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The Wild Ride in Debt Relief – Andrew Housser

The Wild Ride in Debt Relief   Andrew HousserThe following guest post was contributed by Andrew Houser.

Andrew Housser is co-founder and co-CEO of Freedom Financial Network, LLC, the parent of Freedom Debt Relief, which has settled over $1 billion in debt for its customers in the past 8 years. He sits on the executive board of the American Fair Credit Council (formerly TASC), a position he has held since 2006. Andrew received his MBA from Stanford Business School, where he was an Arjay Miller Scholar and he received a B.A. from Dartmouth College Summa Cum Laude and Phi Beta Kappa.

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Debt relief companies across the US have had quite a wild ride the last couple of years. Changing state regulations, federal legislation proposed by Senator Schumer last year that could have crippled our industry, and the new FTC debt relief rules, including the advance fee ban, have made for a stressful year. Combine that with lower aggregate levels of consumer debt nationwide and we are seeing the most rapidly changing business environment in our industry’s short history.

There are so many changes it could make your head spin. But one thing hasn’t changed. It’s the needs of the people using our services. We’ve been listening to our customers for years- and what they’re saying has been pretty constant. They care about solving their debt problems. They care about getting back on solid financial footing for themselves and their families. They care about trusting the companies they do business with and finding a real advocate who will stick up for them. Do consumers care about the problems currently facing debt relief companies? Not really.

But we have always known that meeting our customers’ needs is what makes us successful. That is why we are supporters of the FTC rule – the regulations finally create an environment that forces companies to buy into this viewpoint. Because if you are not meeting your customers’ needs in the post-FTC world, you won’t be in business for long. Furthermore, the new regulations finally give consumers the confidence to know that they will only pay for results, and that confidence can only help our industry in the long run. It’s this focus on the consumers we are serving, and the bright line distinction between compliance and non compliance with the FTC rule that led TASC to change its name to the American Fair Credit Council, with a new mission focused on the consumers we serve and on compliance with the FTC rules.

But, to be sure, it is going to be a lot of work in the years ahead for debt relief businesses. What does it mean to the businesses struggling for success in this new post-FTC world?

The first big challenge is continuing to invest in customer service and negotiations at a time when no revenue is coming in the door. Efficiency is key, and providing high-quality service in the most efficient manner is certainly a challenge. At the same time you are driving for efficiency in your organization, you cannot lower the levels of service you are providing to your customers. This is an emotional, high-touch program – and your customers demand a high level of service. You need to have the staff to answer the phone when they call you, and to negotiate resolution on their debts quickly. This requires investment – both time and money. This industry is no longer for short-timers. You have to be willing to invest a ton of effort, and be willing to run a business that loses money for at least a couple years in order to build a long-term sustainable no advance fee company. Having an industry filled solely with companies that are taking a long term view can only be good for consumers as well.

Another challenge we face is how do you keep customers committed to the program when they have no “skin in the game”?  Providing successful resolution as early as possible in the program and keeping steady contact with your customers as they progress through the program is key. The good news is that in a no advance fee world, you should be able to negotiate accounts earlier in the program and give your customers some early wins. The bad news is that the old reasons why customers drop from programs still remain- such as difficulty making program payments. Appropriate screening up front (what many in our industry call underwriting) is something we have always advocated, and it is now more important than ever.

And, as to the future legislative focus of the new AFCC? We believe that new legislation (both state and federal) should focus on closing FTC loopholes/exemptions, not on adding additional burdens on the good companies trying to do the right thing. The “loopholers” are making it more difficult for the good companies by continuing to drive sky high customer acquisition costs and by continuing to paint our industry in a negative light. The good companies that are living within the constraints of the advance fee ban are struggling with delayed revenues and are reducing costs, and they are committed to helping consumers in need over the long term. We firmly believe that adding burdensome state regulations and arbitrary fee caps on top of the FTC Rule at a time when good companies are struggling to live with the guidelines is counter-productive and bad for consumers.  Doing full service debt settlement right requires a high caliber workforce, and a significant amount of labor. The FTC did recognize this, and despite their decision to regulate the way in which our industry charges fees, they also recognized the benefit of consumer choice in the marketplace. If consumers want to pay more for a higher level of service, or less for a “self directed” settlement model, they should be able to make the choice for themselves, as long as the company is only charging a fee after getting results. Fortunately, in the wake of the FTC regulations, several states seem to agree with this sentiment and have enacted laws that do not cap fees for companies that are operating within the constraints of the FTC rules.

