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Global Client Solutions and Rocky Mountain Bank & Trust Said to Have Aided and Abetted Debt Settlement Companies to Violate Statute

A regulator friend of mine just forwarded me a copy of the State of Washington amicus brief filed in a class action case I reported about previously. The case is Carlsen v. Global Client Solutions and Rocky Mountain Bank & Trust. – Source

The State of Washington weighed in on the matter and make some strong statements that do not shield escrow companies of potential liability when working with debt settlement companies that violate the law.

Brief Summary

Everything below is from the amicus brief filed. You can read the full brief here.

  • Washington says Debt Adjusting Act and fee limits apply to the debt settlement companies that Global Client Solutions and Rocky Mountain Bank & Trust work with and serve.
  • State there is a private cause of action against Global and Rocky if the helped debt settlement companies violate the Debt Adjusting Act.
  • States that aider and abettors can be civilly liable for assisting others to violate the Debt Adjusting Act.
  • States holding Global and Rocky accountable is important.
  • Debt settlement companies are debt adjusters and statutory fees in Washington apply to them.
  • There is an implied cause of action under 874A and Bennett against Global and Rocky for aiding and abetting debt settlement companies that violate the debt adjusting act.
  • Helping debt settlement companies violate the Debt Adjusting Act can also result in aiding and abetting liability.
  • “If Global and Rocky provided the means and instrumentality to violate the law, then they should be liable under consumer protection law.”
  • “A party shall be responsible for the fault of another person…where both were acting in concert…”
  • Civil aiding and abetting liability can lie against Global and Rocky for any of four reasons.”

Global Client Solutions and Rocky Mountain Bank & Trust Said to Have Aided and Abetted Debt Settlement Companies to Violate Statute
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About Steve Rhode

Steve Rhode
Steve Rhode is the Get Out of Debt Guy and has been helping good people with bad debt problems since 1994. You can learn more about Steve, here.
  • Angelo

    Outlook contact manager is a casual database.

    Most robust databases include those features you mentioned but why is that wrong? Think about it, who wouldnt want one centralized system to track and monitor everything? Remember, without these systems to track all the data, creating reports and providing transparency would be extremely difficult, if not impossible. I cant think of one industry that doesnt have a custom software system?

    There are several CRM’s designed specifically for the debt settlement industry….Debt Manager Soft, Prime Debt Soft, SX3, Next Gen CRM, Debt Settlement Machine, ESP and MOST of them can sync up to Global. Programs like Act, Goldmine, Salesforce or any of the off the shelf CRM’s can also be customized to streamlinie any business and also sync up to Global.

    At the end of the day, Debt manager is no different than any of the CRM’s I mentioned except they are owned by Global. Considering the tremendous amount of transactions that Global processes, doesnt it make sence for them to have an interest in also providing a software solution? Kind of like how QuickBooks offers payroll services. It’s just smart business.

    Global may be guilty of corporate greed but I think Aiding and Abetting is a bit much.

  • Vend2003-info

    Calculator, I don’t know details of exactly when/why they switched or added MidFirst. I do know that in 2010 the “Phone Pay” option in Debt Manager had to be modified for some DS companies to send the correct value for MidFirst phone pay.

    Took forever, but I found this doc via Google…
    http://www.1stamericands.com/W

    MoneyGram Instructions:
    Agent locator – http://www.moneygram.com
    Sending Instructions
    Pay to – Global Client Solutions – MidFirst
    Receive Code – 7273
    Account # – ‘DR’+ last 8 digits of your 16-digit acct #
    (Example: DR12345678)

    Apparently their association was not publicized, but this proves the collaboration.

    That’s about all I can provide on GCS/MidFirst, not my area of expertise concerning GCS.

    I wouldn’t say my interest in the topic is dwindling, but my posting here is getting repetitive. You can email me at the vend2003 email address if you have questions along the way.

  • Calculator

    Vend, your bringing up the Debt Manager attribute is the only place I have seen the reference.

    You refer to your interest in this topic winding down in your comment above. Mine is just getting started. If you would not mind and if it is not too much trouble, could you comment with more information about GCS once using Rocky Mt. and how they now use MidFirst Bank?

    What happened?

