I Call BS on These Student Loan Assistance Companies and Urge Consumers to Do Some Research

It is simply amazing how the most innocent communication can lead to a whole truckload of crap pulling up to the loading dock.

What began as a simple inquiry led to a collection of similar sites and testimonials, web servers in Ho Chi Minh City in Vietnam, alleged call centers in Southern California and loads of potential robocalls.

There is so much more to this story that I can’t post because I’ve been unable to independently verify all the information I’ve learned along the way.

But here is what I can confidently share with you so you can understand why warning horns sounded in my head.

When digging into stories like these I try very hard to NOT create some deep conspiracy and simply stick to the details I can confirm and verify. While the hole I’m about that share feels like it runs deep, someone with a much more conspiracy-oriented mind could dig much deeper than I did and connect dots that may be dubious. That’s not my style.

Here is How This All Started

I received a copy of a service agreement for a company allegedly called Account Preparation Services. If you look at the client agreement you will notice the company has no identified address but that disputes will be resolved “exclusively by arbitration in the county which the Client resides, or the closest metropolitan county, in accordance with the Laws of the State of California for agreements to be made in and to be performed in California.” California, hum, that’s oddly specific for generally generic agreement.

A search of California corporation and LLC records could not locate any company registered to do business in California named Account Preparation Services.

The website for the company was disclosed in one of the emails from a sales representative that was passed on to me. The website was listed as accountpreparationservices.com.

One of the things I’ve learned to look for when researching are websites that share common content. This indicates to me that they apparently either have stolen content off the other sites or are related.

The Account Preparation Services website had a glowing testimonial on it.

“Dean Edelman “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Account Preparation Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – AccountPreperationServices.com

Well, either Dean Edelman has run all over the place getting the exact same assistance as claimed by Account Preparation Services or the similarities with a bunch of other websites make me nervous.

• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Sequoia Account Management I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating. – Sequoia Accounting Management
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Primary Account Solutions I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Primary Account Solutions
• ““I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Financial Loan Advisors I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Financial Loan Advisors
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Direct Account Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Direct Account Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the EDU Doc Support I was able to get qualified for a program that my servicer couldn’t offer. I am on the path to total loan forgiveness. It was the smartest move I have made since graduating.” – EDU Doc Support
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Tangible Savings Solutions I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Tangible Savings Solutions
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Financial Preparation Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Financial Preparation Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Yellowstone Account Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Yellowstone Account Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Administrative Account Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Administrative Account Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with ClearStudentLoanDebt I was able to get qualified for a program that my servicer couldn’t offer. I am on the path to total loan forgiveness. It was the smartest move I have made since graduating.” – ClearStudentLoanDebt
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Coastal Shores Financial Group I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Coastal Shores Financial Group
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Prime Document Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Prime Document Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the AdministrativeAccountingCenter I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Administrative Accounting Center
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Best Choice Financial Center I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Best Choice Financial Center
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the First Document Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – First Document Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Direct Account Services I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Direct Accounting Services
• “I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the South Coast Financial Center I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – South Coast Financial Center

I’m not going list all I found but by now you get the point.

One concern is these are all sites that were created by a lead generator that led back to Premier Student Loan Center, as one telephone representative said when questioned who they really were.

Maybe That Was Just a Coincidence But Why Are the Servers Located in Vietnam?

It seems unlikely the sites above are using the same client testimonial without permission since some of them are located on the same servers with the same Vietnam based hosting company. To me, that shows some amount of cooperation.

Vietnam server 112.78.2.174 – Source

administrativeaccountservices.com
docmanagementsolutions.com
financialaccountingcenter.com
firstchoicefinancialcenter.com
primaryaccountsolutions.com
primedocumentservices.com

Vietnam server 112.78.2.146 – Source

accountpreparationservices.com
administrativefinancial.com
coastalshoresfinancialgroup.com
directaccountservices.com
southcoastfinancialcenter.com

Vietnam server 112.78.2.50 – Source
financialloanadvisors.com
tangiblesavingssolutions.com

This was not an exhaustive search, just enough to give me confirmation the sites were more likely to have intentionally used the same “client” testimonials and that they must have some commonality since they are hosted on common servers.

