Table of Contents
I just published a story about Legal Helpers Debt Resolution being hit with a class action suit in Washington.
And then in my inbox lands an email with the Legal Helpers Debt Resolution marketing pitch. I’ve covered something like this before and I’d pass writing about it again but in light of the new class action suit I decided to take a look at the participants in the agreement to see if I can make sense of the who the players are.
The email that went out was the one below and it contained a number of attachments and a link to LegalHelpers-DR.com.
The attachments are shown below and you can click on any image for a larger view.
Let’s See if We Can Figure This All Out
- Legal Helpers Debt Resolution says it is the is the law firm of Macey, Aleman, Hyslip & Searns.
- An apparent employee of the law firm LHDR, Jordan Abele sends out an email to attract marketers.
- The marketing agreement is actually not with the law firm. It is with a company called Legal Services Support Group, LLC. – Source
- Legal Service Support Group, LLC is a Nevada corporation that is owned by three companies: Lynch Financial Solutions, JEM Group, and Century Mitigations. – Source
- Lynch Financial Solutions is a Florida corporation owned by Thomas Lynch, Jr and the officers are Maryana Gomez and Dale Weikel. – Source
- JEM Group is owned by Joanne Garneau and Arthur Garneau. JEM Group was just named in the class action suit against Legal Helpers Debt Resolution.
- The Garneau’s also own Nationwide Support Services, Inc. – Source
- Century Mitigations, LP is owned by Consumer Finance Alternatives, Inc. – Source
- The attached spreadsheets refer to TFG receiving money as part of the added on up-sell financial coaching program. I believe TFG refers to Financial Strength Builders, see this article, which is really owned by Joanne Garneau and Arthur Garneau. – Source
The Association of Settlement Companies (TASC)
At the time this marketing email was sent out Joanne Garneau was listed as being on the executive board of TASC. – Source
Dave Leuthold was the former executive director of TASC.
In August of 2010 TASC came out with a public statement they supported the up-front fee ban and embraced the performance model. – Source
Do You Have a Question You'd Like Help With? Contact Debt Coach Damon Day. Click here to reach Damon.
The Legal Helpers model is not the performance model and charges advanced fees as evidenced by their spreadsheets shown above.
So it appears that at the same time TASC was saying they were not in favor of advanced fee debt settlement, executive member(s) of TASC were actually engaged in working with Legal Helpers Debt Resolution to market and support advanced fee services.
Nationwide Support Services and Century Negotiations are still listed as accrediated TASC members. – Source
Before My Brain Explodes
Unless I’m reading the marketing documents and attachments wrong it certainly appears that LHDR, a law firm, is directing affiliates and marketers to work with an enterprise that is not a law firm and benefits Joanne Garneau and Arthur Garneau since their involved enterprises of LSSG and TFG seem to make a good chunk of the money paid by the consumer in advanced fees. as shown in:
Layers and layers.
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.
- We Rise From the Dead Yet Again – Podcast - October 2, 2023
- Lexington Law Credit Repair Gets Hammered in Lawsuit Settlement. If You Sell Credit Repair – Wake Up! - August 28, 2023
- People That Got Scammed by Robocall Debt Relief Company Life Management Services of Orange County to Get Money Back - July 7, 2023
You know I just realized, where are all the debt settlement LAWYERS who do the Lord’s work for so many people? Why aren’t any of them on here defending their careers? I know that they are getting suspended and disbarred from time to time, but I don’t see any of them receiving any kind of humanitarian award.
Yes he did, and he gave us many examples, and I accepted them as fact, and they show that people can be largely (not completely) successful if their fees are cut to less than five percent, and as low as one percent, of their enrolled debt. He did a great job, and did not endanger anyone’s privacy. But he did not put a dent in my argument.
here we go again with little Errick’s “show me 1″… haha, ok let me break privacy laws just to give this random internet kid “one” client. Even Michael who writes on this board and is respected by many as verified he has done so…. What you what? Social’s? Telephone numbers for an interview?
Oh, I forgot to give you the solution which is scary that after 3 years in the business you haven’t figured it out.
If you’re ready, say I’m Ready…
Don’t put consumers into programs that don’t make the best financial sense for them!
Problem solved. I will send you over a Paypal link for my consulting fee.
Oh, one caveat to that, when doing the right thing, you can make a profit, but it will be less than you have been making thus far. You will have to decide what is more important, doing right by people or making as much money as possible.