At the end of the day, serving customer needs is the key that unlocks the door for all good debt relief companies. Our customers care about whether we’ll defend and protect them from others. They care about the services available and whether they will be successful in getting their debts resolved. They care that we’ll be their advocates. That’s what they care about and it’s what we need to care about too.

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  • James Hutton

    How come you have no response to the bait & switch tactics used by Rescue One Financial..You are okay with what they are doing? Or are you the President of the vulture club?? We have heard from different sources what a arrogant sob & condescending crook you really are..How can you not have a comment on the Bait & Switch to entice people to call & flip them into your debt settlement program..How come Rescue One Financial is not a regulated lender in California?? I hope your partnership with Rescue One Financial is closed down by FTC & state regulators..

  • Tony

    The first big challenge is continuing to invest in customer service and negotiations at a time when no revenue is coming in the door. – REALLY? no revenue huh? You guys have been in business how long? I think it’s hilarious that DS Executive’s make it seem like the performance based model is a new thing and it’s so hard to accomplish. Also, Tasc changing names is an absolute joke… Andrew, you being a part of tasc surprises me considering Tasc’s track record and the people who founded and have sat on the board these years. I can name a dozen that have either robbed consumers through their own company or robbed front end  companies submitting deals on what they were told was a legitimate model and business plan.

    The performance based model isn’t difficult to execute. I agree yes it does take time and effort and the willingness to lose some money. However, its just like any other start up business.

    TASC and its following put together the most deceptive brochure that convinced most that with a minimal invest you can make millions with DS. 50% of the people I know in the business barely got their money back if that, charging 15-20% UP FRONT, 25-30% went out of business on their own or got screwed their residual when a tasc member decided not to pay anymore. The rest may have made a little money.

    The best part is this front end model was passed out like ecstasy at a rave to ANYONE. Then companies like SAFETRUST/LHDR/GHS/DEBTREM/SQUAREONE/ECLIPSE ETC.. got on the wagon and see ya later consumer… Literally if you put everyone who was ever associated with TASC in a room and locked the door 10 years ago, this DS world would be a better place 

    Most companies that started in DS before the industry became popular were performance based and there were no issues. The big change came with bigger companies like FDR, Nationwide, Acushield/ Debtco, EFA CNI, HOMELAND, HESS ETC… that allowed every tom dick and harry to become a front end and start selling DS to the masses. this forced lead cost  up and there was a need for more money up front to cover this rising lead costs..thanks for that. Also, up front fees are more attractive to get affiliates right, especially from the mortgage industry that was lining up to become front ends.I am laughing looking at the executive board. You have an attorney that will accept money to explain how to find a loopholes and embraces companies currently doing it. Not to mention, an attorney that was promoting the loan mod/auto warranty industry 2 months before the FTC announced the amended TSR. I have an e-mail somewhere that was a sales pitch essentially comparing the the profits from DS to auto warranty and loan mod and the attorney on the board here was the poster boy. You have members paying huge dues waiting for answers on the fate of their business and the guy who should be comforting them is promoting a different business. Century Negotiations, board at large.. should I type more? DMB huh? Have you visited their office?Jesse, isn’t your company processing for world law group? Maybe thats just a rumor, I don’t know.. could be wrong.. TASC was literally a yellow page for the FTC.Do you have any idea what the companies in your vendor section do to provide marketing to your members and non members?  Seriously?Thanks for your contribution. Tell everyone at tasc thanks too.Anyone who reads this, if your serious about getting out of debt… do it yourself.http://www.zipdebt.com/  I have been following Charles for years and hands down he knows more than anyone I know about this game… anyone…If your reading this and want to get into the business,I have done performance based and up front fee debt settlement… they are equally challenging.. if you’re starting a business broke and without a plan, shame on you anyway.. but don’t shy away from this business and definitely DO NOT associate with anyone that is or has previously been with tasc. Also, learn how to generate your own leads, trust me. Andrew does

