Debt Relief Industry Marketing

Legal Helpers Debt Resolution Beta Testing Face-to-Face Meetings

A tipster (send in your tips here) sent me information that Legal Helpers Debt Resolution is moving ahead with their plan to continue selling advanced fee debt settlement services through their “hopefully” complaint avoidance of the new FTC telemarketing sales rules.

Apparently in the Los Angeles – Orange County area they have had some agents going out and meeting with people face-to-face recently. I can’t revel too much but I can tell you the meetings have identified some problems and issues that could create client dissatisfaction.

This is not a new avenue for me. When I was in England I was part of a test where I worked with a group to send out field agents to meet with people and gather documents in an attempt to offer higher levels of customer service, not to get around any regulation. What I learned is the process has a number of issues that need to be dealt with and a lot of off script stuff can happen with a field agent sitting in front of a potential client.

I’ll bet you that off script stuff that is going to potentially land some debt settlement companies, that want to skirt the law, in hot water.

All I can do is report and offer my opinion and after having tried something similar myself there is no way I’d do it again.


I can always use your help. If you have a tip or information you want to share, you can get it to me confidentially if you click here.

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About the author

Steve Rhode

Steve Rhode is the Get Out of Debt Guy and has been helping good people with bad debt problems since 1994. You can learn more about Steve, here.

22 Comments

  • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

    Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

    Here is what the FTC says:

    Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

    Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

    Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

  • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

    Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

    Here is what the FTC says:

    Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

    Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

    Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

  • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

    Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

    Here is what the FTC says:

    Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

    Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

    Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

  • I am a field agent who is going to work for LHDR.I have no idea what they do. Should I be scared about something? This is my first job and I am very confused. With the limited oppurtunities available in this market I was happy that I found a job but after doing some research I am quite skeptical if I should go ahead with this job. Please advise.

  • I am a field agent who is going to work for LHDR.I have no idea what they do. Should I be scared about something? This is my first job and I am very confused. With the limited oppurtunities available in this market I was happy that I found a job but after doing some research I am quite skeptical if I should go ahead with this job. Please advise.

    • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

      Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

      Here is what the FTC says:

      Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

      Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

      Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

    • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

      Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

      Here is what the FTC says:

      Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

      Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

      Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

    • I’d like to help you further. Can you please share with me the duties you would be carrying out and how you will be paid per visit.

      Just from your comment my initial concern is that according to the FTC public statements if a face-to-face meeting is going to occur then the face-to-face meeting must take place before the sale is completed. The meeting should be an actual sale presentation to the buyer but my warning bells went off when you said you did not know what LHDR did.

      Here is what the FTC says:

      Suppose my company hires someone to meet with potential customers before we sign them up for our service. Do we qualify for the face-to-face exemption to the TSR?

      Under the Rule, whether a particular telemarketing transaction qualifies for the face-to-face exemption will depend on the facts of each case. A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer. The key to the face-to-face exemption is the direct and personal contact between the buyer and seller. You can’t get around the Rule by hiring representatives just to hold cursory pre-enrollment meetings with potential customers.

      Keep in mind that, if you or your employee give a sales presentation away from your usual place of business, like at the consumer’s home, you must comply with the FTC’s Cooling Off Rule. This Rule gives customers the right to cancel agreements with you within three days of signing up. It also requires you to tell customers about their right to cancel and to give them a cancellation form to use if they decide to exercise that right. Note that even when the TSR doesn’t apply to a transaction, Section 5 of the FTC Act and state laws do, and compliance is your responsibility. – Source

  • More importantly it seems as if the meeting does not even meet the requirements of a face-to-face exemption since it sounds like the consumer has already been sold prior to the meeting.

    “A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer.”

    How much do you want to bet that there was already some telemarketing going on prior to this meeting?

    Steve

  • Apparently they just…don’t…care! I overheard a rep working for one of it’s affiliates state that she, her manager, the client would all sit down for that “compliance” meeting, at a conveniently located designated place (ie., Starbucks??!!) to conduct the meeting and sign docs…huh??? Not only now is this prospective client having to go out of his/her way and make time in their schedule….but they arent even meeting with attorneys??

  • I am wondering if this is the new Plan that Mr. Macey indicated that I would be pleased about? I have one question and it deserves a simple answer.

    Does legal helpers simply not understand how a front loaded debt settlement fee structure damages consumers, or do they simply not care?

    Those are the only two options and I would like an answer on that.

  • I am wondering if this is the new Plan that Mr. Macey indicated that I would be pleased about? I have one question and it deserves a simple answer.

    Does legal helpers simply not understand how a front loaded debt settlement fee structure damages consumers, or do they simply not care?

    Those are the only two options and I would like an answer on that.

    • Apparently they just…don’t…care! I overheard a rep working for one of it’s affiliates state that she, her manager, the client would all sit down for that “compliance” meeting, at a conveniently located designated place (ie., Starbucks??!!) to conduct the meeting and sign docs…huh??? Not only now is this prospective client having to go out of his/her way and make time in their schedule….but they arent even meeting with attorneys??

      • More importantly it seems as if the meeting does not even meet the requirements of a face-to-face exemption since it sounds like the consumer has already been sold prior to the meeting.

        “A telemarketing transaction qualifies for the exemption if: (1) the face-to-face meeting takes place before the sale is completed and before the consumer is required to pay or authorize payment; and (2) the meeting includes an actual sales presentation to the buyer.”

        How much do you want to bet that there was already some telemarketing going on prior to this meeting?

        Steve

  • Meeting with a field agent hired at a couple bucks to get doc’s signed…. Does that equal “face to face”?

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