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Let’s Play “Do They Comply” with Debt Help Center USA & Hulk Hogan

By on October 27, 2010
Let’s Play “Do They Comply” with Debt Help Center USA & Hulk Hogan

National Media Connection is still advertising the “Hulk Team” commercials for debt settlement leads. – Source. Keeping in mind that effective today the new FTC telemarketing sales rules went into effect, I’m curious to hear what you think.

Do the ads below comply with the new rules? Post your comments below.


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About 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.

18 Comments

  1. Jason Taylor

    November 22, 2010 at 5:54 pm

    I’ll be surprised if the FTC doesn’t take enforcement after these types of ads. If indicating getting out of debt in 12-36 months, and that doesn’t happen for the TYPICAL client or the percentage of clients that this ACTUALLY occurs for is not clear and conspicuously disclosed my guess is there is big trouble ahead. Read the FTC guide for businesses, it doesn’t take a Harvard lawyer to figure out know what’s probably crossing the line.

    Whoever is running these ads better have independently verified data from the company buying the leads. I could see Terry landing himself in hot water too- he is probably just as liable, unfortunately, even if he is not up to speed with industry compliance. He likely has deeper pockets to go after than the marketer or the company buying these leads….well maybe not with his ex wife’s compensation. Seriously, for his sake hopefully he does hires someone like Loeb and Loeb to evaluate just what kind of position he is putting himself in. I wouldn’t rely on any opinion other than someone who is very familiar with the industry such one of the attorneys who were involved with the FTC in their rule making decisions.

  2. Matt

    October 28, 2010 at 7:03 pm

    Thanks for your thoughtful reply, Steve. Our current ads make no claim involving percentages or time frame, for the exact reasons you outline. That’s why I was surprised to see your comments. However, it appears that some of our media partners are still airing some of the old ads on a very limited basis. We are working to fix that ASAP as our new ads make no such claims. I’m confused about your comments regarding the 50%, though. We purposely removed any percentages for the Hulk ads because we certainly didn’t want to bring any unwanted scrutiny to a campaign that was bound to get some attention. So there’s nothing like that in the ads above. A testimonial client states in the Terry ad that his debt was reduced by nearly 50% but we make no claims or promises. We left the 12-36 months because we strongly felt we had to list some points that created value and made us competitive with the plethora of ads still airing that make several similar claims. Note that “Requires full participation in program through completion.” always appears when we make mention of this or any claims regarding the benefits of debt settlement. It’s also crucial to point out that 100% of our calls are going to one company that is fully compliant and stopped taking any up-front fees a long time ago. They are attorney based – their President is a former federal prosecutor. So every call is going to a good company that we know is compliant and doing right by their clients. We felt this was the right thing to do in the current climate to ensure that a) we continue to be a part of the solution and b) we don’t have an FTC issue. I’m confident that anything we say can be proven by our partner but at the same time I’m fully aware that fighting the government is a fool’s errand. As Robert points out so well, the difficulty lies in the number of people who drop out of the program or get enough settled to go it alone and get back on their feet. In fact, our client informs us that 89% of the clients who engage them are able to avoid bankruptcy after starting the program. Many of them still leave before it’s completed but they’re in good enough shape by that time to clean things up themselves and don’t file bk. It’s a very competitive space and it’s difficult to make much headway when everyone else is making every possible claim. I think the big key, according to our FTC attorney, is that the calls are going to a company that isn’t ripping off consumers and is doing business the right way. Hope this helps address your comments. Thanks again for your time.

    Matt

  3. Steve Rhode

    October 28, 2010 at 4:15 pm

    Just my opinion but I think the stats could be narrowed down if they were qualified on the front end. I get what you’re talking about but the impression the consumer gets is a lot different if they are told: “Of the 36% of consumers that actually settled debt, the average settlement was for 50% (using the FTC formula)”, than if consumers are given just the statement of “settle for 50%.”

    Or, “Of the 25% of clients that have settled all their debt, they did it by the 36th month.” That makes it clear to the consumer not all consumers are successful, and of those that are quantifiably successful, they did it by the 36th month.”

    Statements like that can be verified. Anyone not making a quantifiable statement that can be supported with actual data is simply playing with fire. How would anyone even begin to prove out of debt in “13 to 36 months” or “only paid 50%” without defining the group of clients that applied to? It certainly does not apply to all.