  • Tony

     The first big challenge is continuing to invest in customer service and negotiations at a time when no revenue is coming in the door. – REALLY? no revenue huh? You guys have been in business how long? I think it’s hilarious that DS Executive’s make it seem like the performance based model is a new thing and it’s so hard to accomplish. Also, Tasc changing names is an absolute joke… Andrew, you being a part of tasc surprises me considering Tasc’s track record and the people who founded and have sat on the board these years. I can name a dozen that have either robbed consumers through their own company or robbed front end  companies submitting deals on what they were told was a legitimate model and business plan.

    The performance based model isn’t difficult to execute. I agree yes it does take time and effort and the willingness to lose some money. However, its just like any other start up business.

    TASC and its following put together the most deceptive brochure that convinced most that with a minimal invest you can make millions with DS. 50% of the people I know in the business barely got their money back if that, charging 15-20% UP FRONT, 25-30% went out of business on their own or got screwed their residual when a tasc member decided not to pay anymore. The rest may have made a little money.

    The best part is this front end model was passed out like ecstasy at a rave to ANYONE. Then companies like SAFETRUST/LHDR/GHS/DEBTREM/SQUAREONE/ECLIPSE ETC.. got on the wagon and see ya later consumer… Literally if you put everyone who was ever associated with TASC in a room and locked the door 10 years ago, this DS world would be a better place 

    Most companies that started in DS before the industry became popular were performance based and there were no issues. The big change came with bigger companies like FDR, Nationwide, Acushield/ Debtco, EFA CNI, HOMELAND, HESS ETC… that allowed every tom dick and harry to become a front end and start selling DS to the masses. this forced lead cost  up and there was a need for more money up front to cover this rising lead costs..thanks for that. Also, up front fees are more attractive to get affiliates right, especially from the mortgage industry that was lining up to become front ends.I am laughing looking at the executive board. You have an attorney that will accept money to explain how to find a loopholes and embraces companies currently doing it. Not to mention, an attorney that was promoting the loan mod/auto warranty industry 2 months before the FTC announced the amended TSR. I have an e-mail somewhere that was a sales pitch essentially comparing the the profits from DS to auto warranty and loan mod and the attorney on the board here was the poster boy. You have members paying huge dues waiting for answers on the fate of their business and the guy who should be comforting them is promoting a different business. Century Negotiations, board at large.. should I type more? DMB huh? Have you visited their office?Jesse, isn’t your company processing for world law group? Maybe thats just a rumor, I don’t know.. could be wrong.. TASC was literally a yellow page for the FTC.Do you have any idea what the companies in your vendor section do to provide marketing to your members and non members?  Seriously?Thanks for your contribution. Tell everyone at tasc thanks too.Anyone who reads this, if your serious about getting out of debt… do it yourself.http://www.zipdebt.com/  I have been following Charles for years and hands down he knows more than anyone I know about this game… anyone…If your reading this and want to get into the business,I have done performance based and up front fee debt settlement… they are equally challenging.. if you’re starting a business broke and without a plan, shame on you anyway.. but don’t shy away from this business and definitely DO NOT associate with anyone that is or has previously been with tasc. Also, learn how to generate your own leads, trust me. Andrew does

  • Errick

    What, you mean track records like this one?

    “This testimonial is based on the experience of one person; you may not
    experience similar results. Jessica from Los Angeles, CA resolved her
    initial debt of $14,568.00 for $6,477.00 and paid $2,185.20 in fees,
    thereby completing her debt resolution program in 19 months. Clients who
    make all their monthly program payments pay approximately 50% of their
    enrolled balance before fees, or 71% including fees, over 24 to 48
    months.”

