A reader forwarded to me a debt relief services contract from Boulder Legal Group that says it is the services of the Law Offices of Camron Hoorfar in Summit Missouri. The agreement certainly appears to include costs and fees in advance of settling the debt.
What makes this contract even more interesting is the Global Client Solutions service contract that is included.
Considering the actions taken by the Consumer Financial Protection Bureau (CFPB) against Global Client Solutions (GCS) in which the CFPB announced they took action against GCS in the form of a complaint and court order.
The CFPB had said, “The CFPB alleges that Global Client Solutions and its two principals, Robert Merrick and Michael Hendrix, violated the Telemarketing Sales Rule by making it possible for debt-settlement companies to charge consumers illegal upfront fees. The rule prohibits debt-settlement companies from charging consumers advance fees before settling any of their debts. The rule protects consumers from the risk of spending money on services that may not materialize and may ultimately leave them even worse off.
According to the CFPB’s complaint, since October 2010, Global Client Solutions processed tens of millions of dollars in illegal advance fees from tens of thousands of consumers. Global Client Solutions processed these unlawful fees on behalf of hundreds of debt relief companies across the country.
Today’s proposed order bans Global Client Solutions from enabling other companies to collect illegal fees from consumers. The defendants will be subject to monitoring by the CFPB and will be required to make reports to the CFPB to ensure their compliance. The defendants will also pay over $6 million in consumer relief in addition to paying a civil money penalty of $1 million.”
Bolder Legal Group, LLC listed it’s two members on their Arizona corporate registration as Rick Gustafson from Chicago, and Camron Hoorfar. A Rick Gustafson was a partner with Legal Helpers and appears to have been involved with bankruptcy services. – Source, Source, Source
I attempted to contact GCS for feedback on this contract but their contact form does not work and I did email Camron Hoofar, Esq. for a comment as well.
The client agreement says the services that will be performed are, “Pursuant to this agreement’s terms, Boulder will assist you with the resolution of burdensome debt, and as such, the Representation contemplated in this Agreement is referred to as a Debt Resolution Program. In return for Boulder’s services, you agree to pay specific amounts to Boulder, as specified in this Agreement and its enclosures.”
More specifically, “Boulder’s services are performed by a group of professionals, including attorneys, paralegals, negotiators, assistants, and others. Attorneys directly supervise the activities they do not directly perform. Boulder will perform the various services described in this section.
1.1. Debt Analysis
Boulder will review Client’s personal hardship and other debt circumstances and formulate a plan to negotiate improved terms.
1.2. Negotiate and Resolve Client Debt
Boulder will undertake representation of Client regarding specific, unsecured debts listed in the Creditor List enclosed with this agreement. Representation related to any debt is governed by the promises and limitations discussed throughout this agreement.
1.3. Litigation Defense Services
Boulder will advise and represent Clients in their defense of litigation initiated by creditors or collectors to recover debts listed in this agreement. Boulder attorneys are immediately notified of litigation, and may be assigned to address any litigation served on Client after the effective date of this agreement. Litigation services are further conditioned and limited by other terms of this agreement, circumstances of practicality, and jurisdictional rules.
1.4. Services Not within Scope of Representation
Boulder’s services are limited to those specifically listed above. This means that Boulder will not provide accounting, financial planning, or tax advice. Boulder does not engage in credit repair or credit reporting. Boulder does not attempt to resolve debts on which a judgment has been obtained. Bankruptcy services, and defense or prosecution of any debt not listed in this agreement are outside the scope of representation. Further, Boulder cannot guarantee that creditor or collector harassment will cease at any point in the representation. However, under some circumstances, Boulder may take appropriate legal action against creditors or collectors engaged in illegal activity.
1.5. Work Performed by Contracted Parties
Boulder Legal Group may contract work relating to this Agreement to third parties for such tasks including, but not limited to customer service and debt negotiations. Boulder attorneys will supervise all third party entities to ensure contracted services comply with Boulder’s rules and regulations.
1.6. Litigation Defense Services
Creditors and/or debt collectors may file lawsuit(s) against Client in order to collect non-payment of owed debt(s). Boulder will provide Litigation Defense Services in the event the client receives a Summons and Complaint. Boulders Litigation services and limitations include: – Source
It appears the agreement includes an attempt to get around the Telemarketing Sales Rule by utilizing a face-to-face meeting with the consumer. It’s not a difficult assumption to make since the agreement says as much, “This Affidavit of Compliance establishes a written record to verify compliance with any and all applicable local, state or federal laws or regulations (collectively the “Applicable Laws”), including, but not limited, to the Telemarketing and Consumer Fraud and Abuse Prevention Act, 15 U.S.C. 6101-08, and the Telemarketing Sales Rule, as amended, 16 C.F.R. Part 310; 75 Fed. Reg. 48458, 48522.”
If I hear back from Camron Hoorfar or Boulder Legal Group with a comment, I’ll add their statement to this post.