“If Frank’s primary function was to get people through the financial aid application, and Frank promised to JPMorgan Chase that their account holders comprised [4.25] million people, that would be a quarter of all financial aid applications in America, depending on how you measure it,” said Mike Pierce, executive director and co-founder of the Student Borrower Protection Center, a nonprofit that focuses on student debt.

“There should always be skepticism about how these private firms monetize what’s supposed to be a free application,” he said.