Attorney General Ellison stops the use of predatory training repayment agreements for salon employees

Settlements prohibit Deka Lash franchises in Minnesota from collecting alleged costs of on-the-job training, require employer to pay back wages deducted from final paychecks

September 26, 2025 (SAINT PAUL) — Minnesota Attorney General Keith Ellison announced today that his office has reached settlement agreements with Southern Escape Ventures Incorporated (“Southern Escape Ventures”) and HW Holdings Cooperative Inc. (“HW Holdings”) over the companies’ use of training repayment agreement provisions, also known as TRAPs, that required employees to pay the alleged costs of on-the-job training if an employee quit or was fired within one year.

Southern Escape Ventures and HW Holdings operate Deka Lash salons in Eden Prairie and Woodbury, Minnesota, respectively. The employees at both salons already had the licenses they needed to do eyelash extensions and related services when they began working for the salons. Southern Escape Ventures and HW Holdings entered into TRAPs with their employees for additional on-the-job training specific to Deka Lash’s products and services. The TRAPs provided the companies with the right to seek reimbursement of up to $3,000 if an employee left their job within six months or up to $1,500 if the employee left before one year. On at least four occasions, Southern Escape Ventures deducted the entirety or a portion of an employee’s final paycheck in an attempt to recover its alleged training costs.

Under Minnesota Statutes section 181.645, an employer may only require its employees to pay for the expenses of training that “is required to obtain or maintain a license, registration, or certification.” Employers seeking to deduct an employee’s wages “to recover any claimed indebtedness” must also comply with the requirements of Minnesota Statutes section 181.79, which prohibits wage deductions “unless the employee, after the loss has occurred or the claimed indebtedness has arisen, voluntarily authorizes the employer in writing to make the deduction.” Minnesota employers must also ensure that any deductions do not bring an employee’s wages below the minimum wage in violation of Minnesota Statutes section 177.24.

As part of its settlement agreement, Southern Escape Ventures will pay back the entire remaining amount of its unauthorized wage deductions, totaling $757.72 in restitution to workers. Southern Escape Ventures and HW Holdings also agree to notify and release all current and former employees from any existing TRAPs, and the companies are prohibited from seeking to collect money under any TRAPs.

“Training repayment agreements can trap workers in their jobs and prevent them from pursuing better employment opportunities elsewhere, including jobs with higher wages and better working conditions,” Attorney General Ellison said. “Workers should not have to pay for on-the-job training that an employer requires for the company’s benefit. I am pleased that Southern Escape Ventures and HW Holdings changed their practices and that my Office was able to secure full restitution for employees.”

What are TRAPs?

Training repayment agreements, also known as TRAPs, are agreements that require an employee to pay an employer for the costs of training if the employee quits work or is fired within a specified period of time. TRAPs with large repayment amounts and lengthy repayment periods can severely limit employee mobility, locking workers in place at jobs that they would otherwise leave. In recent years, TRAPs have become increasingly prevalent across all industries, with employers sometimes including TRAPs in lengthy new hire paperwork or presenting employees with TRAPs as a mandatory condition of their employment. While training can provide marketable skills or credentials that benefit an employee, certain TRAPs may require payment for training that is company-specific or of little external value to the employee. Employers seeking to collect on TRAPs often attempt to deduct wages from an employee’s final paycheck, charge high interest rates for outstanding payments, or refer the TRAP debt to collections agencies or credit bureaus. The Attorney General encourages all employers to review any agreements requiring reimbursement of training costs and to seek advice from an attorney to ensure compliance with the law.

Filing a complaint as a worker

Workers with concerns about TRAPs or complaints about systematic violations of state and federal wage laws can contact the Attorney General’s Office through its online complaint form (available in Spanish or English) or by calling (651) 296-3353 (Metro area) or (800) 657-3787 (Greater Minnesota).