    Let’s see, that’s $8,662 over 19 months, which comes to $455.90 per month.  Boy this lady was in real trouble before she found you, yes-siree.  Of course, she could have just, I don’t know, paid her credit cards!  Where’s my amortization table.  Ah yesss, $455.90 per month, 24 percent interest, carry the seven, all the bills are paid off in 52 MONTHS.  In full.  And that’s if no creditor offers her a program.

    One of these days Chase or Citi will care enough about you guys to sue your asses for intentional interference with lawful contractual relations (lawful economic advantage, for you west coasters).

  • Errick

    No I am not, but if I were I would have this information.

  • Steve Rhode

    @cd332fa4afe4844f44a6c28c193130ac:disqus  I just want to give you a hat tip for submitting your guest post to the site. And I welcome others like Jesse ( @84c19f15bcf1c447fe9138b5428103f8:disqus  ) to the site as well. Since the AFCC has embraced consumer protection and advocacy as its primary mission, together we can all share and learn together.

    More importantly, the faster we all ferret out the bad actors in the debt relief space the sooner regulators will not need to spend as much time focusing on debt relief and we can all just concentrate on doing the right thing.

    Steve

  • Huh?

    the suspicion is a reflex these days. i tip my hat to the clean up crew
    assigned to the spill. not everyone shares the same view points in the
    industry and i would not be surprised by what could turn up in a window
    shopping effort. spill on isle 3 could be what we hear next. then spill
    on isle 5 and so on. i dont know that this type of discovery would
    impede the new tude and the direction afcc is going. it would be an
    opportunity to root out some bad elements and show sincerity. the roto
    rooting was missing from the group formerly known as tasc.. something
    with some kick to it would be the appropriate sauce for an untasty dish.

  • Steve Rhode

    Jesse,

    I thought you would enjoy it and I’d love for you to pose some of your questions to the attorney in the comments on that story to get his feedback.

    I totally hear you on the attorney model loophole issue and agree that there is great abuse in that area. What really amplifies the abuse is that since the TSR passed other companies are no longer engaged in similar advanced behavior and I’m glad to see companies now embracing a performance model. That makes the advanced fee model look apparently egregious to those now not charging.

    It appears to me the sticky issue in the attorney model situation is the claim by lawyers they are operating in their normal course of business with an attorney-client relationship and are thus exempt from regulations intended to protect consumers.

    And on one hand that claim can be made but there are many to be made on the other side. These issues include the abandonment of the attorney fiduciary responsibility to the client, fee splitting, marketing fibs, taking cash for services not rendered, no refunds, etc.

    Many of us would like to see some clarity from enforcement actions. Illinois has their action against Legal Helpers Debt Resolution, the FTC has ongoing investigations, North Carolina has their action against Consumer Law Group that I’ve covered, and I’m sure there are others I’m leaving out.

    Interestingly, Greenspoon Marder represents some of these legal firms that are trying to continue these activities and they are tied closely to TASC (AFCC). Curious. Conflict?

    The law firms will drag these challenges out for as long as possible and until there are rulings against advanced fee attorney model operations, we sit and wait.

    The heart of the matter appears to be what constitutes an attorney relationship between a consumer and an attorney. North Carolina was clear what they felt did and so did that attorney post I sent you.

    I don’t think you or I would have a problem with an attorney holding client funds in an attorney trust account, billing for service rendered and collecting the funds directly from the consumer, did not split fees with marketers, and the attorney also handled the client files and negotiated the debt themselves. That was the loophole the FTC intended. But that’s not what is happening with these legal models.

  • Robert Stevenson

    can we get some information on where the suspicions come from? I am not doubting the claim, but curious to try and put pieces of the puzzle together. 

    Having companies do this ruins the integrity of the organization. I imagine a quick “audit” would be fairly simple… Call the companies and pose as consumers from a “red” state and see if you are referred or given different forms.

  • Huh?

    thank you sir

  • Jesse

    I can’t speak for TASC and I have no authority to do that as that is the job of our board and executive team.  I do know that all clients we enroll in our programs follow the FTC rule.

  • Huh?

    jesse – i appreciate the new tude tasc come afcc has toward adherence to form and spirit of upfront fee ban. can you tell me if afcc or tasc members refer any clients whatsover to non compliant companies like legal models or other such obfuscatinators in states they call red ones? who audits that? words are good for communicating but actions are a bullhorn.

