in New Jersey and appeared in federal court in Manhattan. The complaint accused her of fraud connected to the customer information presented during the acquisition.
The SEC filed a separate action on the same date. The agency alleged violations of federal securities laws and requested financial remedies, civil penalties, injunctive relief, and an officer-and-director bar.
A federal grand jury indicted Javice on May 18, 2023. A superseding indictment filed on July 12, 2023, added Amar as a co-defendant. The charges included conspiracy to commit wire and bank fraud, wire fraud affecting a financial institution, bank fraud, and securities fraud. Both defendants pleaded not guilty, and the case proceeded through discovery and pretrial litigation.
On May 30, 2024, the district court denied the defendants’ motions to dismiss the superseding indictment. The court also denied Amar’s motion to suppress electronic evidence seized during the investigation. On January 23, 2025, the court denied Javice’s request to be tried separately from Amar. The defendants therefore proceeded to a joint trial.
The government presented acquisition documents, internal messages, artificial datasets, purchased student records, customer files, and evidence concerning JPMorgan’s marketing campaign. Prosecutors argued that Javice and Amar knowingly misrepresented Frank’s customer base. The defense disputed the government’s interpretation and maintained that fraudulent intent had not been proved. On March 28, 2025, the jury convicted both defendants of conspiracy, wire fraud, bank fraud, and securities fraud.
Javice and Amar challenged the sufficiency of the evidence and sought judgments of acquittal or a new trial. The district court denied the requests during oral argument on May 29, 2025, and issued a written opinion on August 7, 2025. The court concluded that the evidence was sufficient to support the jury’s verdicts.
U.S. District Judge Alvin K. Hellerstein sentenced Javice to 85 months in federal prison and three years of supervised release. The court entered a forfeiture judgment of $22,360,977.48 and ordered her to pay $287,501,078 in restitution, jointly and severally with Amar. Javice continued challenging the verdict and judgment through post-trial and appellate proceedings.
Javice and Amar requested a new trial based partly on employment relationships between two of Judge Hellerstein’s law clerks and Davis Polk & Wardwell, JPMorgan’s outside counsel. JPMorgan was not a defendant or formal party in the prosecution. Judge Hellerstein denied the motions on March 24, 2026. The defendants then continued seeking review before the Second Circuit.
The appellate proceedings had been paused while the district court considered the new-trial motions. The Second Circuit lifted the stay on May 6, 2026, and established a briefing schedule for Javice and Amar. As of July 21, 2026, the court had not issued a decision on the appeals.
Court:
United States Court of Appeals for the Second Circuit
Case Name:
United States of America v. Javice
Data Analysis
Databases
Data Management
Computer Data
Computer Fraud
Financial Fraud
Fraud Detection
Fraud Examination
Securities Fraud
Business mergers
JPMorgan Chase acquired Frank, a college financial-aid platform, for approximately $175 million in September 2021. During the acquisition process, Frank founder Charlie Javice represented that the company had about 4.25 million users. Federal prosecutors later presented evidence that Frank had closer to 300,000 actual account holders and that artificial records and commercially purchased student information were used to support the larger figure.
Prosecutors accused Javice and former Frank executive Olivier Amar of misleading JPMorgan about the size and source of Frank’s user base. After a six-week trial in the U.S. District Court for the Southern District of New York, a jury convicted both defendants on March 28, 2025, of conspiracy, wire fraud, bank fraud, and securities fraud. Javice was later sentenced to 85 months in prison. Her appeal remained pending before the Second Circuit as of July 21, 2026.
Charlie Javice founded Frank as an online platform designed to help students complete the Free Application for Federal Student Aid, commonly known as FAFSA. The company promoted a simpler process for managing federal financial-aid applications.
People who created Frank accounts supplied information such as their names, email addresses, telephone numbers, and other identifying details. Frank also tracked website traffic, although visitors were not necessarily registered account holders.
Frank entered acquisition discussions with JPMorgan Chase in 2021. During those negotiations, the company stated that it had approximately 4.25 million users who had supplied identifying and contact information. Prosecutors later presented evidence that Frank had closer to 300,000 actual account holders. They alleged that the larger total included records that did not represent people who had registered with Frank.
