The 3rd Circuit handed Pennsylvania Attorney General Josh Shapiro a nice win in Commonwealth v. Navient Corp., when it held that the AG’s Office could maintain a concurrent enforcement action against a student loan provider at the same time as a similar action by the federal Consumer Financial Protection Bureau under the Consumer Financial Protection Act. Perhaps more importantly, the 3rd Circuit held that the federal Education Act does not preempt the state’s claims based on affirmative representations to lure students into more costly student programs.