The Importance of Data Transparency When Working With Credit Counseling and Debt Settlement Regulators and Lawmakers

Recently Christoper Viale, the president and CEO of Cambridge Credit Counseling, and I had a chance to talk about a number of issues that are important in the debt relief world today.

You can read the full transcript of our conversation below.

Some of the highlights are:

  • Coming forward with actual credit counseling performance data was not embraced with open arms by the larger credit counseling trade associations like the National Foundation for Credit Counseling (NFCC), the parent of Consumer Credit Counseling Service, nor the Association of Independent Credit Counseling Agencies (AICCCA).
  • Lawmakers and regulators are thirsty for actual performance data to show the effectiveness of debt relief solutions.
  • We talk about the dangers of not publicly reporting data honestly.
  • Providing good and comprehensive data to regulators can change minds.
  • Consumers need standardized public reporting of performance data so they can make educated and informed decisions about how to get out of debt.
  • Christopher is willing to help and assist any debt relief company to embrace the public reporting of their performance numbers. He invites people to contact him and he’s happy to share his experiences, data points, collection methods, and help in any way. His contact information can be found at the end.
  • He talks about why debt settlement is a consideration for people even when they contact a credit counseling agency.
  • We talk about the shrinking pool of consumers that need debt relief help and services and why that makes it harder for debt relief companies to find new clients.
  • We learn that credit counseling is not a lucrative business to run, client bases are shrinking and the outlook for people needing the service is not good.

The interview contains a lot of good information and insight into openness, transparency, and the state of the credit counseling world today.


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Steve Rhode: I’m here with Christopher Viale, the president and CEO of Cambridge Credit Counseling, who recently released performance numbers, a new event in the credit counseling world of talking about openness and transparency and actually showing how effective the services are. Christopher, thank you for joining me.

Christopher Viale: Thank you, Steve, for having me.

Steve Rhode: Well, I’m sure that your first foray into openness and transparency in the credit counseling world was met with some sort of reaction. What was the reaction?

Christopher Viale: Well, I had some peer agencies that I’ve worked with for the past few years that were excited about it. I did have some resistance from some of the trade groups. I guess they felt that this is more of a self-promotion rather than more of an industry movement that I’m trying to initiate, so it was mixed, Steve, definitely mixed.

Steve Rhode: What’s the downside? What’s the argument of a downside to providing performance transparency?

Christopher Viale: Well, some of the feedback I’ve gotten is that the second we have numbers out there, other companies are gonna try and measure up to those numbers, and they may not provide numbers that are accurate just to measure up in an effective way to hold themselves out to consumers and regulators and legislators that they’re doing a good job. And it also seemed as though some folks thought that Cambridge – by Cambridge doing this we were trying to get a competitive advantage in the marketplace, and it has nothing to do with that at all. We’re simply in a position where regulators and legislators don’t know how effective our services are, because some of the trade groups and some of the organizations that have controlled the industry simply don’t gather this data, or if they do, they don’t publish it. So, it’s really important that our profession takes a stride in the right direction to hold out to these groups that what we do really does help consumers, and it is an effective process.

Steve Rhode: In the past, I’ve asked the National Foundation for Credit counseling for performance numbers, and they have always been hesitant and never provided any, which always seemed surprising to me, because as a national group of consumer credit counseling offices, you would think that they have at least some idea about how effective their services are, other than just saying, “Hey, we’re the white knight. We’re really effective.” What has been your response in providing this information to lawmakers or regulators?

Christopher Viale: It’s been met with open arms. They clearly indicate to me, “Are you sure you wanna go on the record with this data?” because I think it shocks them that someone in our industry was willing to put out clear figures on performance, whether it be failure rate, success rates, the benefits that consumers receive. I met with the National Consumer Law Center, some of the higher-level folks there. I’ve met with and talked to the FTC folks. I’ve met with some of the folks at NAAG, which is the National Association of Attorney Generals that are on the consumer protection division committees, and they’re eager to see and understand what all this means, so it’s been very enlightening experience. 

When I first brought this to the industry about six months ago, it was after several meetings I had had with these policymakers, and with all the problems in the debt settlement field, they’ve really muddied the water in the debt relief space. And it’s really made it quite cloudy for these policymakers to navigate what is a good debt relief provider or service. So, after meeting with all these folks, they said the one thing – and this was consistent across the board – the one thing that I heard over and over again, the theme was transparency. What does the data really show? You guys hold yourselves out as the white knights. 