    Steve

  4. Robert Stevenson

    October 28, 2010 at 3:33 pm

    Steve,

    What are your thoughts on the way the FTC wants these stats? I mean, you really think that it is accurate to count people who enroll, never make a payment, and then drop? According to the new TSR rules, this appears to be how they want stats counted. I just feel this misrepresents the stats as there is no consideration paid yet.

    Second, the stats are difficult enough to calculate for debt relief.. but I’m not so sure someone who enrolls and drops before paying.

    Also, I almost believe there should be 2 separate stats. For example, there are a number of people who enroll in programs, get a few settlements, then drop to settle on their own.

    I think the main goal of the rules is to make sure consumers get the right information and that’s where I am a little twisted. As a consumer, I’d like what you are promoting.. Full transparency. Including, if people drop… why? Did they quit? Bk, etc… its actually too long of a thought for right now.. but I’m sure people have opinions.

  5. Robert Stevenson

    October 28, 2010 at 7:33 pm

    Steve,

    What are your thoughts on the way the FTC wants these stats? I mean, you really think that it is accurate to count people who enroll, never make a payment, and then drop? According to the new TSR rules, this appears to be how they want stats counted. I just feel this misrepresents the stats as there is no consideration paid yet.

    Second, the stats are difficult enough to calculate for debt relief.. but I’m not so sure someone who enrolls and drops before paying.

    Also, I almost believe there should be 2 separate stats. For example, there are a number of people who enroll in programs, get a few settlements, then drop to settle on their own.

    I think the main goal of the rules is to make sure consumers get the right information and that’s where I am a little twisted. As a consumer, I’d like what you are promoting.. Full transparency. Including, if people drop… why? Did they quit? Bk, etc… its actually too long of a thought for right now.. but I’m sure people have opinions.

    • Steve Rhode

      October 28, 2010 at 8:15 pm

      Just my opinion but I think the stats could be narrowed down if they were qualified on the front end. I get what you’re talking about but the impression the consumer gets is a lot different if they are told: “Of the 36% of consumers that actually settled debt, the average settlement was for 50% (using the FTC formula)”, than if consumers are given just the statement of “settle for 50%.”

      Or, “Of the 25% of clients that have settled all their debt, they did it by the 36th month.” That makes it clear to the consumer not all consumers are successful, and of those that are quantifiably successful, they did it by the 36th month.”

      Statements like that can be verified. Anyone not making a quantifiable statement that can be supported with actual data is simply playing with fire. How would anyone even begin to prove out of debt in “13 to 36 months” or “only paid 50%” without defining the group of clients that applied to? It certainly does not apply to all.

      Steve

      • Matt

        October 28, 2010 at 11:03 pm

        Thanks for your thoughtful reply, Steve. Our current ads make no claim involving percentages or time frame, for the exact reasons you outline. That’s why I was surprised to see your comments. However, it appears that some of our media partners are still airing some of the old ads on a very limited basis. We are working to fix that ASAP as our new ads make no such claims. I’m confused about your comments regarding the 50%, though. We purposely removed any percentages for the Hulk ads because we certainly didn’t want to bring any unwanted scrutiny to a campaign that was bound to get some attention. So there’s nothing like that in the ads above. A testimonial client states in the Terry ad that his debt was reduced by nearly 50% but we make no claims or promises. We left the 12-36 months because we strongly felt we had to list some points that created value and made us competitive with the plethora of ads still airing that make several similar claims. Note that “Requires full participation in program through completion.” always appears when we make mention of this or any claims regarding the benefits of debt settlement. It’s also crucial to point out that 100% of our calls are going to one company that is fully compliant and stopped taking any up-front fees a long time ago. They are attorney based – their President is a former federal prosecutor. So every call is going to a good company that we know is compliant and doing right by their clients. We felt this was the right thing to do in the current climate to ensure that a) we continue to be a part of the solution and b) we don’t have an FTC issue. I’m confident that anything we say can be proven by our partner but at the same time I’m fully aware that fighting the government is a fool’s errand. As Robert points out so well, the difficulty lies in the number of people who drop out of the program or get enough settled to go it alone and get back on their feet. In fact, our client informs us that 89% of the clients who engage them are able to avoid bankruptcy after starting the program. Many of them still leave before it’s completed but they’re in good enough shape by that time to clean things up themselves and don’t file bk. It’s a very competitive space and it’s difficult to make much headway when everyone else is making every possible claim. I think the big key, according to our FTC attorney, is that the calls are going to a company that isn’t ripping off consumers and is doing business the right way. Hope this helps address your comments. Thanks again for your time.