  • Vend2003-info

    Well, when I said self-save, I actually meant cut out the 2 middlemen altogether…
    1. The DS company
    2. The payment processor

    I should have said “self-settle”. DS companies don’t do anything an individual couldn’t do if they knew how.

    I have many clues. :)

  • Vend2003-info

    Calculator, you have really dug into this. I’m pretty much done here, it is obvious what was going on and who is at the center of it as far as making it possible/easier by processing the transactions. This involves DS companies from all over the U.S. Whether the scheme is legal or not is up to the “powers”. Either way, GCS was not an innocent bystander.

    I mainly wanted to make sure that Global’s Debt Manager was brought up since it was not mentioned in the descriptions of what they do. BTW, didn’t GCS start using MidFirst Bank last year? Not sure if it was part of the LHDR caper or just because Rocky Mt. was getting too “hot”. Wonder how MidFirst escaped this? Don’t see them named (yet).

  • Steve Rhode

    From what I’ve seen of Debt Manager it looks like more than just a casual database.

    Debt Manager includes a number of features including a “Sales Module including lead monitoring, task management and appointment calendar.” I agree, a simple database to facilitate the escrow services is innocent but is probably another thing when the escrow company actively sells a tool that aids the company in selling/closing deals. It even tracks and charts closes.

  • Calculator

    I would be surprised to learn that the 2 primary escrow service providers to the industry came out against up front fee models and yet still work with companies using them. Was coming out against them done publicly? In the media?

    Whose attorney signs off and gives the green light? The attorney for escrow or for the “in name only” service provider such as Searns or Macey for LHDR? Who audits the applicant and the model used for compliance? What measures are included in the audit?

    Saying one thing and doing the other is not the best confidence builder.

    The TSR rule has a narrow carve out for attorneys that, when fully vetted given the test of time, will not exempt poorly constructed work-a-rounds with an attorney name attached to it. In fact, I suspect they will be targeted.

    Claiming exemption based on a narrow carve out and then partnering with veterans who brought the need for regulatory intervention in the first place while using the same tools and conduits is a recipe for disaster. The financial risk/reward when engaging in creative methods to circumvent laws just does not compute.

    $10 a month for 36 months is $360.00. Transaction fees for the settling of 5 accounts would maybe add $150.00 more to the lifetime value of the account. How is $510.00 worth the risk of being fined 15, 10 or even 5 thousand per violation?

    Certainly there is volume to discuss. $510.00 times 10,000 is not chump change. Perhaps the risk/reward is the assumption that if called to the carpet, a settlement can be reached for 10 or 20 percent of the gains.

    I don’t know… the whole thing seems so slip shod in its construct. Do you put your good name, reputation, license, company, shareholders on black and let-er spin thinking your odds are pretty good?

    While lawyers are not generally within the regulatory purview of the FTC, those offering support services and conduits are. Nationwide & Eclipse participation will come out in great detail during the discovery phase of the IL AG action against LHDR if the case progresses to that level. Those support services are unlikely to be viewed as work product.

    When compared with a concerted effort put forward by multiple attorney generals against some of these outfits using their own states Unfair & Deceptive Acts as the premise of their case, some targets may have preferred to have dealt with the FTC in one action instead.

    I know this thread is about Global Client Solutions and the Washington state issue, but this entire topic has captured my curiosity. I apologize for drifting off topic, though in a somewhat connected way.

  • Angelo

    This shows how clueless you are. No success based debt settlement company would defend LHDR, everyone knows they are hiding behind the attorney model to circumvent FTC rules and all that’s left are either success based companies or Attorney models. We have not charged upfront fees for the past 3 years, well before FTC changes. I’m defending trust companies like Global and NoteWorld because they have nothing to do with what upfront debt settlement companies did.

    Let’s just agree to disagree because I dont think one can argue that the same results would have taken place if LHDR’s clients were told to self save and send in their “retainer fees”.

  • Angelo

    I agree Calculator, attorneys on both sides will argue interpretation, not ignorance. If I’m not mistaken both Global and Noteworld have come out against up front fee models. Noteworld will allow for the attorney model but only if it’s signed off by the attorney. LHDR will claim they are a law firm and therefor exempt, they will probably argue that the FTC doesn’t have governing authority over them also. It’ll be interesting to see how this plays out. Make no mistake, I am not a fan of LHDR or the attorney model, I just dont think holding Global or Noteworld accountable makes sense.