The servers are reported to be located in Vietnam in “Ho Chi Minh – Ho Chi Minh City – Cong Ty Co Phan Dich Vu Du Lieu Truc Tuyen”

The fact the servers are reportedly located in Vietnam is odd and interesting. Why Vietnam of all places?

EDU Doc Support is reported to be hosted in the United States. All the domains I checked for ownership all had their registrations hidden.

By this point in my research, I can’t confirm who is behind this network of student loan assistance sites, if the companies are registered to do business, or how real they even might be.

So Let’s Turn Back to That Client Agreement I Have

Since all the sites I identified appear to be selling identical or similar services, let’s see what they are really offering by reviewing the contract.

Looking at the properties of the PDF it says it says “PDF Producer DebtPayGateway via ABC.pdf.”

Debt Pay Gateway says they currently service the debt settlement, trucking/fleet management, and maintenance and repair account industries. No mention of student loan assistance companies. – Source

On July 5, 2019, I received a message from Kris Kehler of Debt Pay Pro who reiterated, “Debt Pay Gateway does not provide payment or escrow services for the Student Loan Industry, nor have we processed payments for that company.”

Debt Pay Gateway is located in Cardiff California and is a registered California corporation. The company lists the CEO as Christopher Queen and CFO as Kristopher Kehler. – Source

I can’t confirm it was the same Debt Pay Gateway that generated the client agreement but the name in the document properties is sure an interesting coincidence if they didn’t.

The service the consumer is allegedly being sold in the agreement is described as: “Company provides document preparation services to assist consumers who are applying for federal student loan programs using Department of Education (“DOE”) forms. Company is a private company, not affiliated with any government agency, and for a fee Company will assist in assembly and completion of student loan consolidation or other application documents for student loan debt assistance programs offered by the DOE, for delivery to Client for Clients review and submission to DOE. Company is not a lender, a debt consolidation company, or a law firm and does not provide legal advice.”

They also say, “Upon receipt of all information from Client, Company shall promptly analyze Client’s situation, review the information provided by the Client, and complete the application forms required for the DOE program(s) that have been selected by the Client. Company shall prepare for filing an application to initiate a federal student loan consolidation through the DOE on behalf of Client, or alternatively and at the Client’s option, identify and apply for other DOE-sponsored programs suitable for Client. All completed applications shall be delivered by Company to Client for Client’s approval, signature and direct submission to DOE.”

This appears to say the client will have to select the program they request from the Department of Education for their federal student loan payment. The client will also have to submit the forms the client selects to the Department of Education themselves.

The client agreement in exhibit A expands on the description of services to say:

And what do they say they charge for this service in this agreement — a $1,145 enrollment fee and 239 monthly payments of $42 which equals $10,038. The company appears to make no monthly payments towards the actual student loans.

While the fee schedule refers to the first-month payment due of $1,145 as an enrollment fee, the agreement then goes on to say there are no advance fees and that money paid by the consumer are held in a client trust account until, “Client has received a consolidation, adjustment, or otherwise satisfactory result, and Client completes one payment towards such.”

While the client agreement says there is a limited refund available it also says, “Once earned through the above provision of services, all fees are non-refundable.”

So Let’s Look at One Website and See What It Tells Consumers

I went back to the original site that started all of this, accountpreparationservices.com.

The about us page is actually not about them. Rather than tell us who is really behind the company or even where the company is located it instead just talks about how they work with an unidentified “dedicated account provider.” – Source

A company who offers the types of services like Debt Pay Gateway.

They also say:

Consumer protection laws are designed to protect consumers when they do business over the phone and set payment restrictions for companies in industries similar to Account Preparation Services. These laws may not necessarily apply to our business; however, we are always making strides to comply with any such law to provide the highest standard of services available in our industry.

