Again, the intent of the person making the misrepresentation is not a consideration. If the listener “could reasonably be expected to rely, or has reasonably relied, to that person’s detriment”—even if the speaker did not intend such reliance—the statement is a substantial misrepresentation. The Department of Education has announced that these changes to Federal law are intended to protect students and their families from advertisements and other solicitations that might “compromise the ability of students to make informed choices about institutions and the expenditure of their resources on higher education.”