JPMorgan asked Frank to provide information supporting its reported user count. Prosecutors alleged that Javice and Amar first asked Frank’s director of engineering to create artificial customer records for the review. The director questioned the request and declined to complete the work. Javice then hired an outside data scientist who created a file containing 4,265,085 artificial customer records. The file was submitted to a third-party validator. The validator confirmed the number of entries and reported that specified identifying fields were populated. The review did not authenticate the listed identities or confirm that the entries represented registered Frank users.
JPMorgan and Frank signed the merger agreement on August 8, 2021, and completed the transaction on September 14, 2021. JPMorgan purchased Frank for approximately $175 million. Javice received more than $21 million through her ownership interests and related trusts and became eligible for an additional retention payment. She also joined JPMorgan after the transaction closed. The government later alleged that the reported user total formed part of the information supplied during the acquisition review.
Around the time the artificial file was created, Amar arranged for Frank to purchase information concerning approximately 4.5 million students for $105,000. Frank also obtained additional contact information from another provider. After the acquisition, JPMorgan requested customer information for marketing purposes. Records were supplied to the bank on January 21, 2022, and again in early February 2022.
The purchased dataset contained names and address information concerning approximately 4.5 million students. About 2.46 million entries included email addresses, while approximately 2.04 million did not. Neither group contained telephone numbers. Frank later used another provider to obtain or append additional email and telephone information. Prosecutors alleged that the records were supplied without being identified as commercially acquired data and that the listed individuals were not registered Frank users.
According to JPMorgan’s later civil complaint, the bank used approximately 400,000 contacts from the supplied records in a July 2022 test email campaign. JPMorgan alleged that about 28 percent of the messages were delivered and that only 1.1 percent of the delivered emails were opened. The bank then reviewed historical Frank emails and data transferred during the acquisition. According to the SEC’s amended complaint, JPMorgan found communications concerning the artificial dataset and the commercially purchased student list. The bank terminated Javice’s employment for cause on or about November 4, 2022.
JPMorgan filed a civil lawsuit against Javice and Amar in the U.S. District Court for the District of Delaware. The bank alleged that false statements about Frank’s user base induced it to complete the acquisition. The Delaware case was separate from the federal prosecution later filed in New York. The SEC also pursued a civil enforcement action arising from the transaction.
Federal prosecutors unsealed a complaint against Javice on April 4, 2023. She had been arrested in New Jersey and appeared in federal court in Manhattan. The complaint accused her of fraud connected to the customer information presented during the acquisition.
The SEC filed a separate action on the same date. The agency alleged violations of federal securities laws and requested financial remedies, civil penalties, injunctive relief, and an officer-and-director bar.
A federal grand jury indicted Javice on May 18, 2023. A superseding indictment filed on July 12, 2023, added Amar as a co-defendant. The charges included conspiracy to commit wire and bank fraud, wire fraud affecting a financial institution, bank fraud, and securities fraud. Both defendants pleaded not guilty, and the case proceeded through discovery and pretrial litigation.
On May 30, 2024, the district court denied the defendants’ motions to dismiss the superseding indictment. The court also denied Amar’s motion to suppress electronic evidence seized during the investigation. On January 23, 2025, the court denied Javice’s request to be tried separately from Amar. The defendants therefore proceeded to a joint trial.
The government presented acquisition documents, internal messages, artificial datasets, purchased student records, customer files, and evidence concerning JPMorgan’s marketing campaign. Prosecutors argued that Javice and Amar knowingly misrepresented Frank’s customer base. The defense disputed the government’s interpretation and maintained that fraudulent intent had not been proved. On March 28, 2025, the jury convicted both defendants of conspiracy, wire fraud, bank fraud, and securities fraud.
Javice and Amar challenged the sufficiency of the evidence and sought judgments of acquittal or a new trial. The district court denied the requests during oral argument on May 29, 2025, and issued a written opinion on August 7, 2025. The court concluded that the evidence was sufficient to support the jury’s verdicts.
