The suits filed recently by the FTC against Financial Freedom of America, Debt Professionals of America, and Debt Consultants of America surround a common thread and common practices of many debt relief providers. A wide swatch of debt settlement companies have been guilty of similar marketing practices that the FTC is strongly saying are deceptive, unsupported and unfair to consumers.
The heart of the matter are marketing claims made surrounding performance, expectations, and results. Let’s look at the complaint against Debt Consultants of America, Debt Professionals of America, Robert Creel, Corey Butcher, and Nikki Creel aka Nikki Vrla as an example. Although the same issues apply in the complaint against Financial Freedom of America, Financial Freedom Processing, Corey Butcher, and Brent Butcher in their separate complaint. – Source
The FTC Complaint Allegations
Since at least 2006, and continuing thereafter, Defendants DCA, Robert Creel, Corey Butcher, and Nikki Creel have offered debt relief services to consumers having difficulty with their personal finances. In 2008, Defendants Robert Creel, Corey Butcher, and Nikki Creel started Defendant DP A. Since at least 2008, Defendant DP A has offered debt relief services to consumers having difficulty with their personal finances. Defendants target consumers with substantial amounts of unsecured debt, often claiming that participation in their debt relief services will result in the elimination of 40 to 60 percent of consumers’ debts and that participating consumers will be debt free in 18 to 36 months.
Defendant DCA markets its debt relief services on the Web sites www.4dcoa.com, www.debtconsultantsofamerica.com, and www.info@4dcoa.com, and through national radio and television advertisements.
Defendant DPA markets its debt relief services on the Web sites www.4dpoa.com, www.debtprofessionalsofamerica.com, and www.info@4dpoa.com, and through national radio advertisements.
In both radio and television advertisements, Defendants make or have made claims such as, “You could save thousands of dollars in interest” and “Stop late fees, hidden charges and outrageous interest rates.” Defendants also frequently promise to help consumers “eliminate 30 to 60% of [their] credit card debt” and “avoid bankruptcy, save thousands and get more cash back in [their] pocket every month.” Defendants’ radio and television advertisements urge interested consumers to call a toll-free number for a free consultation and to enroll in their debt relief services.
Defendants’ Web sites represent or have represented that consumers can “Reduce credit card debt 40%-60%” and “Get out of debt in 18-36 months.” Defendants’ Web sites further have represented that “Our programs will lower your monthly payments up to 50% and save you literally thousands of dollars.” On their Web sites, Defendants claim to have “established relationships” with creditors that enable Defendants to obtain the best possible settlements for their clients. Defendants’ Web sites encourage consumers to call a toll-free number to learn more about Defendants’ debt relief services. Although Defendants have recently updated their Web sites, the updates do not substantially change the representations described above.
Consumers who call one of Defendants’ toll-free numbers are connected to a sales representative. Defendants require their sales representatives to follow, and the sales representatives do follow, a script when speaking with consumers. Following the script, Defendants’ sales representatives promise to reduce consumers’ debt by negotiating on their behalf with consumers’ creditors. Defendants’ sales representatives often tell consumers that Defendants’ debt relief services will enable consumers to payoff all of their unsecured debt in 18 to 36 months. Defendants’ scripts instruct sales representatives to tell consumers that Defendants’ negotiations “average around .50 Cents [sic] on the dollar” and will result in a 40 to 60 percent savings of the debt owed.
Defendants’ sales representatives typically tell consumers that creditors will not settle their accounts unless the consumers stop making payments to and cease communications with their creditors. Defendants further represent to consumers that allowing their accounts to become delinquent will motivate creditors to settle with them for a substantially reduced amount. In numerous instances, Defendants tell consumers to rely on Defendants to communicate and negotiate with their creditors.
Defendants send consumers who agree to enroll in the debt relief services an initial set of enrollment documents. Included in these documents are: (a) a Client Enrollment Agreement (the “Agreement”), (b) a form for consumers to open a special purpose account with a bank selected by Defendants, (c) a form authorizing automatic transfers from consumers’ personal bank accounts into that special purpose account, and (d) a form to identify the amounts owed by consumers to various creditors.
During the telephone sales call, Defendants’ sales representatives encourage consumers to fill out the enrollment documents and return the papers as quickly as possible. Defendants instruct their sales representatives to discourage consumers from carefully reading the Agreement by stating that “[these] two pages cover everything I have gone over with you about this program.”