  • Vend2003-info

    Exactly.

    The changes to Debt Manager that enabled it to use the LHDR model revolved around adding the ability to use more than 1 set of login info for the GCS interface. This modification allowed “normal” clients to be under the “normal” company and others to go into GCS under the company’s LHDR account. Until this modification, all clients were sent using the same GCS interface login info, no ability to use different login info per client.

    Any investigation/audit that goes back to mid-2010 will verify this.

    Not a case of DS companies doing something on their own without GCS knowledge/help.

  • Calculator

    The TSR addressed escrow services and provides for their use by legitimate players offering the debt settlement service. My read of it says escrow service providers can bill monthly etc…

    Those companies found in violation of the TSR, and where it can be established that substantial assistance was provided to those violators, and where it can be established that the assistance was provided by someone (an entity) who knew and/or had the responsibility to know the system/service was built to avoid compliance….. well, that just may turn out to suck for some people.

    Not much room for claiming ignorance when/if we are talking about a large law firm(s), lawyers, industry veterans, established escrow providers etc….

    The more I look and learn about this stuff, I am left to wonder how anyone thought this would not end badly.

  • Calculator

    The friend of the court brief in Washington is specific to that state and contemplates aiding an alleged impermissible act that predates federal rule changes. The acts and actions of the escrow provider in question are not related to LHDR.

    I do think Vend has brought up a very real concern for Global as relates to the TSR changes and having provided substantial assistance. The strict interpretation would, in my opinion, reach to escrow services. The Frankenstein that was built with LHDR, Nationwide, Eclipse and a host of other participants can likely be proven to have been done so as to circumvent compliance with the TSR. If actions by regulators are taken with a wide range view, and if GCS customized the standard package in order to provide energy to the bolts of the monster, it will not be seen as favorable to any arguments they may raise to insulate themselves as a simple escrow service provider.

    I am only of the butter knife variety in the drawer. If I can see it, so can others.

  • Angelo

    My point was that Debt Manager is simply a customizable database just like Act, Sales force or Goldmine -they can all be integrated to work with Global, Noteworld or any other trust/payment processing company.

    They provide a service that is extremely beneficial to consumers and if you know anything about this industry you know that the temptation to dip into those funds is far too great. I have always given my clients the option to self save and I can tell you from experience that it doesn’t work. The fall off rate for those who chose self save was more than 4x higher than those set up through a trust account. You made the claim that Global shouldn’t take their fees until settlement so it seemed you were under the impression that Global is somehow involved with providing the DS service.

    Using your logic, banks should be held accountable for deposits made from illegal activity and Visa/MC/Amex and Discover should be held accountable for every illegal transaction they process. Although illegal, you can still use your credit card to gamble online or join a porn site. Where’s the uproar ? I dont agree at all with what LHDR is doing but right or wrong, LHDR is categorized as a law firm so why would a processing company be held liable for their actions?

  • Vend2003-info

    No, if I was owner of a DS company I would probably be trying to defend LHDR and Global.

    What does it matter what kind of work I do? Are you hiring?

    What’s important is that LHDR and Global worked together to implement this model and then made sure Debt Manager would interface correctly to enable DS companies to participate.

  • Guest

    Vend2003-info,
    I am just curious, are you an owner of a debt settlement company? What type of work do you do?

  • Vend2003-info

    You made the best suggestion – self save! If a consumer can make sure the money is there for Global to debit from their personal account every month, they can make sure they save the money themselves. They should at least be given the option instead of having an SPAA shoved in their face when they sign up with a DS company.

    This is getting off the point, which is that as listed in the bullet points above…

    “If Global and Rocky provided the means and instrumentality to violate the law, then they should be liable under consumer protection law.”

    “Helping debt settlement companies violate the Debt Adjusting Act can also result in aiding and abetting liability.”

    Without code and database modifications to the Global backend system and Debt Manager, the LHDR model could not have been implemented at Global and DM would not have worked with that model. Both systems required explicit coding modifications to accommodate LHDR.

    The whole LHDR thing was dreamed up to try to get around new laws in 2010. Put consumers under an LHDR account in Global while the DS company does the actual servicing.