  • Jesse

    Steve,

    I read the post you mentioned.  It was very eloquently written and I applaud the author for the various questions being raised and the candor in the matter.  I am, however, unclear how you would like to respond or more importantly, to which part.  My argument was to challenge up front legal models who are flouting the FTC rule.  The article you mention could be debated on many different levels before any one opinion could prevail over another.  I’m not opposed to stating a position, but would like to stick to what is germain to my one area of grave concern – up front fees.

    I would like to address one issue at a time, and in this instance, I am challenging anyone who believes the intent of the FTC rule was to allow legal models to operate in such a manner whereby they are charging upfront fees. 

    I was at the TASC conference and listened to the very candid and intelligent discussion provided by the FTC during the teleconference session on day 2.  I know their intent, it was clear as day.  I was also very happy with the outcome which is why I am an ardent supporter (as is TASC, now the AFCC) of strict adherence to the FTC rules.

    Jesse

  • Jesse

    Hi Steve,

    glad to respond.  I see its a longer post and will give it a thorough read first.

    Jesse

  • Robert Stevenson

    here we go with your crazy rants. Are you a former owner of a credit counseling company that went out of business? Even that gives you too much credit… Go back to playing tetherball

  • Steve Rhode

    Jesse,

    Glad to have you here on the site.

    I think your willingness to tackle these issues would be welcomed as well on this other recent post. I’d love to see your response to that one from the debt settlement attorney.

    Steve

  • Jesse

    Bravo Andrew.  I think FDR’s retention rates, integrity, and track record speaks for itself.  The fact of the matter is that FDR is still strong and doing good business to help consumers post FTC ruling.  The capital requirement to do this for 2 years before making any positive return on the investment speaks highly for FDR’s commitment to this industry.  If they were in business for a “quick buck” like so many former sub-prime mortgage brokers who found the “next best thing” after the mortgage implosion, then they would not be continuing to be so dedicated to the mission of debt settlement by honest players – to help consumers first and foremost.

    My name is Jesse Torres, and I’m the CEO of Debtmerica.  I have nothing to hide either and that’s why I’m not afraid to state my name here.  Up front legal models…you know what you are doing, and you know it violates the intent of the FTC rule and hurts honest players…give me any argument and I would be glad to rebut it.  Try me.

    Jesse Torres
    CEO
    Debtmerica LLC

  • Jesse

    Bravo Andrew.  I think FDR’s retention rates, integrity, and track record speaks for itself.  The fact of the matter is that FDR is still strong and doing good business to help consumers post FTC ruling.  The capital requirement to do this for 2 years before making any positive return on the investment speaks highly for FDR’s commitment to this industry.  If they were in business for a “quick buck” like so many former sub-prime mortgage brokers who found the “next best thing” after the mortgage implosion, then they would not be continuing to be so dedicated to the mission of debt settlement by honest players – to help consumers first and foremost.

    My name is Jesse Torres, and I’m the CEO of Debtmerica.  I have nothing to hide either and that’s why I’m not afraid to state my name here.  Up front legal models…you know what you are doing, and you know it violates the intent of the FTC rule and hurts honest players…give me any argument and I would be glad to rebut it.  Try me.

    Jesse Torres
    CEO
    Debtmerica LLC

    • http://GetOutOfDebt.org Steve Rhode

      Jesse,

      Glad to have you here on the site.

      I think your willingness to tackle these issues would be welcomed as well on this other recent post. I’d love to see your response to that one from the debt settlement attorney.

      Steve

      • Jesse

        Hi Steve,

        glad to respond.  I see its a longer post and will give it a thorough read first.

        Jesse

      • Jesse

         Steve,

        I read the post you mentioned.  It was very eloquently written and I applaud the author for the various questions being raised and the candor in the matter.  I am, however, unclear how you would like to respond or more importantly, to which part.  My argument was to challenge up front legal models who are flouting the FTC rule.  The article you mention could be debated on many different levels before any one opinion could prevail over another.  I’m not opposed to stating a position, but would like to stick to what is germain to my one area of grave concern – up front fees.