Thus far, most have chosen the later, and unfortunately for you, created a reality that is impossible for you to defend even though your livelihood depends on it.
Keep in mind, I never said a debt settlement strategy is bad. The way most companies attempt to implement them are the problem.
Wow, I love this argument.
Banks screw people. We are screwing them less, therefore even though we are screwing people we are providing a good service. Brilliant.
I love how Sales people always jump to the extreme.
Well if it isn’t our program than it must be bankruptcy, and that is bad, therefore you must have our program or your life will be over.
Riddle me this…
Do you really believe that as a whole, the majority of the players in the debt settlement industry are doing a good thing for their clients?
If you believe this, please show me the data that shows that a majority of consumers who enroll in a typical debt settlement program end up better off.
You want to know about the millions of dollars that have been settled on a monthly basis as proof of success. Fair enough, let me point to the large number of millionaires created by Bernie Madoff as proof of his success as well.
Oh, we can’t talk about the much larger number of people that got screwed by him, we are only talking about his small number of successes as proof of concept that ponzi schemes work.
What else do you have?
I would like to hear from some of those thousands of people who are now out of debt. Would you mind asking them to post on this forum? The thing is, no one seems to be able to actually name, or produce, or verify in any way any of the successful clients of consumer debt settlement. I’m sure at least one of the thousands of clients would be quite willing.
I’m not sure if this will be posted or not or removed so the Debt Settlement industry is painted as this “fraudulant, predatory” industry where it’s minions are instructed to take advantage of little old ladies. I pose the question, what options would you provide as an alternative? Bankruptcy? And what about the millions of dollars settled on a monthly basis? Or the thousands of clients now out of debt without filing bankruptcy?
As one of the “minions” “selling” this product I have a inside perspective on how we do HELP consumers in need. The real crooks are credit card companies. It’s also the consumer’s fault for charging the credit cards without truly understanding the repercussions. Should they just be forced to file Bankruptcy or pay minimum payments for the rest of their lives or for the next 20yrs?
Attorney representation for some is everything. Knowing that in worse case scenario their attorney is there for them vs. a company giving a website and saying you’re on your own. I’ve been helping clients for over 3yrs now and 10/10 times if ask someone “if you are being sued would you like to address the situation on your own or have the assistance of an attorney?” they will ask for the attorney. Also, if you have $40,000 in debt at an average APR of 10% (far lower then the average rate) it will take someone 461 months paying $733 a month & $72,926 later to get out of debt if they can only afford the minimum payment. Compare that to 45 months, $640 a month, and $28,902 (including fees/attorney costs/45% settlement percentage), which one would you choose? And we won’t talk about the consumer’s with 19%+ interest rates. Or the consumer’s who cannot afford to pay for food because they try to keep up with their minimum payments. There is no magic wand to get out of debt and bankruptcy for some is not an option, so I pose again the question, what is your solution?
Joanne Garneau is the poster-child for fraudulant debt-negotiation schemes. Aside from the current class-action and attorney general lawsuits against her and her new “front” company LHDR, she was sued and basically shut down by the FTC in 2008:
http://www.ftc.gov/opa/2006/09…
http://www.ftc.gov/opa/2008/09…
Joanne Garneau is the poster-child for fraudulant debt-negotiation schemes. Aside from the current class-action and attorney general lawsuits against her and her new “front” company LHDR, she was sued and basically shut down by the FTC in 2008:
http://www.ftc.gov/opa/2006/09/nationwide.shtm
http://www.ftc.gov/opa/2008/09/nss.shtm
Give me a break. Typical sales guy, blame the client. I am so sick of sales people putting consumers into programs that don’t make financial sense and then blaming the client for not reading the contract. The contract is not going to explain what a bad plan this is if the client does not have the context to understand that what they are signing up for is not a proper solution.
I just got off the phone with a cancer survivor who is still getting treatments. She lost her job 6 months ago and is struggling to live on 900 a month unemployment while she finds another job. Her insurance alone is 650 a month which she has to have because of the cancer, and her rent is 600.
So enter a sales person for Imperial Debt Settlement. He has a genius plan, put her on a settlement program for 262 a month. Wait how is she going to pay that? He doesn’t care, he is going to make money until she realizes she can’t. She was nervous, scared, and confused and she was taken advantage of. She always paid her bills and wanted to do the right thing. This guy is promising a solution to pay her debt at lower monthly payments which sounds better than what she has. He says bankruptcy will ruin her and this is much better.