U.S. District Judge Alvin K. Hellerstein sentenced Javice to 85 months in federal prison and three years of supervised release. The court entered a forfeiture judgment of $22,360,977.48 and ordered her to pay $287,501,078 in restitution, jointly and severally with Amar. Javice continued challenging the verdict and judgment through post-trial and appellate proceedings.
Javice and Amar requested a new trial based partly on employment relationships between two of Judge Hellerstein’s law clerks and Davis Polk & Wardwell, JPMorgan’s outside counsel. JPMorgan was not a defendant or formal party in the prosecution. Judge Hellerstein denied the motions on March 24, 2026. The defendants then continued seeking review before the Second Circuit.
The appellate proceedings had been paused while the district court considered the new-trial motions. The Second Circuit lifted the stay on May 6, 2026, and established a briefing schedule for Javice and Amar. As of July 21, 2026, the court had not issued a decision on the appeals.
The following categories describe technical testimony that may arise in disputes involving customer records and acquisition representations. They are not presented as witnesses who testified in United States v. Javice.
Data Analysis Expert Witness
A customer data analytics expert witness may compare reported user totals with account records, registration logs, duplicate entries, consent records, and platform activity. The analysis may distinguish registered account holders from website visitors, marketing leads, subscribers, and purchased contacts and may trace selected records to the systems in which they were collected.
Digital Forensics Expert Witness
A digital forensics expert witness may examine emails, file metadata, database logs, document versions, access histories, and transfer records. The review may determine when a dataset was created, modified, exported, or supplied to another party and compare those records with internal communications and witness testimony.
Transaction Valuation and Damages Expert Witness
A transaction valuation and damages expert witness may examine the purchase price, company value, transaction proceeds, projected customer growth, and claimed losses. The analysis may address how customer volume, engagement, expected revenue, and marketing opportunities affected the buyer’s valuation, while restitution and forfeiture remain for the court to determine.
Financial Fraud Expert Witness
A financial fraud expert witness may examine transaction records, financial statements, internal communications, payment flows, and representations made during an acquisition. The analysis may address whether financial information and supporting records were consistent with the company’s reported operations and transaction claims.
Defining User Categories in Data Reporting
A registered account holder, website visitor, marketing lead, subscriber, and purchased contact represent different relationships with a platform. Acquisition materials may define the activity required for each category so reported totals can be compared with the company’s underlying records.
Comparing Reported User Totals with Original System Records
A standalone file does not establish that each listed person created an account, logged in, completed an application, or used the service. Reported totals may be compared with account-creation logs, registration dates, consent records, login histories, and completed transactions.
Identifying Artificial or Synthetic Customer Data
Artificial records may be created for testing, privacy protection, system development, research, or other purposes. Transaction materials may identify those records and keep them separate from genuine customer information because row counts and populated fields do not establish that the entries correspond to actual account holders.
Tracing Purchased Contact Lists to Data Providers
Commercial datasets may contain names, addresses, email addresses, telephone numbers, and demographic information, but those records do not establish that the listed individuals used the purchaser’s platform. Comparing purchased lists with the seller’s account system can separate externally acquired contacts from information collected directly from registered users.
Distinguishing File Validation from User Authentication
File validation may confirm the number of entries, required fields, formatting, and internal consistency of a dataset. User authentication separately examines whether the listed individuals are genuine account holders and whether the records correspond to actual platform activity.
The federal case focused on representations made about Frank’s user base, the creation of an artificial dataset, and the later use of commercially purchased student records. The jury convicted Javice and Amar on March 28, 2025, and the district court subsequently denied their post-trial challenges.
Javice received an 85-month prison sentence, three years of supervised release, a forfeiture judgment of $22,360,977.48, and $287,501,078 in restitution jointly and severally with Amar. As of July 21, 2026, the appeals remained pending before the Second Circuit.
When did JPMorgan acquire Frank?
JPMorgan completed the acquisition on September 14, 2021, for approximately $175 million.
What user count did Frank report?
Frank reported approximately 4.25 million users. Prosecutors later presented evidence that the company had closer to 300,000 actual account holders.
What data did prosecutors challenge?
The government presented evidence involving 4,265,085 artificial records and commercially purchased information concerning approximately 4.5 million students.