        I would like to address one issue at a time, and in this instance, I am challenging anyone who believes the intent of the FTC rule was to allow legal models to operate in such a manner whereby they are charging upfront fees. 

        I was at the TASC conference and listened to the very candid and intelligent discussion provided by the FTC during the teleconference session on day 2.  I know their intent, it was clear as day.  I was also very happy with the outcome which is why I am an ardent supporter (as is TASC, now the AFCC) of strict adherence to the FTC rules.

        Jesse

      • Huh?

        jesse – i appreciate the new tude tasc come afcc has toward adherence to form and spirit of upfront fee ban. can you tell me if afcc or tasc members refer any clients whatsover to non compliant companies like legal models or other such obfuscatinators in states they call red ones? who audits that? words are good for communicating but actions are a bullhorn.

      • Jesse

        I can’t speak for TASC and I have no authority to do that as that is the job of our board and executive team.  I do know that all clients we enroll in our programs follow the FTC rule.

      • Huh?

        thank you sir

      • Robert Stevenson

         can we get some information on where the suspicions come from? I am not doubting the claim, but curious to try and put pieces of the puzzle together. 

        Having companies do this ruins the integrity of the organization. I imagine a quick “audit” would be fairly simple… Call the companies and pose as consumers from a “red” state and see if you are referred or given different forms.

      • Huh?

        the suspicion is a reflex these days. i tip my hat to the clean up crew
        assigned to the spill. not everyone shares the same view points in the
        industry and i would not be surprised by what could turn up in a window
        shopping effort. spill on isle 3 could be what we hear next. then spill
        on isle 5 and so on. i dont know that this type of discovery would
        impede the new tude and the direction afcc is going. it would be an
        opportunity to root out some bad elements and show sincerity. the roto
        rooting was missing from the group formerly known as tasc.. something
        with some kick to it would be the appropriate sauce for an untasty dish. 

      • http://GetOutOfDebt.org Steve Rhode

        Jesse,

        I thought you would enjoy it and I’d love for you to pose some of your questions to the attorney in the comments on that story to get his feedback.

        I totally hear you on the attorney model loophole issue and agree that there is great abuse in that area. What really amplifies the abuse is that since the TSR passed other companies are no longer engaged in similar advanced behavior and I’m glad to see companies now embracing a performance model. That makes the advanced fee model look apparently egregious to those now not charging.

        It appears to me the sticky issue in the attorney model situation is the claim by lawyers they are operating in their normal course of business with an attorney-client relationship and are thus exempt from regulations intended to protect consumers.

        And on one hand that claim can be made but there are many to be made on the other side. These issues include the abandonment of the attorney fiduciary responsibility to the client, fee splitting, marketing fibs, taking cash for services not rendered, no refunds, etc.

        Many of us would like to see some clarity from enforcement actions. Illinois has their action against Legal Helpers Debt Resolution, the FTC has ongoing investigations, North Carolina has their action against Consumer Law Group that I’ve covered, and I’m sure there are others I’m leaving out.

        Interestingly, Greenspoon Marder represents some of these legal firms that are trying to continue these activities and they are tied closely to TASC (AFCC). Curious. Conflict?

        The law firms will drag these challenges out for as long as possible and until there are rulings against advanced fee attorney model operations, we sit and wait.

        The heart of the matter appears to be what constitutes an attorney relationship between a consumer and an attorney. North Carolina was clear what they felt did and so did that attorney post I sent you.

        I don’t think you or I would have a problem with an attorney holding client funds in an attorney trust account, billing for service rendered and collecting the funds directly from the consumer, did not split fees with marketers, and the attorney also handled the client files and negotiated the debt themselves. That was the loophole the FTC intended. But that’s not what is happening with these legal models.

    • Errick

      What, you mean track records like this one?