The Agreement is a single-spaced document in approximately eight-point font. The Agreement contains provisions that are often contrary to the representations made in the sales call or are not addressed in the sales call. For example, the Agreement contains the following statement in an attempt to disclaim the savings claims made to consumers in the advertisements and sales calls: “DCA’s [or DPA’s] expressions about the outcome of any matter are its best professional estimates only, and are limited by present policies, cash advances, balance transfer and Client’s financial resources at the time negotiations are obtained with Client’s Creditors (estimated savings do not include fees).” The Agreement also provides additional infonnation about Defendants’ fees.
As indicated above, consumers open a special purpose bank account into which funds are automatically transferred from the consumer’s personal bank account. The special purpose account, which is maintained at a separate financial institution, is purportedly maintained to accumulate funds for the purpose of repaying consumers’ enrolled debts. However, the fonns completed by the consumer authorize the Defendants to withdraw their fees automatically from this account.
Defendants charge their clients fees, including administrative fees, monthly maintenance fees, negotiation fees, and, in some instances, a cancellation fee. Defendants’ fees are withdrawn automatically from the consumers’ special purpose account each month. From the inception of the business through at least late spring 2009, all fees were non-refundable unless consumers cancelled their enrollment in the debt relief services before the end of the three-day Right of Refusal period provided for in the Agreement. Defendants have collected a $299 cancellation fee from numerous consumers who submitted a cancellation request after the Right of Refusal period.
Defendants charge consumers an up-front administrative fee that is calculated as 10 percent of the amount of debt that consumers owe their unsecured creditors at the time of their enrollment in Defendants’ debt relief services. The administrative fee varies by consumer based on the amount of debt enrolled, but typically ranges from $1000 to $4000.
Defendants also charge a monthly maintenance fee of $29.95 or $39.95 for each month consumers are enrolled in Defendants’ debt relief services.
Defendants also charge a negotiation fee for each account settled. The negotiation fee is calculated as 10 percent of the purported savings the company obtains in a settlement. Many consumers never pay a negotiation fee because Defendants do not settle their debts. Other consumers are surprised to discover that Defendants collect the negotiation fee even when consumers settle their own debts.
After consumers enroll in Defendants’ debt relief services, they receive a packet of documents from Defendants, which Defendants call a “Welcome Kit.” The Welcome Kit provides additional infonnation about how Defendants’ debt relief services work and is delivered to consumers after the Right of Refusal period has ended. In numerous instances, consumers receive their Welcome Kit after their first month’s payment.
The Welcome Kit states that Defendants will not contact creditors until the consumers’ accounts are 120 to 180 days delinquent and the consumers have saved enough money in their special purpose accounts to make a settlement offer of approximately 50 percent of the lowest debt balance enrolled. In addition, the Welcome Kit states that if consumers accept a settlement offer from their creditors while enrolled in the services, Defendants are entitled to collect the negotiation fee, even if the consumers conducted all of the negotiations with the creditor. In numerous instances, Defendants do not disclose this infonnation to consumers prior to their enrollment.
In numerous instances, Defendants do not contact or commence settlement negotiations with consumers’ creditors immediately upon the consumers’ enrollment in their debt relief services. Defendants typically do not contact or initiate negotiations with any creditor until after: (a) consumers have paid the administrative fee in full, and (b) consumers have accumulated enough funds in their special purpose account to settle the debt with that creditor. Often, the first time Defendants mention this fact to consumers is in the Welcome Kit.
For numerous consumers, it takes a minimum of four to six months after enrollment to pay Defendants’ administrative fee in full and begin accumulating funds in their special purpose account for the first settlement offer. Throughout this time, Defendants typically do not contact the consumers’ creditors and continue to advise consumers to cease making payments to and communicating with their creditors.
Contrary to Defendants’ representations that consumers will pay off their debts in 18 to 36 months at 40 to 60 percent savings, Defendants rarely negotiate settlements for all accounts entered into the debt relief services by consumers. Moreover, even when Defendants succeed in negotiating a settlement on one or more of the consumers’ several accounts, in numerous instances, consumers’ account balances increase from the time of enrollment to the time of settlement due to creditors’ additional late fees, finance charges, and other charges. Therefore, the total aggregate amount consumers are required to pay is, in numerous instances, higher than 60 percent of the total amount the consumers owed to their creditors at the time of enrollment. In numerous instances, consumers have not obtained the 40 to 60 percent savings on their debt and do not have their debts paid off in 18 to 36 months as promised by Defendants.