Then the new FTC law passes and this sales person moves to Morgan Drexen and tells the client to come with him after already taking 1200 dollars from her. Morgan Drexen happily accepts her and ups her payment to 550 a month to cover all their fees. Wow, how very consumer friendly of them.
That is when she luckily found my website.
She sent me over her cash flow worksheet and had 30 dollars a month listed as her food. I said you can’t possibly live on this and she says, I pretty much do. I have soup, water, bread and don’t spend much.
Frankly I don’t know how you sales people selling people into these front loaded programs with no hope of success can sleep at night. I asked if the sales person was aware she was unemployed and only getting 900 a month. Yes of course he was aware of it, but that didn’t matter, he was going for a sale.
If you don’t have an understanding of basic personal finance or you don’t really give a rip about ruining peoples lives you should not be on the phone selling something that you have no flipping clue about.
I know there are good people that work in the settlement industry, but if you are not reviewing a clients circumstances for ultimate success, then you are simply taking advantage of them and ripping them off. You can try and justify it all you want by blaming the client, but they are coming to you for help and advice. If you are not intellectually equipped to provide that, then stop pretending that you are. You are ruining real lives and families and at the end of the day it is on you.
You got to ask tho what about the clients that sign up for this stuff. It’s not like these people put a gun to their head and said hey give us your money. These people are obviously not reading their paper work that they are getting. It’s not hard to read very easy to complain and say you got taken advantage of.
You got to ask tho what about the clients that sign up for this stuff. It’s not like these people put a gun to their head and said hey give us your money. These people are obviously not reading their paper work that they are getting. It’s not hard to read very easy to complain and say you got taken advantage of.
Give me a break. Typical sales guy, blame the client. I am so sick of sales people putting consumers into programs that don’t make financial sense and then blaming the client for not reading the contract. The contract is not going to explain what a bad plan this is if the client does not have the context to understand that what they are signing up for is not a proper solution.
I just got off the phone with a cancer survivor who is still getting treatments. She lost her job 6 months ago and is struggling to live on 900 a month unemployment while she finds another job. Her insurance alone is 650 a month which she has to have because of the cancer, and her rent is 600.
So enter a sales person for Imperial Debt Settlement. He has a genius plan, put her on a settlement program for 262 a month. Wait how is she going to pay that? He doesn’t care, he is going to make money until she realizes she can’t. She was nervous, scared, and confused and she was taken advantage of. She always paid her bills and wanted to do the right thing. This guy is promising a solution to pay her debt at lower monthly payments which sounds better than what she has. He says bankruptcy will ruin her and this is much better.
Then the new FTC law passes and this sales person moves to Morgan Drexen and tells the client to come with him after already taking 1200 dollars from her. Morgan Drexen happily accepts her and ups her payment to 550 a month to cover all their fees. Wow, how very consumer friendly of them.
That is when she luckily found my website.
She sent me over her cash flow worksheet and had 30 dollars a month listed as her food. I said you can’t possibly live on this and she says, I pretty much do. I have soup, water, bread and don’t spend much.
Frankly I don’t know how you sales people selling people into these front loaded programs with no hope of success can sleep at night. I asked if the sales person was aware she was unemployed and only getting 900 a month. Yes of course he was aware of it, but that didn’t matter, he was going for a sale.
If you don’t have an understanding of basic personal finance or you don’t really give a rip about ruining peoples lives you should not be on the phone selling something that you have no flipping clue about.
I know there are good people that work in the settlement industry, but if you are not reviewing a clients circumstances for ultimate success, then you are simply taking advantage of them and ripping them off. You can try and justify it all you want by blaming the client, but they are coming to you for help and advice. If you are not intellectually equipped to provide that, then stop pretending that you are. You are ruining real lives and families and at the end of the day it is on you.
I’m not sure if this will be posted or not or removed so the Debt Settlement industry is painted as this “fraudulant, predatory” industry where it’s minions are instructed to take advantage of little old ladies. I pose the question, what options would you provide as an alternative? Bankruptcy? And what about the millions of dollars settled on a monthly basis? Or the thousands of clients now out of debt without filing bankruptcy?