    In this case, the shooter needed a special gun to shoot the consumer and Global customized the gun, loaded it and handed it to the crook so they could shoot the victim. This was not a hunting accident.

  • Angelo

    I should have clarified, Noteworld process for multiple industries.

  • Joe_debt_jr

    lol great question, i want to hear this.

  • Angelo

    That’s the part most people cant seem to understand, Global/NoteWorld are not Debt Settlement companies, they have nothing to do with the industry except to process transactions. No different from any other payment processing company.

    PS- every software is customizable, like Act, Goldmine, Salesforce, Prime Debtsoft, SX3 etc… Debt Manager is nothing more than a database. Get a clue, it’s like blaming the gun manufacturer when someone is shot. Blame the people that pulled the trigger and caused the harm.

    The only other alternative is the self-save method and honestly, most consumers do not have the discipline to self save. What will you suggest consumers/Debt Settlement companies do if companies like Global or Noteworld were forced to not service the DS industry any longer? Do you have any other suggestions?

  • Vend2003-info

    Global chose to modify their system and Debt Manager to accommodate the bogus LHDR model. They custom-made the car used in the robbery so it would perform the way the crooks needed. Could they have done that without conspiring with LHDR all along?

    Even if they were not involved in the LHDR scam, the fact remains that they are charging consumers monthly processing fees, while it is illegal for the debt settlement company to do so. To be fair, Global should not be able to collect any fees until settlement, same as the DS company.

    Let’s let the authorities decide if Debt Manager is an appropriate product to be owned by a company that is supposed to be just a payment processor.

  • Guest

    What are the multiple industries they process for?

  • Guest

    What are the multiple industries they process for?

    • Anonymous

      lol great question, i want to hear this.

    • Angelo

      I should have clarified, Noteworld process for multiple industries.

  • Angelo

    Debt manager is a CRM package for the Debt Settlement industry, every industry has them and the software has nothing to do with Globals $9 monthly bank fees. There are many other software solutions that debt settlement companies can use. Global does not force anyone to use their software.

    Blaming Global or Note world for what the upfront or attorney model companies did to consumers is like blaming a car manufacturer for selling a car that was used in a robbery. People need to wake up and realize that Global and Note World are nothing but payment processing companies, they have nothing to do with debt settlement services or companies. All they do is process transactions….for multiple industries, not just debt settlement.

    This is the problem with our legal system, these shyster lawyers have a “sue everybody” mentality and they are just looking to extort money from a processing company.

  • Vend2003-info

    I haven’t seen any mention of Debt Manager, the software that Global sells to debt settlement companies. Global owns the company “Debt Manager, LLC”. http://www.debtmanagersoft.com
    Just another “tool” they use to get consumers into their system so they can charge them $10/month for processing payments.

    Also, why is Global allowed to take processing fees out of the escrow accounts monthly before settlement if the debt settlement company cannot? No fees until settlement should apply to all aspects of the scheme.

  • Vend2003-info

    I haven’t seen any mention of Debt Manager, the software that Global sells to debt settlement companies. Global owns the company “Debt Manager, LLC”. http://www.debtmanagersoft.com/
    Just another “tool” they use to get consumers into their system so they can charge them $10/month for processing payments.

    Also, why is Global allowed to take processing fees out of the escrow accounts monthly before settlement if the debt settlement company cannot? No fees until settlement should apply to all aspects of the scheme.

    • Angelo

      Debt manager is a CRM package for the Debt Settlement industry, every industry has them and the software has nothing to do with Globals $9 monthly bank fees. There are many other software solutions that debt settlement companies can use. Global does not force anyone to use their software.

      Blaming Global or Note world for what the upfront or attorney model companies did to consumers is like blaming a car manufacturer for selling a car that was used in a robbery. People need to wake up and realize that Global and Note World are nothing but payment processing companies, they have nothing to do with debt settlement services or companies. All they do is process transactions….for multiple industries, not just debt settlement.

      This is the problem with our legal system, these shyster lawyers have a “sue everybody” mentality and they are just looking to extort money from a processing company.

      • Vend2003-info

        Global chose to modify their system and Debt Manager to accommodate the bogus LHDR model. They custom-made the car used in the robbery so it would perform the way the crooks needed. Could they have done that without conspiring with LHDR all along?