You’re the good guys. You’re fighting these debt settlement groups, saying that they are the bad guys, but you are the good guys. Well, what evidence do we really have that this works? So, that was the theme, and when you talk about the NFCC, I spoke with some folks there, and I’m not gonna name names. They wanted to be off the record, but they said to me that they do provide data to the National Association as part of their due diligence, but the data is how many DMPs enrolled, what – there’s no real meat to the data. 

They’re just looking at basic data, not really getting into what the consumer experience is truly like and what a consumer can expect from their experience as far as success when they’re on these plans. So, I think I’ve shaken things up a little bit, and I hope for the good.

Steve Rhode: The information that’s reported, some say it’s, as you mentioned before, it’s only in your self-interest, and some say that maybe the data isn’t reliable; you’re just trying to show a good side. But, if a company did that, if a company lied about their performance data, wouldn’t that come back to bite them in the ass?

Christopher Viale: Oh, absolutely, because at the end of the day, this is gonna need to be validated by third parties. This is just the start of the process that Cambridge has undertaken. When I came to industry six months ago with an urge to try and move this forward, I fell on deaf ears. I mean, that whole initiative fell on deaf ears with the trade groups, so I just moved forward with the process and in hopes that others would follow along. And I know of a few agencies that wanna come down the same path, and once we’ve identified the actual data and how each agency is going to provide accurate data to each of the metrics, then we’re gonna go out, get – hire a third-party group to come in and validate the fact that these numbers are accurate and they’re on the record. 

For any – it’s funny, too, because I’ve had some agencies, through e-mail, say, “Yeah, Cambridge is putting this data out there. It can’t be reliable. They’re just trying to hold themselves out as the good guys.” With everything that Cambridge went through, for me to put data on record with the FTC and consumer groups and national Association of Attorney Generals and that data not be accurate, I mean, that would be pretty naïve and I’ll say stupid on my part, so…

Steve Rhode: Now, some groups say that providing the data doesn’t make any sort of difference at all, and it’s a worthless exercise, and it won’t change anybody’s mind. But, what I hear you saying is, “That’s not true.”

Christopher Viale: Oh, it’s not true at all. Part of the reason that Cambridge is able to provide some of this data, through all of the trouble that Cambridge went through in the early 2000s, for Cambridge to come out of that and still be a going entity, I had to agree on all kinds of consumer protection measures with attorney generals throughout the country and agree to have monitors in place to make sure that Cambridge was fulfilling its intent of trying to develop a best practice for the consumer itself. So, our system, which is – it’s a proprietary software that we have, with our quality assurance team that we have in place, we look at this data and strive to get each piece of this data better and better every single quarter for the past six years. So, by putting data out there, by no means am I saying, “Okay, Cambridge is the best company.” It’s not about that. 

It’s about, okay, here is the data. How do we keep improving on this data? And if agencies want to get on board – and maybe they haven’t had to go through what Cambridge has had to go through, and maybe they’re not operating as efficient as they can and experience that the consumer may not be the best it can, but if they have their numbers and they’re actually able to look at the data on a quarterly basis, you got to imagine that these groups do want to improve, and this is the perfect vehicle, a tool to be able to have an agency continually strive to improve the experience the consumer is gonna have.

Steve Rhode: So, the data is not necessarily focused on how many DMPs that Cambridge enrolls. If I hear you right, the data is focused on the consumer experience and the results that it achieves for people who do enroll.

Christopher Viale: That’s absolutely correct. We do have a lot of data on the counseling sessions for folks that don’t enroll in a DMP, and as we move this project along, each quarter there will be a separate theme that we sorta highlight in each of the quarter releases that we do. But, for the beginning part of this, based on what I heard from the consumer protection groups and the policymakers, they wanna know that when we hold out to a consumer that a DMP is a good relief product for them, what are the results? And if we’re holding out certain expectations, are – does the average consumer, the typical consumer get that benefit? 

Do they receive those benefits that you’re holding out? That seemed to be the most important thing right now when we had the debt settlement problem that we’ve had for the past couple years. You’ve got groups like the Consumer Union, the CFA, Consumers for Responsible Lending and the National Consumer Law Center, whether they’re working together or in conjunction, it’s to sort of create a white paper to hand off to Elizabeth Warren’s group to say, “Okay, here’s the true relief of these debt relief products,” whether it be – they’re trying to focus on debt settlement being bad or good or being lumped into that same thing. I felt through all of my meetings that it is critical to get our best foot forward, that the experience consumer does receive from what we hold out is a typical experience and it’s a good experience for the consumer. So, that was the main focus of the first release was just to address the fact that we’ve got the new Consumer Protection Bureau coming into play, and they’re asking for information. 