As one of the “minions” “selling” this product I have a inside perspective on how we do HELP consumers in need. The real crooks are credit card companies. It’s also the consumer’s fault for charging the credit cards without truly understanding the repercussions. Should they just be forced to file Bankruptcy or pay minimum payments for the rest of their lives or for the next 20yrs?
Attorney representation for some is everything. Knowing that in worse case scenario their attorney is there for them vs. a company giving a website and saying you’re on your own. I’ve been helping clients for over 3yrs now and 10/10 times if ask someone “if you are being sued would you like to address the situation on your own or have the assistance of an attorney?” they will ask for the attorney. Also, if you have $40,000 in debt at an average APR of 10% (far lower then the average rate) it will take someone 461 months paying $733 a month & $72,926 later to get out of debt if they can only afford the minimum payment. Compare that to 45 months, $640 a month, and $28,902 (including fees/attorney costs/45% settlement percentage), which one would you choose? And we won’t talk about the consumer’s with 19%+ interest rates. Or the consumer’s who cannot afford to pay for food because they try to keep up with their minimum payments. There is no magic wand to get out of debt and bankruptcy for some is not an option, so I pose again the question, what is your solution?
I would like to hear from some of those thousands of people who are now out of debt. Would you mind asking them to post on this forum? The thing is, no one seems to be able to actually name, or produce, or verify in any way any of the successful clients of consumer debt settlement. I’m sure at least one of the thousands of clients would be quite willing.
here we go again with little Errick’s “show me 1″… haha, ok let me break privacy laws just to give this random internet kid “one” client. Even Michael who writes on this board and is respected by many as verified he has done so…. What you what? Social’s? Telephone numbers for an interview?
Yes he did, and he gave us many examples, and I accepted them as fact, and they show that people can be largely (not completely) successful if their fees are cut to less than five percent, and as low as one percent, of their enrolled debt. He did a great job, and did not endanger anyone’s privacy. But he did not put a dent in my argument.
Wow, I love this argument.
Banks screw people. We are screwing them less, therefore even though we are screwing people we are providing a good service. Brilliant.
I love how Sales people always jump to the extreme.
Well if it isn’t our program than it must be bankruptcy, and that is bad, therefore you must have our program or your life will be over.
Riddle me this…
Do you really believe that as a whole, the majority of the players in the debt settlement industry are doing a good thing for their clients?
If you believe this, please show me the data that shows that a majority of consumers who enroll in a typical debt settlement program end up better off.
You want to know about the millions of dollars that have been settled on a monthly basis as proof of success. Fair enough, let me point to the large number of millionaires created by Bernie Madoff as proof of his success as well.
Oh, we can’t talk about the much larger number of people that got screwed by him, we are only talking about his small number of successes as proof of concept that ponzi schemes work.
What else do you have?
Oh, I forgot to give you the solution which is scary that after 3 years in the business you haven’t figured it out.
If you’re ready, say I’m Ready…
Don’t put consumers into programs that don’t make the best financial sense for them!
Problem solved. I will send you over a Paypal link for my consulting fee.
Oh, one caveat to that, when doing the right thing, you can make a profit, but it will be less than you have been making thus far. You will have to decide what is more important, doing right by people or making as much money as possible.
Thus far, most have chosen the later, and unfortunately for you, created a reality that is impossible for you to defend even though your livelihood depends on it.
Keep in mind, I never said a debt settlement strategy is bad. The way most companies attempt to implement them are the problem.
You know I just realized, where are all the debt settlement LAWYERS who do the Lord’s work for so many people? Why aren’t any of them on here defending their careers? I know that they are getting suspended and disbarred from time to time, but I don’t see any of them receiving any kind of humanitarian award.
Errick, my assumption is that you work in credit counseling
at an executive level. Unless you reply that you are an attorney practicing
debt collection or bankruptcy, it would be hard to shake me off of this.
You have posted continuously on Care One threads on this site and rail against
debt settlement. You never mention that CareOne also provides debt management
plan services. Why is that?
CareOne offers DMP’s as a for profit company. One of the few who do. They do
not accept fair share or grant contributions from creditors to my knowledge,
unlike the non profit DMP providers who, for the most part, are beholden to
creditors and their whimsies because without the revenue from creditors they
would fail as going concerns. Why is it that CareOne can do what non profits can’t?