They also say their “goal is 100% client satisfaction” but the client agreement also says no-refunds.

Their services page says they provide three services. – Source

The contact page of the website provides scant details. There is no address listed, just a telephone number and email address.

More Websites

More websites that appear to be selling similar products and/or services are coming online right now. The website for Pacific Palm Financial Group was registered just 19 days ago from the time I’m writing this. And guess what that site has the same testimonial.

Another new website Regional Accounting Center was registered just 14 days ago. – Source

“I worked with my servicer for nearly a year attempting to lower my payment. Within 30 minutes of speaking with the Pacific Palm Financial Group I was able to get qualified for a program that my servicer never offered. I am on the path to financial freedom. It was the smartest move I have made since graduating.” – Pacific Palm Financial Group

And I also located Doc Management Solutions, Administrative Financial, Financial Accounting Center, Keystone Document Center, First Choice Financial Center, Signature Loan Solutions, and Pacific Shores Advisory.

Is This the Connection I Was Looking For or a Bridge Too Far?

Another student loan assistance website that was using the same client testimonials as I described above was Premier Student Loan Center. – Source, Source

According to online archives, a 2015 archive of the Premier Student Loan Center website had that testimonial on it.

If Premier Student Loan Center is connected to that broad network of student loan assistance sites that I identified, then we know who was identified as the president of the company.

The State of Oregon says an Albert Kim was the president of Consumer Advocacy Center that was doing business as Premier Student Loan Center. – Source

They also say the following address in Irvine California was associated with the company — 173 Technology Dr. Ste 202, Irvine, CA 92618.

The BBB says Albert Kim is the CEO as well. – Source

On March 14, 2019, the State of Oregon issued an order for the company to stop providing services in Oregon.

The order says:

“1. CAC is a California corporation doing business as PSLC. Its principal place of business is at 173 Technology Dr., Ste 202, Irvine, CA 92618.

2. Respondent’s president is Albert Kim.”

And sure enough, the State of California does have an active registered corporation where the CEO, Secretary, and CFO is Albert Kim. – Source

Consumer Advocacy Center first registered to do business in California on August 6, 2014. – Source

Employment Lawsuit Against Consumer Advocacy Center and Premier Student Loan Center

In 2017 a former employ of Consumer Advocacy Center sued them in a California court. The documents filed gave an additional set of alleged facts, including its alleged Consumer Advocacy Center ownership that included Albert Kim, Kaine Wen, Tom Nguyen who is also known as Tom Nelson.

The suit states:

“14. CAC was at all times relevant an employer covered by Cal. Gov. Code § 12940(a). Peacock was hired by CAC on August 3, 2016 as a processor and placed in CAC’s processing department. Her manager was Dinh, and Peacock worked with approximately 10 other people in the processing department. As a processor, Peacock regularly fielded calls from individuals seeking student loan debt relief, consolidation, and other assistance. Her job duties included contacting clients to verify their demographic information, requesting financial documents to submit to the Department of Education (“DOE”), filing consolidations with the DOE, and following up with clients until the process was complete.

15. Peacock was the only African-American employee in the processing department. Dinh, and all of CAC’s owners, are Asian. Over the months of Peacock’s employment, a consistent pattern developed whereby Dinh would regularly favor some of Peacock’s coworkers, to Peacock’s detriment. Upon information and belief, Peacock alleges that this favoritism was at least in part motivated by racial bias. At all relevant times, Peacock worked hard for CAC and consistently produced satisfactory numbers based on the referrals being allowed to her. Peacock was never written up or reprimanded during the course of her employment.

16. During the course of her employment, Peacock regularly worked long hours at the office, but was never paid overtime. For example, between August 3, 2016 to March 30, 2017, Peacock was not required to clock in, despite her status as a W-2 non-exempt employee, and she worked on average 13 hours each day, plus every other Saturday. After March 31, 2017, Peacock regularly clocked in and out, though she was never paid overtime rates, and Defendants told her that the commissions she made during her overtime hours would consistute her overtime pay. Peacock regularly worked 55-60 hours per week during the course of her employment with CAC.