Few consumers who enroll in Defendants’ debt relief services ever complete the services and receive the promised results. In numerous instances, consumers cancel or drop out of Defendants’ debt relief services before any debt is negotiated because they cannot afford to pay Defendants’ substantial fees and also accumulate money to payoff their debts. Other consumers cancel or drop out because of harassment and escalating collection attempts by their creditors. Consumers who cancel or drop out before any debts are settled forfeit most or all fees paid to Defendants.
Consumers who purchase Defendants’ debt relief services frequently seek a refund from Defendants. Defendants routinely deny consumers’ refund requests. – Source
The Heart of the FTC Issues are NOT Related to the New Telemarketing Sales Rules
At the center of the Federal Trade Commission concerns with these and other debt relief companies are the issues of deception surrounding advertising and other claims made that are unsubstantiated. Even though these complaints are against debt relief companies, the issues raised are about the basic deception these debt relief companies engaged in while allegedly having no data or support to substantiate the claims they made.
It is alleged the typical consumer did not realize a savings as promoted nor reduced their debt in the time period specified. The kicker here, and the point all debt relief companies needs to focus on, is not if someone was able to reduce their debt by 40 to 60 percent within 18 to 36 months but if the typical and average client was able to do that. If they were not then the claims made are misrepresentations of the average results and therefore deceptive.
These deceptive acts and practices are covered by Section 5(a) of the FTC Act, 15 U.S.C. § 45(a) and don’t need the new telemarketing sales rules (TSR) to wield a heavy hammer.
Financial Freedom of America Had a Different Point of View
It’s interesting to go back and now read the review I wrote about the companies in February, 2010.
In the comments section on that post Financial Freedom of America Said:
To date, FFoA has over 5,000 graduated and active clients, and has settled over $73 million in unsecured debt on behalf of our clients.
To set a standard of excellence for our work, we are an accredited member of the United States Organization for Bankruptcy Alternatives (USOBA), whose mission is to advocate for fair regulation and protection of consumers.
Our President and CEO, Corey Butcher, is a leader in this industry. He serves on the board of USOBA and consults with the organization to develop state-specific agendas.
Furthermore, Financial Freedom of America is certified by BSI Management Systems America, verifying we operate a quality management system that complies with the requirements of USOBA’s best practice standard. Additionally, all of our Negotiators, Managers and Directors are certified through the International Association of Professional Debt Arbitrators.
Based on those comments and the fact Butcher was a “leader in this industry”, “Served on the board of USOBA”, was “certified by BSI Management Systems America”, and had a certified staff through the “International Association of Professional Debt Arbitrators”, you can only wonder how in the world they operated making claims that were deceptive and unsupported.
In the video above you will hear Robert Creel him say they settle debt “for about half of what it is.”
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How are you a victim? I hear this way too often without anything substantial. Many times, “they haven’t even contacted my creditors yet!”.. THEY DO IT ON A CASE BY CASE BASIS. Anyone who knows anything about settling will tell you some creditors WILL SUE YOU if you tell them for in advance that you want to settle. Some creditors only need be informed of settling right before settlement is ready….
What have they done or not done?
I am also a victim of FFA. I was trying to get out of debt while going through a divorce. I called after hearing the ad on AM radio. I was convinced they could help. All paper-work was done and faxed back. Then my bank, Bank of America, denied them authority to withdraw funds. I decided not to fax another another copy of the authorization back to FFA. No matter, they already had all my banking information anyways. Eventually they were withdrawning money costing me overdraft charges and depleting my bank account. I want to sue! Not only for my money but all the other innocent victims of this scam. Let’s get our money back. Chris Barnas
I am also a victim of FFA. I was trying to get out of debt while going through a divorce. I called after hearing the ad on AM radio. I was convinced they could help. All paper-work was done and faxed back. Then my bank, Bank of America, denied them authority to withdraw funds. I decided not to fax another another copy of the authorization back to FFA. No matter, they already had all my banking information anyways. Eventually they were withdrawning money costing me overdraft charges and depleting my bank account. I want to sue! Not only for my money but all the other innocent victims of this scam. Let’s get our money back. Chris Barnas
How are you a victim? I hear this way too often without anything substantial. Many times, “they haven’t even contacted my creditors yet!”.. THEY DO IT ON A CASE BY CASE BASIS. Anyone who knows anything about settling will tell you some creditors WILL SUE YOU if you tell them for in advance that you want to settle. Some creditors only need be informed of settling right before settlement is ready….