        Even if they were not involved in the LHDR scam, the fact remains that they are charging consumers monthly processing fees, while it is illegal for the debt settlement company to do so. To be fair, Global should not be able to collect any fees until settlement, same as the DS company.

        Let’s let the authorities decide if Debt Manager is an appropriate product to be owned by a company that is supposed to be just a payment processor.

      • Angelo

        That’s the part most people cant seem to understand, Global/NoteWorld are not Debt Settlement companies, they have nothing to do with the industry except to process transactions. No different from any other payment processing company.

        PS- every software is customizable, like Act, Goldmine, Salesforce, Prime Debtsoft, SX3 etc… Debt Manager is nothing more than a database. Get a clue, it’s like blaming the gun manufacturer when someone is shot. Blame the people that pulled the trigger and caused the harm.

        The only other alternative is the self-save method and honestly, most consumers do not have the discipline to self save. What will you suggest consumers/Debt Settlement companies do if companies like Global or Noteworld were forced to not service the DS industry any longer? Do you have any other suggestions?

      • Vend2003-info

        You made the best suggestion – self save! If a consumer can make sure the money is there for Global to debit from their personal account every month, they can make sure they save the money themselves. They should at least be given the option instead of having an SPAA shoved in their face when they sign up with a DS company.

        This is getting off the point, which is that as listed in the bullet points above…

        “If Global and Rocky provided the means and instrumentality to violate the law, then they should be liable under consumer protection law.”

        “Helping debt settlement companies violate the Debt Adjusting Act can also result in aiding and abetting liability.”

        Without code and database modifications to the Global backend system and Debt Manager, the LHDR model could not have been implemented at Global and DM would not have worked with that model. Both systems required explicit coding modifications to accommodate LHDR.

        The whole LHDR thing was dreamed up to try to get around new laws in 2010. Put consumers under an LHDR account in Global while the DS company does the actual servicing.

        In this case, the shooter needed a special gun to shoot the consumer and Global customized the gun, loaded it and handed it to the crook so they could shoot the victim. This was not a hunting accident.

      • Guest

        Vend2003-info,
        I am just curious, are you an owner of a debt settlement company? What type of work do you do?

      • Vend2003-info

        No, if I was owner of a DS company I would probably be trying to defend LHDR and Global.

        What does it matter what kind of work I do? Are you hiring?

        What’s important is that LHDR and Global worked together to implement this model and then made sure Debt Manager would interface correctly to enable DS companies to participate.

      • Angelo

        This shows how clueless you are. No success based debt settlement company would defend LHDR, everyone knows they are hiding behind the attorney model to circumvent FTC rules and all that’s left are either success based companies or Attorney models. We have not charged upfront fees for the past 3 years, well before FTC changes. I’m defending trust companies like Global and NoteWorld because they have nothing to do with what upfront debt settlement companies did.

        Let’s just agree to disagree because I dont think one can argue that the same results would have taken place if LHDR’s clients were told to self save and send in their “retainer fees”.

      • Vend2003-info

        Well, when I said self-save, I actually meant cut out the 2 middlemen altogether…
        1. The DS company
        2. The payment processor

        I should have said “self-settle”. DS companies don’t do anything an individual couldn’t do if they knew how.

        I have many clues. :)

      • Angelo

        My point was that Debt Manager is simply a customizable database just like Act, Sales force or Goldmine -they can all be integrated to work with Global, Noteworld or any other trust/payment processing company.

        They provide a service that is extremely beneficial to consumers and if you know anything about this industry you know that the temptation to dip into those funds is far too great. I have always given my clients the option to self save and I can tell you from experience that it doesn’t work. The fall off rate for those who chose self save was more than 4x higher than those set up through a trust account. You made the claim that Global shouldn’t take their fees until settlement so it seemed you were under the impression that Global is somehow involved with providing the DS service.

        Using your logic, banks should be held accountable for deposits made from illegal activity and Visa/MC/Amex and Discover should be held accountable for every illegal transaction they process. Although illegal, you can still use your credit card to gamble online or join a porn site. Where’s the uproar ? I dont agree at all with what LHDR is doing but right or wrong, LHDR is categorized as a law firm so why would a processing company be held liable for their actions?

