While the new policies seem tailor-made to benefit nonprofit consumer credit counseling agencies, there is one very important fact I missed that highlights how the new Google policy actually screws most in debt relief.
To recap, the new Google Adsense debt relief advertising policy states that to even be eligible to apply for debt relief advertising in the United States the company “will need to be registered, licensed, or approved by the relevant regulatory authorities or recognized professional bodies in the country or countries they are targeting.” – Source
Additionally, they will need to be approved by the Department of Justice credit counseling or debtor education program managed by the United States Trustee Program.
This is the program that is responsible for pre and post-bankruptcy filing requirements.
But Here is the Rediculous Issue
I understand Google is in a difficult spot and someone has decided to drive this bus to solve some underlying issue. And these changes to their overall debt advertising policy impact providers in Australia, Japan, South Africa, South Korea, Spain, the United Kingdom, and the United States. – Source
In all the impacted countries Google appears to have elected to use a government or official agency to be the hurdle to cross. Here in the United States debt relief companies would also need to demonstrate they meet all state regulations and registration requirements to conduct business in their field. For credit counseling that may also mean being an IRS approved 501(c)(3) non-profit agency or at least a state formed nonprofit.
But the perfectly stupid issue here in the United States is the gatekeeper doesn’t give a damn about the quality of services delivered by an approved agency.
The United States Trustee Program (USTP) boldly states the following:
So to comply with the new Google policy a company needs to be really good at filling out forms and administrative issues and the quality of a debt relief program isn’t even a consideration.
The additional hurdles it takes to be an approved provider are such a financial and time drain that it is estimated at least half of all non-profit credit counseling agencies don’t even participate.
Just read the 33 pages of application instructions to be a credit counseling provider and make your own determination if it makes any financially responsible reason to participate in a program that has a fee cap of about $50 and an exclusion to provide services if the consumer can’t pay.
And maybe a debt relief provider just wants to apply to be a provider of a personal financial management course with the USTP. Those application instructions are only 19 pages and involve a colonoscopy as well.
And all of this doesn’t even cover the final Google debt relief provider certification process which at the time of this post, is still a mystery.
Causes and Solutions
I stand by my long-held belief that the cause of this and other regulatory actions are the chronic failures for debt relief associations, of any flavor, to police their own industry and keep the bad actors out. The most aggressive effort I’ve seen recently is the Organization of Compliant Credit Account Managers (OCCAM).
But where are the other niche trade groups in outing or shedding light on problem providers? Crickets.
Settlement folks sell against credit counselors and bankruptcy. Credit counselors sell against settlement and bankruptcy. Bankruptcy sells against settlement and credit counseling. But notice what is predominately missing, advice that is in the best interest of the consumer.
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This lack of industry policing just leaves providers like Google to bend to pressure to be some sort of gatekeeper. And it seems Google managed to develop a policy that passes the buck and shifts the blame or burden to an imperfect governmental entity that doesn’t even “guarantee the quality of its counseling or instructional services.”
So what we are left with is a new Adsense policy where everyone is unhappy with the policy except for the 50 percent of non-profit credit counseling providers and others who want to play the USTP game.
Here is What I Bet Will Happen Next
Companies will write sternly worded letters to Google and explain why the new policy is unfair. Some companies or trade groups might even sue Google to try and get a policy change. I can’t even begin to imagine the vast repetitive dollars that will be spent by each debt relief vertical to try and get Googe to change their opinion. But whatever happens, it will wind up being a circular firing squad where all the industries point at the others and smash them. This just leaves Google with a clear justification of why the new policy is a smart move if everyone is bad.
At the end of the day the debt relief industry in general needs, a third-party to point to that is not a specific niche cheerleader and it actually acts as a debt relief regulator of all solutions. Who that entity will be has yet to be embraced by most.
For decades now I’ve tried to help keep this industry I love clean by shedding light on the bad actors and stop the pollution but maybe Google has actually pushed this issue to a point where all debt relief providers will need to get along to create a solution that ends the need for silly Adsense policies like this.
Besides, we all know the very entities that Google is trying to stop are just going to rent an approved agency and do business through the backdoor. I don’t even need a crystal ball to see that.
Regulations and policies paint with a broad brush and the good guys get coated in the process. It’s time for the entire debt relief industry to put on a damn paint suit.