Placement and Salary Claims Bring FTC Cases Against Schools. Every Number in an Ad Needs Proof on the Page.

Trade schools, career colleges and online programs sell an outcome: a job, a license, a raise. So the claim they most want to put in an ad is a number about that outcome. "92% placed." "Graduates earn $55,000." "Hired within 90 days." Those numbers work, which is exactly why regulators read them closely, and why the FTC's largest settlements with schools turned on job and pay claims.

This chapter covers what those cases were about, what the schools in our example market actually claimed, what a placement number needs beside it to hold up, and the other claims that can end a school's Google Ads account on the spot.

The FTC's Largest School Settlements Turned on Job and Pay Claims. DeVry Paid $100 Million Over Its Placement and Income Claims.

The Federal Trade Commission's education cases read like a list of ad headlines that went too far:

• DeVry University, 2016. The FTC charged that DeVry claimed "90 percent of graduates actively seeking employment landed jobs in their field within six months of graduation," and that its bachelor's graduates "had 15 percent higher incomes one year after graduation" than graduates of all other colleges. DeVry agreed to a $100 million settlement. The order specifically bars DeVry from counting jobs students obtained more than six months before graduating.
• University of Phoenix, 2019. A record $191 million settlement, over ads that falsely touted relationships and job opportunities with companies including AT&T, Microsoft and the American Red Cross.
• Sollers College, 2023. The school advertised on its website that "90% of our students are placed within 3 months of graduation." The FTC said the school's own data put the current placement rate for graduates of one group of its programs as low as 52 percent. Sollers was ordered to cancel $3.4 million in student debt.
• Career Step, 2024. $43.5 million in cash and debt cancellation, over ads the FTC said falsely touted inflated employment outcomes, job placement and partnerships with prominent companies. Career Step is also one of our twelve example schools, and none of its ads we read in 2026 stated an outcome number.

In 2021, the FTC went further and sent a formal notice about education claims to 70 for-profit colleges. The notice names, as unfair or deceptive, misrepresenting graduates' employment prospects, the share of students who found jobs, how much graduates will or may earn, the school's job placement help and even "the need or demand" for its graduates. The FTC said being on the list didn't mean a school had done anything wrong. It meant the school had been told, and later violations could bring civil penalties.

For schools that take federal student aid, federal education regulations cover the same ground. As Chapter 13 covered, they treat a misleading statement about employment prospects, earnings or licensure pass rates as misrepresentation, including statements made by the school's marketing vendors.

None of Our 12 Example Schools Advertised a Placement Rate. The One Rate Claim We Found Had No Number on the Site.

We read all 234 ads with readable text that the Ads Transparency Center held for our twelve example schools in the Salt Lake City market. Not one stated a placement percentage or a salary figure.

What they said instead was vague: "Build real-world skills that lead straight to a job," "career-ready programs," "a redefined approach to rigor that delivers top college placements." Lines like those promise an outcome without measuring it.

One ad did reach for a rate. The CDL school's ads said "Excellent pass rate with the Full Course." When we checked the school's website, no pass rate appeared on any page we checked. The same school's home page promises "Lifetime job placement," which is the kind of placement-help claim the FTC's notice names, and it needs a description on the page of what that help actually is. Another, at a private college, said "Cybersecurity jobs projected to grow 32%." That's a claim about job prospects in a field, which both the FTC's notice and the federal aid rules name, and the college's cybersecurity page backs it the right way, crediting the federal Bureau of Labor Statistics projection for 2022 to 2032.

There's a reasonable instinct behind the vagueness: a school that isn't sure of its numbers stays away from them. But families notice. As Chapter 8 found, students argue about outcomes with numbers: how soon after a license test they were hired, a school's state board pass rate, the size of a raise. A school with a strong, honest number has every reason to publish it. A school without one shouldn't imply one with "excellent."

A Placement Rate Only Holds Up When the Page Says Which Graduates, Which Jobs and Which Year It Counts.