What have they done or not done?
Corey,
Thank you for your comment and establishing an open channel of communications.
I was taken aback by your statement that I “routinely blog” about your companies. I wrote a review in February, 2010, a couple of posts about the FTC charges yesterday, a post about how Financial Freedom was named in Senate Testimony in August, 2010, a mention of you from a New York Times article, and a post about your issues with Vermont. I would hardly categorize that as routinely.
The bottom line is that I’ve never sought you out to write about you. I was either asked about your companies by a reader or you appeared in testimony or actions by regulators. I’d be interested to know what specific statements you feel, fall into your position that I have blogged about you and your companies with “many unsupported facts.” What facts are unsupported? I’d be more than happy to discuss them but this is the first time this has been brought to my attention.
I applaud your willingness to answer questions publicly. So let’s begin.
Is it your position that the average of all of your clients was that they settled their debt, in full, for between 30%-60% and accomplished that goal within 18-36 months?
What is the independently substantiated average percentage of savings of settlements among all the clients, factoring in all fees, and terminations?
What is the independently substantiated average time for settling debt for all clients that settled all of their debt?
Did you provide 100% refunds to consumers that requested them?
Did you ever charge any consumer a $299 cancellation fee?
Which of the following claims did you not make?
1. “stop never ending late fees and outrageous interest rates,”
2. “Be debt free in as little as thirty to thirty six months.”
3. “wipe out 30 to 60% of[their] credit card debt”
4. “avoid bankruptcy, save thousands and get more cash back in [their] pocket every month.”
5. “secret programs most credit card companies won’t tell you about”
While I acknowledge your invitation to travel to see your offices I am left wondering, for what end. I acknowledge in advance you probably have a nice office, with nice people, sitting at nice desks, and working on nice equipment.
The issues involved here have nothing to do with the staff or individual clients. They are about the aggregate and the expectation that an average client should expect the results that were presented in marketing messages.
You say, “I challenge you to research all sides before you draw your conclusions,” and I accept that challenge. All I need is your audited data of all clients in order to reach a conclusion. The FTC assertion is that the claims you made were not true among all clients, show me data that shows me they were wrong and I’ll print that.
As far as expecting a retraction I’m curious what you want me to retract? I’m not aware of anything that I have reported that is not supported by the facts, even if those facts are that the FTC sued you and your company.
Steve
Mr. Rhode,
First of all let me start out by saying, just because a law suit has been filed does not establish guilt. You have routinely blogged about our companies, myself and other parties vigorously with many unsupported facts. We have always been very transparent and more than willing to answer any questions or concerns for media outlets, regulators and bloggers. We strongly believe that the claims alleged by the FTC will be proven as a misunderstanding of our data. I am not sure how you can make assumptions that we do not provide service to our clients or substantiate our claims. Since 2006 we have graduated more the 2400 clients, settled more than 150 million dollars for an average savings of 50% from the original debt enrolled. I have always focused, not on the clients who complete their programs, but on those who struggle to complete or discontinue their programs. The issue I have with many of the non-completions stem from the negative media that surrounds this industry. For example, the BBB’s rating system and TOB process, creditors, collection agencies and law firms that routinely violate the fair debt collection practices act (which is the most complained about service to the BBB, state and federal regulators), and most importantly bloggers like yourself. I often question who is the real problem in this industry, is it rogue settlement companies (which they definitely play a role), is it the BBB, is it regulators that routinely make public statements that are far from accurate or is it some blogger that remarks on their experience from their own clouded vision. I believe it is the combination of all. Mr. Rhode I wish you would come to our office just one day and witness the work that is being accomplished for so many struggling families, hear the stories we hear of the harassment these clients have to endure, the tears of excitement when one completes (which currently we average 6 completions a day), and the words promising to never over-extend themselves financially again. FFoA, DPA, DCA and its entire staff has continued to hold their heads high; believing that one day the real story will be told. Mr. Rhode, I know you believe in your heart of hearts that you are doing everything to protect and educate consumers but I challenge you to research all sides before you draw your conclusions. In the past six months (including yesterday), I have had several interviews with media professionals. In every instance, after visiting with me and allowing me to show them the successes of our clients, they have all remarked that they had a completely different impression of our companies. Yesterday, I had a media professional ask me “why were we being targeted?†I simply responded that those who aren’t afraid to stand tall aren’t afraid to be persecuted. Lastly, I have always said that if it is found that we have taken advantage of anyone or done anything unlawfully, then we should be held fully responsible. Mr. Rhode, you have my word that at the conclusion of this case I will personally update you and if we are vindicated, I expect some type of retraction.