Are they more efficient than non profits? Probably, but let’s be real here. It
costs less than 10 bucks a month to service a DMP client. For some I bet the
costs are less than that. If the average monthly fee is $30 that’s at least a
200% return! With that kind of margin, why do non profits even need fair share
or grant money from creditors? What well run company cannot do well with a 200%
monthly operations budget?
I did not account for marketing. To do so would be to admit that nonprofit DMP
providers have to market. All the stuff I see presents nonprofits as some
benign help the community -help the people – type of set up. They are not. They
are companies just like any other. They just don’t pay tax and have to comply
with certain things as a result. They are to provide education. Big whoop!
There are many free sites with constantly updated money, budgeting and finance
education and advice that blow doors on the education offered by most non
profits. That being the case, non profits appear to not have to pay tax for
next to no good reason. If free sites can provide the same and better education
to consumers at no cost and pay tax on whatever revenue they generate, why cut
the nonprofits a tax break? Because they do the educating live in office or in
the local community, in schools and such? Maybe, but how many of the non
profits do that really? Could nonprofits who do not engage in DMP services do
the same and non profits DMP-ers pay tax? Yes indeed. Would creditors cut fair
share and grants even more because the “donations” would no longer be
a tax write off for them? You betcha! Nonprofits may take exception to my
stating this so simply, but it’s just not complicated.
So, non profits market. Is that why they need grant and fair share money? The
marketing and acquisition costs? Probably partly. I think its more a fact of
customer attrition though. What is the success rate of a DMP client? How many
people drop from a DMP in 3 to 12 months. Determining that number is important
for the American public to know. If the attrition is high, it means non profits
enroll people who should have been referred straight to bankruptcy. That’s the
only next step according to your answer. Why take on people who cannot finish?
For revenue and to serve the nonprofits true master, the banks. If nonprofit
DMP providers truly serve the consumer, and given your position that its either
DMP or BK than the only people who should ever be referred to nonprofit DMP
providers would be because of the BAPCPA. Following your logic it’s just that
plain and simple.
People should TRY EVERYTHING and when failed then to bankruptcy
is what you said above. Why Errick? Because its the moral thing to do? Because
it generates revenue for non profits? Because it serves banks?
So, what’s your opinion on CareOne’s DMP service they offer
while not accepting funds from creditors? Any feedback? I know mine. Its Kudos
to CareOne for being positioned to represent consumers more than banks.
Nonprofit DMP-ers cannot say they represent consumers more than banks with a
straight face.
I guess there are some states that require a nonprofit deliver a debt
management plan. So non profits should only exist to serve those states. I
think those laws should be changed to allow for profit companies who can do it better
and for less cost than the non profits and who pay tax to the treasury that
supports this country in its current troubled economy. Why the hell should
nonprofit DMP-ers be getting the tax break on DMP revenue when there is not
enough in the coffers to prevent severe poverty in this nation?
Errick – You favor DMP’s and I assume you work in the
nonprofit sector at a high and well informed level. How consumer focused are
the DMP-ers when 2 years ago one of the largest credit card issuers and another
one in the top 12 were offering account holders to settle their accounts at 15%
of the balance pre charge off? Were the DMP-ers “educating” consumers about
that? Bet not. For me, that would mean they are not interested in helping
consumers, just themselves and the banks they serve. Banks that, need I remind
you, have and will continue to pay out BILLIONS of dollars for their wrong
doing. That’s what you support Errick. A system that brought this nation to its
worst economic condition since the great depression.
“Now get in the pit
and try to love someone.”
P.S. I don’t work for CareOne or company related to them. I
am not related to anyone who does work for them nor any contractor for them
etc. I am just kinda sick of the Erricks and the holier than thou attitude they
have about debt management plans that are mostly offered by nonprofits. CareOne
is an exception and a good one for the DMP.
Legal Helpers Debt Resolution has just been sued by the Attorney General of Illinois. You can read the suit here.
Legal Helpers Debt Resolution has just been sued by the Attorney General of Illinois. You can read the suit here.
http://fmdconsumer.com/post/20…
One or more of the other models so call “face to face” models have an absolute cap of 20% in fees.
At the very least, and I mean VERY LEAST, LH should do the same and make sure when adding up ALL the fees, they do not go above 18% -20% and any monthly fee STOPS when the cap is reached if a program takes longer than estimated. I would expect that fair fees vs exhorbrint fees will be torwards the top of the list in the decision making process regulators use to decide what actions to bring.