What were Javice and Amar convicted of?
The jury convicted both defendants of conspiracy, wire fraud, bank fraud, and securities fraud on March 28, 2025.
What sentence did Javice receive?
Javice received 85 months in prison and three years of supervised release, along with forfeiture and restitution orders.
The following categories describe technical testimony that may arise in disputes involving customer records and acquisition representations. They are not presented as witnesses who testified in United States v. Javice.
Data Analysis Expert Witness
A customer data analytics expert witness may compare reported user totals with account records, registration logs, duplicate entries, consent records, and platform activity. The analysis may distinguish registered account holders from website visitors, marketing leads, subscribers, and purchased contacts and may trace selected records to the systems in which they were collected.
Digital Forensics Expert Witness
A digital forensics expert witness may examine emails, file metadata, database logs, document versions, access histories, and transfer records. The review may determine when a dataset was created, modified, exported, or supplied to another party and compare those records with internal communications and witness testimony.
Transaction Valuation and Damages Expert Witness
A transaction valuation and damages expert witness may examine the purchase price, company value, transaction proceeds, projected customer growth, and claimed losses. The analysis may address how customer volume, engagement, expected revenue, and marketing opportunities affected the buyer’s valuation, while restitution and forfeiture remain for the court to determine.
Financial Fraud Expert Witness
A financial fraud expert witness may examine transaction records, financial statements, internal communications, payment flows, and representations made during an acquisition. The analysis may address whether financial information and supporting records were consistent with the company’s reported operations and transaction claims.
Defining User Categories in Data Reporting
A registered account holder, website visitor, marketing lead, subscriber, and purchased contact represent different relationships with a platform. Acquisition materials may define the activity required for each category so reported totals can be compared with the company’s underlying records.
Comparing Reported User Totals with Original System Records
A standalone file does not establish that each listed person created an account, logged in, completed an application, or used the service. Reported totals may be compared with account-creation logs, registration dates, consent records, login histories, and completed transactions.
Identifying Artificial or Synthetic Customer Data
Artificial records may be created for testing, privacy protection, system development, research, or other purposes. Transaction materials may identify those records and keep them separate from genuine customer information because row counts and populated fields do not establish that the entries correspond to actual account holders.
Tracing Purchased Contact Lists to Data Providers
Commercial datasets may contain names, addresses, email addresses, telephone numbers, and demographic information, but those records do not establish that the listed individuals used the purchaser’s platform. Comparing purchased lists with the seller’s account system can separate externally acquired contacts from information collected directly from registered users.
Distinguishing File Validation from User Authentication
File validation may confirm the number of entries, required fields, formatting, and internal consistency of a dataset. User authentication separately examines whether the listed individuals are genuine account holders and whether the records correspond to actual platform activity.
The federal case focused on representations made about Frank’s user base, the creation of an artificial dataset, and the later use of commercially purchased student records. The jury convicted Javice and Amar on March 28, 2025, and the district court subsequently denied their post-trial challenges.
Javice received an 85-month prison sentence, three years of supervised release, a forfeiture judgment of $22,360,977.48, and $287,501,078 in restitution jointly and severally with Amar. As of July 21, 2026, the appeals remained pending before the Second Circuit.
When did JPMorgan acquire Frank?
JPMorgan completed the acquisition on September 14, 2021, for approximately $175 million.
What user count did Frank report?
Frank reported approximately 4.25 million users. Prosecutors later presented evidence that the company had closer to 300,000 actual account holders.
What data did prosecutors challenge?
The government presented evidence involving 4,265,085 artificial records and commercially purchased information concerning approximately 4.5 million students.
What were Javice and Amar convicted of?
The jury convicted both defendants of conspiracy, wire fraud, bank fraud, and securities fraud on March 28, 2025.
What sentence did Javice receive?
Javice received 85 months in prison and three years of supervised release, along with forfeiture and restitution orders.
Data Analysis
Databases
Data Management
Computer Data
Computer Fraud
Financial Fraud
Fraud Detection
Fraud Examination
Securities Fraud
Business mergers
Broker, +4
Finance
Forensic Accounting, +4
Finance