17. During the course of her employment, Peacock was also never provided mandatory meal and rest periods as required under the California Labor Code. Instead, she was told to clock in and out for lunch, for legal purposes, but was still expected to, and in fact did, work through her lunch periods.

18. When Peacock began her employment with CAC, she was compensated directly, in her personal capacity, with “1099” income, without any applicable tax withholdings being made to her paychecks. CAC later changed this policy and beginning in January of 2017, started paying its employees W-2 wages, but also offered the option for employees to be compensated with 1099 income through S Corps. Peacock received W-2 income between January 3, 2017 and approximately the beginning of April, at which point CAC again began paying her 1099 income, but this time through an S Corp whose information Peacock provided to Nguyen. No one at CAC ever advised Peacock as to the legality or advisability of accepting wages in this fashion, and had she been properly advised, she would have never agreed to such an arrangement.

19. On or around May 22, 2017, Peacock sent an e-mail to CAC owners Kim and Wen regarding her work conditions, and complained that she was not getting an equivalent number of files each day that Dinh was giving to other processors, despite the fact that Peacock worked harder and longer hours than those processors. Wen replied to Peacock that while he understood her position, he was still in full support of Dinh’s decision-making in how she assigned files.

20. Later that week, on or around May 25, 2017, Peacock sent another e-mail to CAC owners Kim and Nguyen with a complaint about other processors, who were friends with Dinh, getting paid for work they were not completing. Specifically, Peacock disclosed that Dinh was allowing two employees, Frank Hernandez and Sal Avila, to fraudulently notate in CAC’s Customer Relationship Management system that they had completed a required task to get paid, even though they had not. Such activities constituted direct insubordination and an attempt to steal from CAC by invoicing tasks that the processors falsely claimed to have completed. It also resulted in fraudulent and unauthorized fees passed on to CAC’s clients, who are student loan borrowers. While Nguyen acknowledged receipt of Peacock’s e-mail, and agreed that the reported conduct was improper, the very next day, Peacock was fired, ostensibly for “insubordination.” Plaintiff alleges on information and belief that Defendants fired her out of a concern that she would continue to identify and complain about unlawful and/or fraudulent practices taking place at CAC, that were resulting in fraudulent charges and other prejudice to the customers of CAC.” – Source

So Where Are We Now

I think my research has at the very least raised a number of questions that any smart consumer should research before signing on the line. My primary concern is, who really is behind all of these companies with similar sites, testimonials, and living on servers in Vietnam. And again, I have no issue with Vietnam, I just find it interesting or odd, that’s all.

I would recommend that anyone considering using such a company should read the following free guides.

1. The Ultimate Consumer Guide to Checking Out a Debt Relief Company Before You Sign On the Line
2. 10 Must Do Steps to Find the Best Credit Counseling or Debt Settlement Company for You
3. How to Check Out a Business or Company to Avoid Getting Scammed or Ripped Off

If you receive a client agreement from one of these companies it would make logical sense to read it through carefully to understand the products, services, and fees you are agreeing to pay. Get all your questions answered before you enroll. Any good company will gladly make sure all your concerns are addressed before pushing you to sign.

While some of the websites I’ve mentioned to offer a very clear disclaimer that they are not doing anything you can’t do yourself and you are paying for them to fill out your free forms for you.

For example, on the Account Preparation Services website that started this whole tumble down the rabbit hole, it says:

“Disclaimer
Our number one priority is our clients. Please take the time to read our disclaimer. We want to work hard for you. However, before you become a client we want to make sure you understand our company and services fully.

Account Preparation Services specializes in federal student loan document preparation and processing services to help each borrower identify and gain approval for one or multiple government debt relief programs. Once your financial analysis is complete our agents will help you find a repayment solution that works best for you and fits your specific financial situation and goals.