Oh I forgot, if they did this they would their lose marketing affilates because the pie of fees then becomes too small. How many of these marketing affilates do we think have concern for the customer?
In the long run the lower fees would lead to more people signing up, less complaints and higher retention (more money for settlements), to the extent of it being an advance fee model.
LH are you listening? If not, fine, keep your head on the regulator chopping block and give the already tarnished industry a worse reputation. I doubt the FTC will go after legal helpers under the telemarketing rule, but if the FTC is not talking to state regulators and bar associations I would be very surprised, and all of their marketers will be much easier to bring action upon. Suppose I could be dead wrong about all of this?
Am I reading those excel spreadsheets right? About $12,000 in fees assessed to a client with 40,000 in debt, and front loaded??? Isn’t that around 30%??? And that is before they completely TKO the client with the financial coaching upsell sham?
Retainer fees, performance bonus fees, 125.00 monthly legal fees, account fees, coaching fees…… Are you kidding me? How long is the pole these crooks are shoving up the backsides of their clients??? Sad thing is that they are going to need all that revenue and more to cover all the expenses from incoming legal bills and regulatory fines. High Industry marketing costs will be petty in comparison to a few more of these actions.
My question is when will the marketing front-ends of LHDR realize that they are just pawns being manipulated like puppets for the benefit of the coffers of Macey, Searns, Garneau, Leuthold, et al (aka “The Greed Club”). How do these people sleep at night? I mean really?
Classic.
NIce work Steve.
Do research on Joanne’s son’s prior debt settlement company and his former partner Dennis and you will be tickled with integrity. Here’s a hint. It’s called Homeland Financial.
TASC has lost any credibility it never had.
Classic.
NIce work Steve.
Do research on Joanne’s son’s prior debt settlement company and his former partner Dennis and you will be tickled with integrity. Here’s a hint. It’s called Homeland Financial.
TASC has lost any credibility it never had.
Bad news Bears. Looks like a bunch of people trying to game the system and stiff consumers with the bill. Nothing new in the debt relief space unfortunately. If someone calls you and offers to help with your debt, forget it, they are pitching you something you don’t need. I can say that every time and I would be spot on more than 95% of the time. Sad, but true.
Bad news Bears. Looks like a bunch of people trying to game the system and stiff consumers with the bill. Nothing new in the debt relief space unfortunately. If someone calls you and offers to help with your debt, forget it, they are pitching you something you don’t need. I can say that every time and I would be spot on more than 95% of the time. Sad, but true.
Am I reading those excel spreadsheets right? About $12,000 in fees assessed to a client with 40,000 in debt, and front loaded??? Isn’t that around 30%??? And that is before they completely TKO the client with the financial coaching upsell sham?
Retainer fees, performance bonus fees, 125.00 monthly legal fees, account fees, coaching fees…… Are you kidding me? How long is the pole these crooks are shoving up the backsides of their clients??? Sad thing is that they are going to need all that revenue and more to cover all the expenses from incoming legal bills and regulatory fines. High Industry marketing costs will be petty in comparison to a few more of these actions.
My question is when will the marketing front-ends of LHDR realize that they are just pawns being manipulated like puppets for the benefit of the coffers of Macey, Searns, Garneau, Leuthold, et al (aka “The Greed Club”). How do these people sleep at night? I mean really?
One or more of the other models so call “face to face” models have an absolute cap of 20% in fees.
At the very least, and I mean VERY LEAST, LH should do the same and make sure when adding up ALL the fees, they do not go above 18% -20% and any monthly fee STOPS when the cap is reached if a program takes longer than estimated. I would expect that fair fees vs exhorbrint fees will be torwards the top of the list in the decision making process regulators use to decide what actions to bring.
Oh I forgot, if they did this they would their lose marketing affilates because the pie of fees then becomes too small. How many of these marketing affilates do we think have concern for the customer?
In the long run the lower fees would lead to more people signing up, less complaints and higher retention (more money for settlements), to the extent of it being an advance fee model.
LH are you listening? If not, fine, keep your head on the regulator chopping block and give the already tarnished industry a worse reputation. I doubt the FTC will go after legal helpers under the telemarketing rule, but if the FTC is not talking to state regulators and bar associations I would be very surprised, and all of their marketers will be much easier to bring action upon. Suppose I could be dead wrong about all of this?