      • Calculator

        The friend of the court brief in Washington is specific to that state and contemplates aiding an alleged impermissible act that predates federal rule changes. The acts and actions of the escrow provider in question are not related to LHDR.

        I do think Vend has brought up a very real concern for Global as relates to the TSR changes and having provided substantial assistance. The strict interpretation would, in my opinion, reach to escrow services. The Frankenstein that was built with LHDR, Nationwide, Eclipse and a host of other participants can likely be proven to have been done so as to circumvent compliance with the TSR. If actions by regulators are taken with a wide range view, and if GCS customized the standard package in order to provide energy to the bolts of the monster, it will not be seen as favorable to any arguments they may raise to insulate themselves as a simple escrow service provider.

        I am only of the butter knife variety in the drawer. If I can see it, so can others.

      • http://GetOutOfDebt.org Steve Rhode

        From what I’ve seen of Debt Manager it looks like more than just a casual database.

        Debt Manager includes a number of features including a “Sales Module including lead monitoring, task management and appointment calendar.” I agree, a simple database to facilitate the escrow services is innocent but is probably another thing when the escrow company actively sells a tool that aids the company in selling/closing deals. It even tracks and charts closes.

      • Angelo

        Outlook contact manager is a casual database.

        Most robust databases include those features you mentioned but why is that wrong? Think about it, who wouldnt want one centralized system to track and monitor everything? Remember, without these systems to track all the data, creating reports and providing transparency would be extremely difficult, if not impossible. I cant think of one industry that doesnt have a custom software system?

        There are several CRM’s designed specifically for the debt settlement industry….Debt Manager Soft, Prime Debt Soft, SX3, Next Gen CRM, Debt Settlement Machine, ESP and MOST of them can sync up to Global. Programs like Act, Goldmine, Salesforce or any of the off the shelf CRM’s can also be customized to streamlinie any business and also sync up to Global.

        At the end of the day, Debt manager is no different than any of the CRM’s I mentioned except they are owned by Global. Considering the tremendous amount of transactions that Global processes, doesnt it make sence for them to have an interest in also providing a software solution? Kind of like how QuickBooks offers payroll services. It’s just smart business.

        Global may be guilty of corporate greed but I think Aiding and Abetting is a bit much.

      • Calculator

        The TSR addressed escrow services and provides for their use by legitimate players offering the debt settlement service. My read of it says escrow service providers can bill monthly etc…

        Those companies found in violation of the TSR, and where it can be established that substantial assistance was provided to those violators, and where it can be established that the assistance was provided by someone (an entity) who knew and/or had the responsibility to know the system/service was built to avoid compliance….. well, that just may turn out to suck for some people.

        Not much room for claiming ignorance when/if we are talking about a large law firm(s), lawyers, industry veterans, established escrow providers etc….

        The more I look and learn about this stuff, I am left to wonder how anyone thought this would not end badly.

      • Vend2003-info

        Exactly.

        The changes to Debt Manager that enabled it to use the LHDR model revolved around adding the ability to use more than 1 set of login info for the GCS interface. This modification allowed “normal” clients to be under the “normal” company and others to go into GCS under the company’s LHDR account. Until this modification, all clients were sent using the same GCS interface login info, no ability to use different login info per client.

        Any investigation/audit that goes back to mid-2010 will verify this.

        Not a case of DS companies doing something on their own without GCS knowledge/help.

      • Angelo

        I agree Calculator, attorneys on both sides will argue interpretation, not ignorance. If I’m not mistaken both Global and Noteworld have come out against up front fee models. Noteworld will allow for the attorney model but only if it’s signed off by the attorney. LHDR will claim they are a law firm and therefor exempt, they will probably argue that the FTC doesn’t have governing authority over them also. It’ll be interesting to see how this plays out. Make no mistake, I am not a fan of LHDR or the attorney model, I just dont think holding Global or Noteworld accountable makes sense.

      • Calculator

        I would be surprised to learn that the 2 primary escrow service providers to the industry came out against up front fee models and yet still work with companies using them. Was coming out against them done publicly? In the media?

        Whose attorney signs off and gives the green light? The attorney for escrow or for the “in name only” service provider such as Searns or Macey for LHDR? Who audits the applicant and the model used for compliance? What measures are included in the audit?