      “This testimonial is based on the experience of one person; you may not
      experience similar results. Jessica from Los Angeles, CA resolved her
      initial debt of $14,568.00 for $6,477.00 and paid $2,185.20 in fees,
      thereby completing her debt resolution program in 19 months. Clients who
      make all their monthly program payments pay approximately 50% of their
      enrolled balance before fees, or 71% including fees, over 24 to 48
      months.”

      Let’s see, that’s $8,662 over 19 months, which comes to $455.90 per month.  Boy this lady was in real trouble before she found you, yes-siree.  Of course, she could have just, I don’t know, paid her credit cards!  Where’s my amortization table.  Ah yesss, $455.90 per month, 24 percent interest, carry the seven, all the bills are paid off in 52 MONTHS.  In full.  And that’s if no creditor offers her a program.

      One of these days Chase or Citi will care enough about you guys to sue your asses for intentional interference with lawful contractual relations (lawful economic advantage, for you west coasters).

  • Dave

    Andrew, great story, well written and I agree with you completely.

    Dave

  • Dave

    Andrew, great story, well written and I agree with you completely.

    Dave 

  • Andrew

    With respect to TX:
    1. the bill has been worked on since the 2009 session.
    2. the language with fees was drafted before the FTC released its rule.
    3. we thought is made sense to change the language to mirror the FTC, but others (not TASC) did not want to make changes to something all stakeholders had agreed to for fear it would cause delay and lower the chance of a successful bill.
    4. while the bill contains the old fee language, it also includes a section validating and rewarding the FTC no advance fee structure.
     
    We support the FTC advance fee rules, as we did in CO, MD, MO, and TX.  While TX technically authorizes a non-FTC fee structure, federal law obviusly prevents it in Texas, as well in every other state.  That is why we though it was better to get a law in place in TX compared to no law at all.

  • Andrew

    With respect to TX:
    1. the bill has been worked on since the 2009 session.
    2. the language with fees was drafted before the FTC released its rule.
    3. we thought is made sense to change the language to mirror the FTC, but others (not TASC) did not want to make changes to something all stakeholders had agreed to for fear it would cause delay and lower the chance of a successful bill.
    4. while the bill contains the old fee language, it also includes a section validating and rewarding the FTC no advance fee structure.
     
    We support the FTC advance fee rules, as we did in CO, MD, MO, and TX.  While TX technically authorizes a non-FTC fee structure, federal law obviusly prevents it in Texas, as well in every other state.  That is why we though it was better to get a law in place in TX compared to no law at all.
     

    • http://GetOutOfDebt.org Steve Rhode

      @cd332fa4afe4844f44a6c28c193130ac:disqus  I just want to give you a hat tip for submitting your guest post to the site. And I welcome others like Jesse ( @84c19f15bcf1c447fe9138b5428103f8:disqus  ) to the site as well. Since the AFCC has embraced consumer protection and advocacy as its primary mission, together we can all share and learn together.

      More importantly, the faster we all ferret out the bad actors in the debt relief space the sooner regulators will not need to spend as much time focusing on debt relief and we can all just concentrate on doing the right thing.

      Steve

  • Piper

    I’m curious.  If TASC (now AFCC) supports the FTC rule and wants to crack down on loopholers, why was TASC such a strong supporter of SB 141 in Texas that continues to allow up front fees and rewards companies handsomely for loopholing?

  • Piper

    I’m curious.  If TASC (now AFCC) supports the FTC rule and wants to crack down on loopholers, why was TASC such a strong supporter of SB 141 in Texas that continues to allow up front fees and rewards companies handsomely for loopholing?

  • Errick

    It’s great that you are not hiding behind your lawyers and your confidential settlement in Washington state.  That is to your credit.  So where are all these people who thank the gods they worship that they found you, and did business with you?  I can’t find any.

  • Errick

    It’s great that you are not hiding behind your lawyers and your confidential settlement in Washington state.  That is to your credit.  So where are all these people who thank the gods they worship that they found you, and did business with you?  I can’t find any.

    • Robert Stevenson

      here we go with your crazy rants. Are you a former owner of a credit counseling company that went out of business? Even that gives you too much credit… Go back to playing tetherball

      • Errick

        No I am not, but if I were I would have this information. 

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