        Matt

        • Jason Taylor

          November 22, 2010 at 10:54 pm

          I’ll be surprised if the FTC doesn’t take enforcement after these types of ads. If indicating getting out of debt in 12-36 months, and that doesn’t happen for the TYPICAL client or the percentage of clients that this ACTUALLY occurs for is not clear and conspicuously disclosed my guess is there is big trouble ahead. Read the FTC guide for businesses, it doesn’t take a Harvard lawyer to figure out know what’s probably crossing the line.

          Whoever is running these ads better have independently verified data from the company buying the leads. I could see Terry landing himself in hot water too- he is probably just as liable, unfortunately, even if he is not up to speed with industry compliance. He likely has deeper pockets to go after than the marketer or the company buying these leads….well maybe not with his ex wife’s compensation. Seriously, for his sake hopefully he does hires someone like Loeb and Loeb to evaluate just what kind of position he is putting himself in. I wouldn’t rely on any opinion other than someone who is very familiar with the industry such one of the attorneys who were involved with the FTC in their rule making decisions.

  6. Steve Rhode

    October 28, 2010 at 2:10 pm

    Matt,

    I think you’ll find that commenters thought the ads generally complied. I had not weighed in till now.

    Thank you for reaching out.

    My opinion is the time and/or saving claims is going to potentially be an issue if leads from these ads are farmed to multiple companies and the claims “12-36 months”, “reduce debt by nearly 50%” can’t be supported with facts.

    So I’m curious how you deal with that issue. What’s the plan and how do you support the claims if you were asked by the FTC today?

    Here is what I’m thinking about specifically. The FTC gives the following guidance:

    If you provide debt relief services, it’s illegal to misrepresent any material aspect of your services, either explicitly or by implication. A material aspect of a debt relief service includes any information that is likely to affect someone’s decision to sign up for your program or to choose one program over another. Some examples of claims that would be material:

    * the amount of money or the percentage of the debt someone may save by using your service;
    the amount of time necessary to get the results you represent;

    * the amount of money or the percentage of each outstanding debt the customer must accumulate before you’ll begin your attempts to negotiate, settle or modify the terms with creditors;

    * the amount of money or the percentage of each outstanding debt the customer must accumulate before you’ll make a bona fide offer to negotiate, settle or modify the terms with creditors;

    * the effect of your service on the customer’s creditworthiness;

    * the effect of your service on the collection efforts of any creditors or debt collectors;

    * the percentage or number of customers who have gotten the results you represent; and
    whether your business is a bona fide nonprofit entity.

    May I base my advertising claims on the experiences of some previous customers?

    Yes, but your sample must be representative of the entire relevant population of your past customers. To accomplish this you must, among other things, use appropriate sampling techniques, proper statistical analysis, and safeguards for reducing bias and random error. You can’t cherry-pick the most successful examples to inflate your results.

    If you advertise or represent that your customers will save a certain amount of money or reduce their debt by a certain percentage – for example, “We can settle your debts for 40% to 60%” – your statements must be truthful, and you must have objective proof to back them up. Your claims must accurately reflect the results you’ve achieved for previous customers. It’s important to consider the message your claims convey. Under the law, the FTC looks at claims from the point of view of reasonable consumers. Therefore, what matters isn’t the literal accuracy of the words you use, but rather your proof to support the “net impression” your message conveys. For example, claiming that your past customers have achieved “up to 60% savings” is likely to convey to new customers that they, too, will get savings of around 60%. If you don’t have solid proof to back that up, the claim is deceptive.

    Here are several important requirements for making sure your savings claims are truthful and not deceptive:

    1. State the savings based on the customer’s debt when he or she signs up for the program. You may not inflate savings figures or percentages by including interest and fees the credit card company adds after a customer signs up for your program.

    Example 8: Andy signs up with a debt relief service offered by Company H, owing $10,000 on his credit card. One year later, following negotiations with the credit card company, Company H negotiates a settlement allowing Andy to pay $6,000 to resolve the debt. However, since Andy enrolled, the credit card company has charged him interest and late fees totaling $2,000, so that Andy now owes $12,000. By getting a settlement for $6,000, Company H has saved Andy $4,000 ($10,000 minus $6,000) or 40% of the debt at the time of enrollment. It would be deceptive for Company H to claim to have saved Andy $6,000 ($12,000 minus $6,000) or 50% of his debt.