We are not a government agency, the Department of Education, or your loan servicer.

Account Preparation Services is a private company, not affiliated with the government or the Department of Education. We work strictly on behalf of the borrower, for the borrower, with only the borrower’s best interest in mind. As a Client of Account Preparation Services, you will always know that you have the finest team of advocates working hard for you every step of the way.

We do not make loan payments on your behalf and loans remain in your name.

We assist in identifying appropriate government loan repayment programs and assist in document preparation to apply for the programs. Any fees that you pay to Account Preparation Services are for its services and you are responsible for repaying your loan separately.

Do it yourself without a fee – all programs are freely available for enrollment through the Department of Education.

You could do your own taxes for free, but wouldn’t you rather trust an experienced tax professional to ensure you are receiving the maximum benefits available for your unique situation? Would you feel comfortable having the IRS complete your tax return for you instead of a trusted adviser? With a record number of student loan borrowers falling victim to default each day, we at Account Preparation Services know first hand how difficult navigating these programs can be. For some, navigating through multiple loan servicers, loan structures and statuses, confusing small print, and different payment due dates every month can be overwhelming. There is no one-size-fits-all solution. We attempt to take the stress out of finding programs that meet the financial needs of our clients.

We only receive payment for our work after your loan forms are prepared, submitted, and you make your first payment on the new program.

Account Preparation Services does not take any upfront fees. To the extent that you set aside funds for our services, we are not allowed to collect them until after we have completed our work and you have made a payment on your new repayment program.

At Account Preparation Services, our employees have helped thousands of consumers find a student loan repayment plan that is more in line with their current financial situation. You can count on us to evaluate and assist you in developing a fiscal plan that better suits your desired lifestyle.”

What I can’t figure out is why a company that offers such a clear disclaimer thinks it is a good idea to potentially hide behind multiple names, with fake testimonials, and hide where they are located and registered to do business. Why?

By the way, a similar disclaimer can be found on a number of those other websites I mentioned. They share more than just testimonials.

My Final Concerns

Ultimately I’m most concerned about unsuspecting consumers being attracted to less than transparent companies and induced to enroll by a commissioned salesperson when there may be some amount of potential deception or a lack of openness involved in attracting and selling to consumers.

I would suspect a number of well-intentioned sales agents are just trying to close sales without realizing they can be named in civil or criminal complaints. Those folks can wind up in a terrible spot as well.

I would also not be surprised if there are one or more highly paid lead generators selling consumers information and/or leads to the company ultimately responsible for this network.

Just be careful everyone. That warning extends to consumers, employees or representatives of the companies and lead generators.

Nobody wants to be named in a lawsuit as an employee like Monique was, “Plaintiff alleges on information and belief that Defendant Monique Dinh (“Dinh”) is an employee of CAC, who at all times relevant herein resided in the County of Orange, State of California.”

If You Have Something to Share — Please Do

If you know something that might help me in my research on this subject, you can reach me here.

After Finishing the Post Above

After finishing the post above I asked Matt Hearn for his public point of view on what I published. Matt is someone who has a good point of view of the debt relief industry. He works with good companies to help them get and stay legal and/or complaint of state and federal regulations. He is also the founder of the Organization of Compliant Credit Account Managers (OCCAM).

Matt sent me the following response to the story above. He appears to pull no punches.

“I was asked for a response to the upcoming story about Premier and their network of associated companies.

As the founding member of OCCAM, I have first contact with consumer responses, inquiries and complaints.

After receiving an inquiry through our OCCAM Website, I reached out to one Albert Kim by phone regarding their company, Account Preparation Services and the inquiry we received.

Our initial investigations uncovered several illegal activities (FSAID Access and Collecting an Advance Fee for a Debt Relief Provider) and several areas of general non-compliance (UDAAP and Section 5).