Very Respectfully,
Corey Butcher
Mr. Rhode,
First of all let me start out by saying, just because a law suit has been filed does not establish guilt. You have routinely blogged about our companies, myself and other parties vigorously with many unsupported facts. We have always been very transparent and more than willing to answer any questions or concerns for media outlets, regulators and bloggers. We strongly believe that the claims alleged by the FTC will be proven as a misunderstanding of our data. I am not sure how you can make assumptions that we do not provide service to our clients or substantiate our claims. Since 2006 we have graduated more the 2400 clients, settled more than 150 million dollars for an average savings of 50% from the original debt enrolled. I have always focused, not on the clients who complete their programs, but on those who struggle to complete or discontinue their programs. The issue I have with many of the non-completions stem from the negative media that surrounds this industry. For example, the BBB’s rating system and TOB process, creditors, collection agencies and law firms that routinely violate the fair debt collection practices act (which is the most complained about service to the BBB, state and federal regulators), and most importantly bloggers like yourself. I often question who is the real problem in this industry, is it rogue settlement companies (which they definitely play a role), is it the BBB, is it regulators that routinely make public statements that are far from accurate or is it some blogger that remarks on their experience from their own clouded vision. I believe it is the combination of all. Mr. Rhode I wish you would come to our office just one day and witness the work that is being accomplished for so many struggling families, hear the stories we hear of the harassment these clients have to endure, the tears of excitement when one completes (which currently we average 6 completions a day), and the words promising to never over-extend themselves financially again. FFoA, DPA, DCA and its entire staff has continued to hold their heads high; believing that one day the real story will be told. Mr. Rhode, I know you believe in your heart of hearts that you are doing everything to protect and educate consumers but I challenge you to research all sides before you draw your conclusions. In the past six months (including yesterday), I have had several interviews with media professionals. In every instance, after visiting with me and allowing me to show them the successes of our clients, they have all remarked that they had a completely different impression of our companies. Yesterday, I had a media professional ask me “why were we being targeted?” I simply responded that those who aren’t afraid to stand tall aren’t afraid to be persecuted. Lastly, I have always said that if it is found that we have taken advantage of anyone or done anything unlawfully, then we should be held fully responsible. Mr. Rhode, you have my word that at the conclusion of this case I will personally update you and if we are vindicated, I expect some type of retraction.
Very Respectfully,
Corey Butcher
Corey,
Thank you for your comment and establishing an open channel of communications.
I was taken aback by your statement that I “routinely blog” about your companies. I wrote a review in February, 2010, a couple of posts about the FTC charges yesterday, a post about how Financial Freedom was named in Senate Testimony in August, 2010, a mention of you from a New York Times article, and a post about your issues with Vermont. I would hardly categorize that as routinely.
The bottom line is that I’ve never sought you out to write about you. I was either asked about your companies by a reader or you appeared in testimony or actions by regulators. I’d be interested to know what specific statements you feel, fall into your position that I have blogged about you and your companies with “many unsupported facts.” What facts are unsupported? I’d be more than happy to discuss them but this is the first time this has been brought to my attention.
I applaud your willingness to answer questions publicly. So let’s begin.
Is it your position that the average of all of your clients was that they settled their debt, in full, for between 30%-60% and accomplished that goal within 18-36 months?
What is the independently substantiated average percentage of savings of settlements among all the clients, factoring in all fees, and terminations?
What is the independently substantiated average time for settling debt for all clients that settled all of their debt?
Did you provide 100% refunds to consumers that requested them?
Did you ever charge any consumer a $299 cancellation fee?
Which of the following claims did you not make?
1. “stop never ending late fees and outrageous interest rates,”
2. “Be debt free in as little as thirty to thirty six months.”
3. “wipe out 30 to 60% of[their] credit card debt”
4. “avoid bankruptcy, save thousands and get more cash back in [their] pocket every month.”