        Saying one thing and doing the other is not the best confidence builder.

        The TSR rule has a narrow carve out for attorneys that, when fully vetted given the test of time, will not exempt poorly constructed work-a-rounds with an attorney name attached to it. In fact, I suspect they will be targeted.

        Claiming exemption based on a narrow carve out and then partnering with veterans who brought the need for regulatory intervention in the first place while using the same tools and conduits is a recipe for disaster. The financial risk/reward when engaging in creative methods to circumvent laws just does not compute.

        $10 a month for 36 months is $360.00. Transaction fees for the settling of 5 accounts would maybe add $150.00 more to the lifetime value of the account. How is $510.00 worth the risk of being fined 15, 10 or even 5 thousand per violation?

        Certainly there is volume to discuss. $510.00 times 10,000 is not chump change. Perhaps the risk/reward is the assumption that if called to the carpet, a settlement can be reached for 10 or 20 percent of the gains.

        I don’t know… the whole thing seems so slip shod in its construct. Do you put your good name, reputation, license, company, shareholders on black and let-er spin thinking your odds are pretty good?

        While lawyers are not generally within the regulatory purview of the FTC, those offering support services and conduits are. Nationwide & Eclipse participation will come out in great detail during the discovery phase of the IL AG action against LHDR if the case progresses to that level. Those support services are unlikely to be viewed as work product.

        When compared with a concerted effort put forward by multiple attorney generals against some of these outfits using their own states Unfair & Deceptive Acts as the premise of their case, some targets may have preferred to have dealt with the FTC in one action instead.

        I know this thread is about Global Client Solutions and the Washington state issue, but this entire topic has captured my curiosity. I apologize for drifting off topic, though in a somewhat connected way.

      • Vend2003-info

        Calculator, you have really dug into this. I’m pretty much done here, it is obvious what was going on and who is at the center of it as far as making it possible/easier by processing the transactions. This involves DS companies from all over the U.S. Whether the scheme is legal or not is up to the “powers”. Either way, GCS was not an innocent bystander.

        I mainly wanted to make sure that Global’s Debt Manager was brought up since it was not mentioned in the descriptions of what they do. BTW, didn’t GCS start using MidFirst Bank last year? Not sure if it was part of the LHDR caper or just because Rocky Mt. was getting too “hot”. Wonder how MidFirst escaped this? Don’t see them named (yet).

      • Calculator

        Vend, your bringing up the Debt Manager attribute is the only place I have seen the reference.

        You refer to your interest in this topic winding down in your comment above. Mine is just getting started. If you would not mind and if it is not too much trouble, could you comment with more information about GCS once using Rocky Mt. and how they now use MidFirst Bank?

        What happened?

      • Vend2003-info

        Calculator, I don’t know details of exactly when/why they switched or added MidFirst. I do know that in 2010 the “Phone Pay” option in Debt Manager had to be modified for some DS companies to send the correct value for MidFirst phone pay.

        Took forever, but I found this doc via Google…
        http://www.1stamericands.com/Welcome-Package-Sample.pdf

        MoneyGram Instructions:
        Agent locator – http://www.moneygram.com
        Sending Instructions
        Pay to – Global Client Solutions – MidFirst
        Receive Code – 7273
        Account # – ‘DR’+ last 8 digits of your 16-digit acct #
        (Example: DR12345678)

        Apparently their association was not publicized, but this proves the collaboration.

        That’s about all I can provide on GCS/MidFirst, not my area of expertise concerning GCS.

        I wouldn’t say my interest in the topic is dwindling, but my posting here is getting repetitive. You can email me at the vend2003 email address if you have questions along the way.

  • Calculator

    Ah… You are ahead of me on this. I commented on Escrow firm implications over on the LHDR article.

    NoteWorld is headquartered in Washington are they not?
    Does NoteWorld have more to be concerned with here than Rocky et al?

    Might be wise to begin spring cleaning early this year.

  • Calculator

    Ah… You are ahead of me on this. I commented on Escrow firm implications over on the LHDR article.

    NoteWorld is headquartered in Washington are they not?
    Does NoteWorld have more to be concerned with here than Rocky et al?

    Might be wise to begin spring cleaning early this year.

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