A placement rate is a fraction, and every part of the fraction is a choice. Which graduates count in the bottom of it: everyone who finished, or only those "actively seeking employment," as DeVry's claim did? Which jobs count in the top: any job, or only jobs in the field trained for? Over what time window, and from which year's class? Does a job the student already had before graduating count? DeVry's order answered that one for DeVry: jobs obtained more than six months before graduating don't.

So a number in an ad needs its method on the page the ad points to. Next to every placement or pass rate, publish:

• The cohort. Which graduating class or classes, and how many students were in it.
• Who's counted. Every graduate, or a defined subset, with the reason for any exclusion.
• What counts as placed. A job in the field trained for, any job, or continuing education, defined in plain words.
• The time window. Within three months, six months, a year.
• The source. The school's own survey, the state licensing board's results, or an accreditor's required report, with the year.

Pass rates are easier, because a state board or national exam publishes them. A nursing program can point to its licensing exam pass rate, and a cosmetology school to its state board results, with the year. Federal rules for schools on student aid count it as misrepresentation when actual licensure pass rates are materially lower than the ones in the school's marketing, so update the ad when each new year's rate comes out.

Salary claims are the hardest to support and the easiest to get wrong. An average salary for "graduates" mixes people who found work in the field with people who didn't, and an industry median from a government survey isn't a claim about the school's own graduates. If a school uses earnings at all, it should say exactly whose earnings they are and where the figure comes from.

Then the ad can be short. A made-up example like "92% of 2025 graduates working in the field within 6 months" fits in two headlines, and the page holds the rest.

Google Shuts Off a School's Ad Account Without Warning for Implying a Government Tie. "Accredited" and "Free" Have Rules Too.

Placement and pay aren't the only claims with consequences. A few others can end the account outright.

Implied government or brand ties. Google's unacceptable business practices policy bars any ad that suggests a tie to a brand, an organization or a government agency the advertiser doesn't have, and says the resulting suspension "occurs upon detection and without prior warning." The FTC's guides for private vocational and distance schools say the same about schools that imply a connection to a government agency, including the federal education department. For a school, that means no seals, colors or wording that suggest a federal program, and no "approved by" language unless the approval is real and named. It also covers employers: Phoenix's case was about implied partnerships with well-known companies.

"Accredited." The FTC's guides for private vocational and distance schools say such a school shouldn't call itself accredited without qualification unless all of its courses and programs are accredited by an agency the Department of Education recognizes. If only some programs are, the ad has to say which.

"Free" and other offers. Chapter 8 found an ad promising a free application while the school's own application flow showed a $65 fee. Google's misrepresentation policy bars offers that families can't easily find on the landing page. "Free" should mean free on the page the ad points to.

Vendors' claims are the school's claims. As Chapter 13 covered, federal rules hold schools on student aid responsible for what their marketing, advertising and recruiting vendors say. Review every ad an agency or lead vendor runs in the school's name with the same eye.

None of this argues for timid ads. Chapter 8's best headlines came from families' own words, and a real number with its method beside it is the strongest headline a career school can run. It argues for ads a school can stand behind on the day a regulator, a reporter or a family asks.

Next: All 16 Chapters in Order, From Tracking the Inquiry to Proving Every Claim

This is the last chapter of the guide. Here are all sixteen, in the order a school's account is built:

1. Track the inquiry, even when it happens on another site
2. Start with families already searching for a seat
3. Set the budget from the enrollment funnel
4. One program per ad group and per page
5. Read every keyword idea before it goes live
6. Launch program and "near me" searches on exact match
7. Bid on the inquiry, not the enrollment
8. Write ads in families' own words
9. Reach teens through their searches and their parents
10. Exclude the wrong pages from Performance Max
11. Run a real campus tour as a YouTube ad
12. Sell the visit where Google shows no stars
13. Turn on AI Max last, and read what it writes
14. Google Ad Grants and the school foundation
15. Answer every inquiry fast
16. Back every number in an ad with proof on the page (this chapter)

The Google Ads for Education guide home has the whole guide on one page. If you'd like a hand building or fixing your school's account, here is how our Google Ads management runs for schools.