What I had neglected to publish previously was something a great tipster (send in your tips here) had sent in showing how Credit Answers was continuing to collect monthly fees for services from month one after the implementation of the FTC telemarketing sales rules.
In this article I showed the catalog Credit Answers was sending out. My theory was they were using the catalog as a probable attempt to circumvent the telemarketing sales rules provision against collecting fees in advance of settling debt.
The email above was sent after December 21, 2010 and clearly shows the fee approach. You can even see in the email footer how the salesperson was using the catalog link. The catalog in mailers and emails seemed to be the push.
The FTC loophole targeted appears to be that of:
Generally, the Rule does not apply to calls placed by consumers in response to a mailed catalog if the catalog:
- contains a written description or illustration of the goods or services offered for sale;
- includes the business address of the seller;
- includes multiple pages of written material or illustrations;
- has been issued at least once a year; and
- the catalog seller doesn’t solicit consumers by telephone, but only receives calls initiated by consumers in response to the catalog, and during the calls, only accepts orders without additional solicitation. The catalog seller may provide the consumer with information about — or attempt to sell the consumer — other items in the same catalog that prompted the consumer’s call or in a similar catalog. – Source
We will just have to watch and see what happens on this approach. Do you think it will be ultimately successful? Is it a wise approach? Post your comments below.
Credit Answers Loopholing TSR With the Catalog Approach? by Steve Rhode
I can always use your help. If you have a tip or information you want to share, you can get it to me confidentially if you click here.