    2. Include the impact of your fees on the claimed savings. You may not inflate your savings claims by excluding the fees your customers paid you.

    Example 9: Betty owes $10,000 on her credit card, and signs up with Company J’s debt relief service. Company J gets a settlement allowing Betty to pay $5,000 to resolve the debt. However, at the time of settlement, Company J charges Betty a $1,000 fee for its work. It would be deceptive for Company J to claim to have saved Betty $5,000 – or 50% of her debt – because Betty also had to pay $1,000 in fees. Instead, Company J may truthfully state Betty’s savings as $4,000 ($5,000 minus $1,000) or 40% of Betty’s debt.

    3. In calculating the results you’ve achieved over time, you must include customers who dropped out or otherwise failed to complete the program. Don’t base your savings claims only on customers who successfully completed your program.

    Example 10: Company K had 10 customers signed up for its service. Each one had $10,000 in unpaid credit card debt for a total of $100,000. Five of the customers completed the program, and each saved $5,000 – for a total savings of $25,000. The remaining five customers dropped out of the program, each one still owing the $10,000 they owed when they signed up with the program. Taken together, Company K has saved its customers $25,000 – or 25% – of the total $100,000 debt they had when they signed up with the program. It would be deceptive for Company K to exclude the drop-outs and claim that it saved its customers 50% of their debt.

    4. Include all debts enrolled by your customers, not only those that have been settled successfully. In calculating your savings claim, you may not exclude accounts you failed to settle, even if the failure was due to customers dropping out of your service.

    Example 11: Company L has 10 customers, and each of them enrolls two $1,000 debts in the program – totaling 20 debts or $20,000. Company L is able to settle 10 of the 20 debts, each for $500. However, it was unable to settle the remaining 10 debts before those customers either completed or dropped out of the program. Thus, Company L has saved its 10 customers $5,000 or 25% of their debts in the program. It would be deceptive for Company L to exclude the 10 accounts that weren’t settled and claim a savings rate of 50%. – Source

    So is the claim of 12 to 36 months an accurate representation of all people who have enrolled as the result of leads generated from these commercials? Do you have an idea of what percentage of people that signed up through the commercial actually settled all their debt in 12 to 36 months?

    Is the “nearly 50%” claim supported as described in the above examples 1,2,3, and 4?

    Steve

  7. Matt Goldreich

    October 28, 2010 at 1:33 pm

    I’m the owner of both National Media Connection and Debt Help Center USA. I understand you have been writing about us and specifically about our Hulk campaign. Very few of those ads should be airing, if any, and we went to great lengths to be compliant and yet make the ads compelling enough that people would call to get help. In this environment it certainly wasn’t easy and it’s been quite an undertaking.

    Unlike some other companies you may feature on your site, I feel that we are an ethical company that wants to be a part of the solution, not a part of the problem. If you’re truly interested in learning more about what we do I’m open to having a conversation with you or communicating via email. It looks like you are providing a well needed service for people struggling with debt so I commend you for this. I hope to hear back from you, Steve.

  8. Matt Goldreich

    October 28, 2010 at 5:33 pm

    I’m the owner of both National Media Connection and Debt Help Center USA. I understand you have been writing about us and specifically about our Hulk campaign. Very few of those ads should be airing, if any, and we went to great lengths to be compliant and yet make the ads compelling enough that people would call to get help. In this environment it certainly wasn’t easy and it’s been quite an undertaking.

    Unlike some other companies you may feature on your site, I feel that we are an ethical company that wants to be a part of the solution, not a part of the problem. If you’re truly interested in learning more about what we do I’m open to having a conversation with you or communicating via email. It looks like you are providing a well needed service for people struggling with debt so I commend you for this. I hope to hear back from you, Steve.

    • Steve Rhode

      October 28, 2010 at 6:10 pm

      Matt,

      I think you’ll find that commenters thought the ads generally complied. I had not weighed in till now.

      Thank you for reaching out.

      My opinion is the time and/or saving claims is going to potentially be an issue if leads from these ads are farmed to multiple companies and the claims “12-36 months”, “reduce debt by nearly 50%” can’t be supported with facts.