5. “secret programs most credit card companies won’t tell you about”
While I acknowledge your invitation to travel to see your offices I am left wondering, for what end. I acknowledge in advance you probably have a nice office, with nice people, sitting at nice desks, and working on nice equipment.
The issues involved here have nothing to do with the staff or individual clients. They are about the aggregate and the expectation that an average client should expect the results that were presented in marketing messages.
You say, “I challenge you to research all sides before you draw your conclusions,” and I accept that challenge. All I need is your audited data of all clients in order to reach a conclusion. The FTC assertion is that the claims you made were not true among all clients, show me data that shows me they were wrong and I’ll print that.
As far as expecting a retraction I’m curious what you want me to retract? I’m not aware of anything that I have reported that is not supported by the facts, even if those facts are that the FTC sued you and your company.
Steve
Mr. Rhodes,
As promised, I wanted to share with you the long-awaited outcome of our case with the FTC. As you will see the courts found in our favor by dismissing the case with prejudice. This was a long and stressful process that resulted in hundreds of people losing their jobs and 3 companies being all but run out of business. It is a shame that an enforcement agency can have the ability to do
this with little or no accountability. Throughout this process, we tried desperately to educate the FTC on the process of settlement but they had already made up their minds and comprised their own opinion. After 7 days of our convincing testimony, consumer survey experts, disgruntled clients (who had nothing to do with the alleged violations) and favorable industry comparisons, the FTC still proceeded to claim that we were nothing but bad actors feasting on the financially distressed. The judge clearly disagreed and stated through the FTC’s own admission that this case was not about the defendants but about the FTC’s biased opinions about the industry. It is amazing that the FTC could actually regulate an entire industry basically out of business with no factual basis.
Not only was the FTC wrong in its allegations but what came out through this case is debt settlement is the best option for consumers who struggle with thier debt and can not afford credit counceling or qualify for chapter 7. I hope this proves that the connection you attempted to make between myself, Mr. Creel, my brother and others, as no more than a group of individuals trying to explote others hardship is retracted. I also hope that this gives you pause before you publically pass judgement on companies or individuals. You must know by now that thier is always two sides to every story.
Respectfully,
Corey Butcher
How long ago did this happen?
The decision was release yesterday.
The record does reflect:
This case was called to trial before the Court. All parties appeared through counsel and announced ready. The case proceeded to trial. By separate instrument of this same date, the Court has made the findings of fact and conclusions of law pursuant to Rule 52(a) of the Federal Rules of Civil Procedure. The Court now renders judgment based on those findings and conclusions.
1. Plaintiff Federal Trade Commission (“FTC”) complains that Defendants Financial Freedom Processing, Inc., d/b/a Financial Freedom of America, Corey Butcher, Brent Butcher, Debt Consultants of America, Inc., Debt Professionals of America, Inc., Robert Creel, and Nikki Vrla (formerly Nikki Creel) violated Section 5(a) of the Federal Trade Commission Act (the “FTC Act”), 15 U.S.C. § 45(a).
2. The FTC originally brought two separate cases: Federal Trade Commission v. Financial Freedom Processing, Inc., et al., Civil Action No. 3:10-CV-2446-N, and Federal Trade Commission v. Debt Consultants of America, Inc., et al., Civil Action No. 3:10-CV-2447-N. By Order dated April 1, 2011, the Court consolidated both actions under the 2446 cause number.
3. The FTC failed to establish by a preponderance of the evidence that any Defendant violated Section 5(a) of the FTC Act.
4. It is ordered that the FTC take nothing by its claims against Defendants and that those claims are dismissed with prejudice.
5. Other than attorneys’ fees, all relief not expressly granted is denied. Court costs are taxed against the FTC. This is a final judgment.
I’ve just published an update to the case at https://getoutofdebt.org/35821/
The Judge’s opinion did not include some of the claims you make about FTC bias and debt settlement performance. Do you happen to have a court document that states otherwise?
Steve,
I am not sure the transcripts are public record but you can read the transcipts, specifically the closing statements to find the judges comments.
Please forward them if you have them.
But I’ve heard back from the FTC. See FTC to Appeal Debt Settlement Case Loss in Texas at https://getoutofdebt.org/35825/ftc-to-appeal-debt-settlement-case-loss-in-texas
FTC has just updated their statement regarding this case for my story. They are now saying, “We’re disappointed in the Judge’s ruling, and continue to believe that the defendants’ conduct is deceptive. We are considering all our options.”