A tipster (send in your tips here) sent me a copy of a recent email sent out by the United States Organization of Bankruptcy Alternatives (USOBA).
The email to other USOBA members is promoting a package called Life After Debt with the message;
The Life After Debt System is a consumer financial education package allowing debt settlement companies to receive an intial profit on the sale of the product as well as a monthly residual fee as their clients revice the monthly newsletter and CD. Earn at least $300 for the initial product sale plus $29 per month for as long as the client remains in the program.
The email looks almost identical to the Life After Debt site.
The system includes the following:
- Generic “I-Pad” player pre-loaded with the following modules
- 157 Page Book – “The Journey” – Reinforces the use of debt settlement as a viable option (Chapters include – the emotional price of debt, slashing spending, building wealth forever)
- “The Life after Debt” Journal – A chapter by chapter walk through of the book helping the consumer to harness the power of decision.
- Audio module with Debt Settlement Disclosures per USOBA
- Audio Module with FDCPA Guide
- Audio Module with Options for Consumers in Debt focusing on Debt Settlement as the primary solution
- Audio Module explaining the FICO credit scoring model
- PDF of an example “stop calling letter”
- PDF of the entire FDCPA
- Bonus Budgeting Software and spreadsheets
- Monthly – The “Life After Debt” Newsletter including breaking news on financial changes impacting our clients everyday lives as well as testimonials and inspiring examples of change. Wealth building, budgeting and financial guidance.
- Monthly – The “Life After Debt” CD including an Interview or monthly teaching offering guidance on wealth building, budgeting and mindset.
- Lifetime Membership and Members Only Access to our “Life After Debt” Web Education Vault. Updated monthly with videos and downloads. – Source
I don’t have a clue how much it’s going to cost but if the affiliate earns $300 on the initial sale then the price must be in the $1,200+ range. The monthly is probably in the $49 range. If anyone has any feedback on exact numbers, please post them in the comments.
Troubling for me is the fact the FTC has already addressed that debt settlement companies cannot sell mandatory products as a way to get around the advance fee ban for debt settlement companies. Some companies may use this product in that way. This could be a problem and run into trouble with the FTC Telemarketing Sale Rules for debt relief services.
The FTC’s SBP makes clear that the use of the term “service” is not intended to be limiting in any way. As a result, the Commission states that “regardless of its form, anything sold to consumers that consists [sic] of a specific group of procedures to renegotiate, settle, or in any way alter the terms of a consumer debt, is covered by the definition.” Further, “he Commission believes that this definition appropriately covers all current and reasonably foreseeable forms of debt relief services, including debt settlement, debt negotiation, and debt management, as well as lead generators for these services.”
Although the Final Rule does not include “products” in the definition of “debt relief services,” the Commission notes in the SBP that this limitation should not be “used to circumvent the rule by calling a service – in which a provider undertakes certain actions to provide assistance to the purchaser – a ‘product.’ Nor can a provider evade the rule by including a ‘product,’ such as educational material on how to manage debt, as part of the service it offers.” – Source
Because of the FTC statements on included or mandatory educational products as part of debt relief services I’d have to include this offer on my watch list of potential problems for debt settlement companies because they are getting a financial benefit from it or it is used as an upsell in conjunction with another program.
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