      So I’m curious how you deal with that issue. What’s the plan and how do you support the claims if you were asked by the FTC today?

      Here is what I’m thinking about specifically. The FTC gives the following guidance:

      If you provide debt relief services, it’s illegal to misrepresent any material aspect of your services, either explicitly or by implication. A material aspect of a debt relief service includes any information that is likely to affect someone’s decision to sign up for your program or to choose one program over another. Some examples of claims that would be material:

      * the amount of money or the percentage of the debt someone may save by using your service;
      the amount of time necessary to get the results you represent;

      * the amount of money or the percentage of each outstanding debt the customer must accumulate before you’ll begin your attempts to negotiate, settle or modify the terms with creditors;

      * the amount of money or the percentage of each outstanding debt the customer must accumulate before you’ll make a bona fide offer to negotiate, settle or modify the terms with creditors;

      * the effect of your service on the customer’s creditworthiness;

      * the effect of your service on the collection efforts of any creditors or debt collectors;

      * the percentage or number of customers who have gotten the results you represent; and
      whether your business is a bona fide nonprofit entity.

      May I base my advertising claims on the experiences of some previous customers?

      Yes, but your sample must be representative of the entire relevant population of your past customers. To accomplish this you must, among other things, use appropriate sampling techniques, proper statistical analysis, and safeguards for reducing bias and random error. You can’t cherry-pick the most successful examples to inflate your results.

      If you advertise or represent that your customers will save a certain amount of money or reduce their debt by a certain percentage – for example, “We can settle your debts for 40% to 60%” – your statements must be truthful, and you must have objective proof to back them up. Your claims must accurately reflect the results you’ve achieved for previous customers. It’s important to consider the message your claims convey. Under the law, the FTC looks at claims from the point of view of reasonable consumers. Therefore, what matters isn’t the literal accuracy of the words you use, but rather your proof to support the “net impression” your message conveys. For example, claiming that your past customers have achieved “up to 60% savings” is likely to convey to new customers that they, too, will get savings of around 60%. If you don’t have solid proof to back that up, the claim is deceptive.

      Here are several important requirements for making sure your savings claims are truthful and not deceptive:

      1. State the savings based on the customer’s debt when he or she signs up for the program. You may not inflate savings figures or percentages by including interest and fees the credit card company adds after a customer signs up for your program.

      Example 8: Andy signs up with a debt relief service offered by Company H, owing $10,000 on his credit card. One year later, following negotiations with the credit card company, Company H negotiates a settlement allowing Andy to pay $6,000 to resolve the debt. However, since Andy enrolled, the credit card company has charged him interest and late fees totaling $2,000, so that Andy now owes $12,000. By getting a settlement for $6,000, Company H has saved Andy $4,000 ($10,000 minus $6,000) or 40% of the debt at the time of enrollment. It would be deceptive for Company H to claim to have saved Andy $6,000 ($12,000 minus $6,000) or 50% of his debt.

      2. Include the impact of your fees on the claimed savings. You may not inflate your savings claims by excluding the fees your customers paid you.

      Example 9: Betty owes $10,000 on her credit card, and signs up with Company J’s debt relief service. Company J gets a settlement allowing Betty to pay $5,000 to resolve the debt. However, at the time of settlement, Company J charges Betty a $1,000 fee for its work. It would be deceptive for Company J to claim to have saved Betty $5,000 – or 50% of her debt – because Betty also had to pay $1,000 in fees. Instead, Company J may truthfully state Betty’s savings as $4,000 ($5,000 minus $1,000) or 40% of Betty’s debt.

      3. In calculating the results you’ve achieved over time, you must include customers who dropped out or otherwise failed to complete the program. Don’t base your savings claims only on customers who successfully completed your program.

      Example 10: Company K had 10 customers signed up for its service. Each one had $10,000 in unpaid credit card debt for a total of $100,000. Five of the customers completed the program, and each saved $5,000 – for a total savings of $25,000. The remaining five customers dropped out of the program, each one still owing the $10,000 they owed when they signed up with the program. Taken together, Company K has saved its customers $25,000 – or 25% – of the total $100,000 debt they had when they signed up with the program. It would be deceptive for Company K to exclude the drop-outs and claim that it saved its customers 50% of their debt.