After reviewing the research done on the company(ies) by our investigations department, and reviewing the (legally recorded) secret shopper calls, we came to understand that the company was accessing the FSAID system, creating usernames and passwords for students through the system, and generally interfacing with the DOE and/or its affiliated servicers. (SEE VERBIAGE BELOW FROM FSAID LOGIN SECTION)

It was also clear that the information they were presenting regarding their service and the programs available through the DOE to consumers was less than honest and, in several instances, misleading. Through the investigations, we uncovered that the company(ies) were collecting an advance fee via credit card, yet the contract stated in paragraph 4 that they do not collect an advance fee.

In this case, an advance fee of $1,142.00 would be collected initially and $42.00 a month is collected for the next 10-15-20 years, depending on when the DOE repayment program concludes.

Initially, Mr. Kim was interested in potentially becoming vetted through OCCAM and agreed that he needed to make some changes to their business practices.

I personally offered to consult him through my compliance consulting firm, MSTARS. They declined the offer of help. Nonetheless, the inquiry was addressed with the client, who was instructed in how to handle their current situation with them and has received a full refund.

The additional information Mr. Rhode has uncovered is disturbing on several levels. In my opinion, it appears that he/they have created a large interconnected network of business brands, websites and fictitious names that route to one provider. I could be wrong on this, but the information speaks pretty loudly here.

If a company is truly operating above board, why wouldn’t they embrace transparency in every area of their operation and present a clear offering to the consumers they purport to help?

This student loan relief vertical, if left unchecked, is destined to fail despite the fact that it is a service that could be sold legitimately and legally compliant and be of benefit to those who would pay for it.

The unfortunate part of this is that without solid leadership, hustlers and unscrupulous entrepreneurs will continue to plague the space, destroying the chances to legitimize the service for the solid operators.

One thing is certain, the regulators aren’t finished with their investigations and enforcement and won’t stop until the consumer abuses end.

Some companies believe they can operate “under the radar”. You cannot be “off the radar” if you are advertising and marketing to the masses. Every bit of consumer facing material in play is seen by not only the consumers, the media, consumer reporting sites and OCCAM, but moto the regulators.

Consumers beware. As for anyone operating in the student loan relief space, if you believe you are potentially operating illegally, we are always happy to provide advice and insight to help you plot a better course.

Note to Student Loan Relief Providers: The TSR Amendment passed in 2010 covers debt relief providers and prohibits the collection of an advance fee. It also lays out specific details on mandatory disclosures. The lawsuits brought against companies through Operation Game of Loans made very clear that this was considered a debt relief service and the TSR was applicable. Calling yourself a “Document Preparation Company” doesn’t mean that you are one. You need to understand the behaviors utilized by your companies that would be construed as “Debt Relief”. Start there.” – Matt Hearn, OCCAM.

FSAID LOGIN VERBIAGE:

Warning

You are accessing a U.S. Federal Government computer system intended to be solely accessed by individual users expressly authorized to access the system by the U.S. Department of Education. Usage may be monitored, recorded, and/or subject to audit. For security purposes and in order to ensure that the system remains available to all expressly authorized users, the U.S. Department of Education monitors the system to identify unauthorized users. Anyone using this system expressly consents to such monitoring and recording. Unauthorized use of this information system is prohibited and subject to criminal and civil penalties. Except as expressly authorized by the U.S. Department of Education, unauthorized attempts to access, obtain, upload, modify, change, and/or delete information on this system are strictly prohibited and are subject to criminal prosecution under 18 U.S.C 1030, and other applicable statutes, which may result in fines and imprisonment. For purposes of this system, unauthorized access includes, but is not limited to:

Any access by an employee or agent of a commercial entity, or other third party, who is not the individual user, for purposes of commercial advantage or private financial gain (regardless of whether the commercial entity or third party is providing a service to an authorized user of the system); and

Any access in furtherance of any criminal or tortious act in violation of the Constitution or laws of the United States or any State.

If system monitoring reveals information indicating possible criminal activity, such evidence may be provided to law enforcement personnel.”