A recent study from the National Association of Realtors shows that across the U.S., student debt continues to hold Millennials back from owning a home for an average of seven years, and now the latest action from the Consumer Financial Protection Bureau shows that debt may not even always be real.

The CFPB took action Monday against the National Collegiate Student Loan Trusts, fifteen Delaware statutory trusts that own more than 800,000 private student loans and their debt collector, Transworld Systems, for illegal student loan debt collection lawsuits.

The company allegedly sued consumers for private student loan debt that it couldn’t prove was owed, or which was past the statute of limitations. In fact, the lawsuits the company filed against consumers were dependent on the filing of false or misleading legal documents, the CFPB said.

The proposed judgement would require an audit of all 800,000 student loans in the National Collegiate Student Loan Trusts’ portfolio. It also prevents the company, or anyone the company hires, from attempting to collect, reporting negative credit information or filing lawsuits on any loan the audit shows is unverified or invalid.

But the CFPB didn’t stop there. It announced it will also require the National Collegiate Student Loan Trusts to pay at least $19.1 million, which includes initial redress to harmed consumers, relinquished funds to the Treasury and a civil money penalty. Under a separate consent order, Transworld Systems is ordered to pay a $2.5 million civil money penalty.

“The National Collegiate Student Loan Trusts and their debt collector sued consumers for student loans they couldn’t prove were owed and filed false and misleading affidavits in courts across the country,” CFPB Director Richard Cordray said. “We’re ordering them to pay at least $21.6 million, stopping them from filing illegal lawsuits, and requiring the trusts to thoroughly audit their loan portfolios to identify any other consumers who were harmed.”

The CFPB alleged the trusts’ actions violated the Dodd-Frank Act and the Consumer Financial Protection Act. Here is the CFPB’s accusation against the companies:

Sued consumers for debts the trusts could not prove were owed: In order to sue to collect debts, the person or company filing suit must be able to prove that the consumer owed the debt and that they own the loan that is being collected. The companies participated in illegal litigation practices when suing consumers without the necessary documentation required to sue. Over 2,000 collections lawsuits were filed on behalf of the trusts in violation of consumer financial protection laws that prevent consumers from having to pay debts they do not legally owe. In these lawsuits, the trusts do not have or cannot find the documentation necessary to prove either that they own the loans or that the consumer owed the debt. In some of these cases, the document the consumer signed promising to pay back the loan is missing. Nonetheless, the trusts filed suit against consumers to collect the debts.

Filed false and misleading affidavits: In many of the collections lawsuits, false and misleading affidavits were filed. To be valid, these affidavits must be signed by a witness with personal knowledge of the consumers’ account records and the debt. In numerous instances, affiants claimed personal knowledge of the student loan debt they did not have.

What’s more, the company also allegedly filed at least 486 collection lawsuits on consumers where the statute of limitations on the debt collection had already expired.