      4. Include all debts enrolled by your customers, not only those that have been settled successfully. In calculating your savings claim, you may not exclude accounts you failed to settle, even if the failure was due to customers dropping out of your service.

      Example 11: Company L has 10 customers, and each of them enrolls two $1,000 debts in the program – totaling 20 debts or $20,000. Company L is able to settle 10 of the 20 debts, each for $500. However, it was unable to settle the remaining 10 debts before those customers either completed or dropped out of the program. Thus, Company L has saved its 10 customers $5,000 or 25% of their debts in the program. It would be deceptive for Company L to exclude the 10 accounts that weren’t settled and claim a savings rate of 50%. – Source

      So is the claim of 12 to 36 months an accurate representation of all people who have enrolled as the result of leads generated from these commercials? Do you have an idea of what percentage of people that signed up through the commercial actually settled all their debt in 12 to 36 months?

      Is the “nearly 50%” claim supported as described in the above examples 1,2,3, and 4?

      Steve

  9. Andy Faria

    October 27, 2010 at 10:41 pm

    I like the first ad, it’s clever. “Don’t sweat the debt!”… come on that’s genious.

    The second ad is stupid. Who wants to see Hulk Hogan, calling himself “Terry”, in head-to-toe baby blue, with soft background music playing? Not me.

    If they can back up their claims I don’t see why this is so bad. They do slap on some extra cheese with statements like, “far less than you owe” and “not 12-36 years”, but it’s obviously attempting to comply.

    Like Michael says, the true test in compliance begins when the consumer calls in for more information. Let’s just hope they don’t have the Hulkster anwering phones too.

  10. Andy Faria

    October 28, 2010 at 2:41 am

    I like the first ad, it’s clever. “Don’t sweat the debt!”… come on that’s genious.

    The second ad is stupid. Who wants to see Hulk Hogan, calling himself “Terry”, in head-to-toe baby blue, with soft background music playing? Not me.

    If they can back up their claims I don’t see why this is so bad. They do slap on some extra cheese with statements like, “far less than you owe” and “not 12-36 years”, but it’s obviously attempting to comply.

    Like Michael says, the true test in compliance begins when the consumer calls in for more information. Let’s just hope they don’t have the Hulkster anwering phones too.

  11. ComplianceSlave

    October 27, 2010 at 5:25 pm

    Well… At least the 1st one wasnt targeting the elderly…. Were small & do buy leads. We have to get them from somewhere. Pretty compliant- 1st one for sure… Really reaching out to the educated…. Ugh.

  12. ComplianceSlave

    October 27, 2010 at 9:25 pm

    Well… At least the 1st one wasnt targeting the elderly…. Were small & do buy leads. We have to get them from somewhere. Pretty compliant- 1st one for sure… Really reaching out to the educated…. Ugh.

  13. Michael

    October 27, 2010 at 4:36 pm

    I did not see too much issue with the first posted commercial other than a mustache hair out of place.

    The second commercial made some claims of savings and time to completion that, if called to task on compliance with a strict formula that must be followed in order to make claims, could potentially be problematic.

    My question is whether Debt Help Center is just a lead provider, or is an actual service provider?

    If they are a lead provider, how have they established the end user, the lead buyer/service provider, does help people save thousands and does indeed get their customers out of debt in 12 to 36 months? Are they sure that the end user based their data to support the claims in the commercial across their entire database.

    For the most part, I thought commercials were ambiguous enough.

    The production quality was good.

    The compliance concerns only start with these commercials. When consumers call in to get more information is when the compliance rubber meets the regulatory road.

  14. Michael

    October 27, 2010 at 8:36 pm

    I did not see too much issue with the first posted commercial other than a mustache hair out of place.

    The second commercial made some claims of savings and time to completion that, if called to task on compliance with a strict formula that must be followed in order to make claims, could potentially be problematic.

    My question is whether Debt Help Center is just a lead provider, or is an actual service provider?

    If they are a lead provider, how have they established the end user, the lead buyer/service provider, does help people save thousands and does indeed get their customers out of debt in 12 to 36 months? Are they sure that the end user based their data to support the claims in the commercial across their entire database.

    For the most part, I thought commercials were ambiguous enough.

    The production quality was good.

    The compliance concerns only start with these commercials. When consumers call in to get more information is when the compliance rubber meets the regulatory road.

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