And the consumer groups are asking us for information, so, I mean, it seems – it would seem foolish not to be as transparent as we can right now given the environment that we’re in.

Steve Rhode: So, how did credit counseling get away with not reporting data for half a century?

Christopher Viale: Groups claim that they don’t have access to the data, or that the data is going to be specific to a region, specific to the type of consumer an agency may see, so it may slight the results from one agency to another and, obviously, at that point, then, give a competitive advantage that may not be true to the actual reports that are out there. You hear all kinds of excuses, Steve, on why this data hasn’t been released. One of the trade groups – well, two – I think the NFCC and AICCCA worked together back in I wanna say ’02 through ’04 to have a report released in ’06 that talked about the effectiveness of phone counseling, and that was a very comprehensive report, 70-page report at the end of the day, and it was done in a very good fashion, but it was for a different purpose. It was for the purpose of making the consumer groups and others understand that phone counseling can be as effective as face-to-face counseling, ‘cause there was a notion that the phone counseling rooms, these DMP mills weren’t really a good option for consumers to experience. 

And that report issued in I think it was ’06 was held out to me, as an example, our industry has already done the work I’m trying to do right now. It has nothing to do with the questions our industry is being asked right now.

Steve Rhode: So, if there was a standardized reporting, would consumers be better informed or better able to make an informed decision about what debt relief product was more appropriate for them?

Christopher Viale: Absolutely, it would help them. It would definitely help them. It would help them understand that this isn’t an easy process. There are too many credit counseling companies or all debt relief providers that pretty much hold out to a consumer that once you’re on our plan, you’re done. You’ll be out of debt in three to five years or two to four years, depending on which product you’re talking about, and you’re done. 

It’s all over with. You’re good to go. The creditors are gonna be fine, and you’ll get all these benefits, and you’ll be out of debt nice and easily. Well, it’s not like that. As you could see in my transparency project, a lot of consumers fall out of these plans, because it’s a difficult process. 

If we’re holding out a DMP to a consumer, that means things are extremely tight for that consumer. For the creditors to endorse the plan and provide the benefits, we’ve gotta be able to prove through our budget analysis that things are tight, and if things are truly very tight for the consumer, it’s only a one-off financial experience that can get them off track and fall off these plans. So, I think it’s important that consumers know that these aren’t easy fixes, so at the end of the day, if all agencies have some sort of consistent reporting of data, will it lead to a consumer comparing prices, comparing results? I’m not sure of that, Steve. I mean, that could be a long way away, but at the very least, they should be a little bit more understanding of this isn’t a quick fix, an easy fix, that they’re gonna have to work just as hard as we work at it for them.

Steve Rhode: So, do you think that people are gonna join you on this journey, or are you gonna stick with it? What’s the future look like on reporting transparency numbers?

Christopher Viale: Yeah, I don’t know. We’re sticking with it 100 percent. This is an initiative that we’ve undertaken. I’ve got a team in place here at Cambridge that is working on this project, so Cambridge is going to continue its path. We feel and believe that this is the right path to take right now. 

I’m hopeful that some of the trade groups do have maybe at some of the upcoming conferences there will discussions about this, but I am hopeful that others do follow suit and weigh in with similar data. And one of the things I’ve held out to everyone is I’m willing to talk about the data points. If I’ve got it wrong and we need to be reporting data in different areas, then let’s talk about it, but it was complete silence, so we had to give our best effort here at Cambridge and provide the data that we felt fit the bill for what is being asked of our profession today.

Steve Rhode: So, of the data that you released, were there some data points that you felt like you could still do better on and are striving to increase?

Christopher Viale: Oh, absolutely. Our proposal acceptance rates. It’s critical that consumers get a comfort level when they first start these plans and that you get as many of these proposals accepted on the first blush through with the creditors so that the consumer experience that first month or two can be a little bit more comforting rather than having denied proposals and creditors calling the client and you having to call the client back and increase payments or ask for additional information. You always can strive to do a better job there. The fact that the completion rates – every company should be striving to have a stronger completion rate, whether it be early in the plan or through the full average 53 months the consumer is with us, the suitability of the plans. 

Are we putting the right plan in front of someone? The benefits consumers receive from these plans, I’m hopeful that this can shed some light to folks like Elizabeth Warren’s group or the OCC or FFEIC that the creditors, we don’t get enough from the creditors in certain circumstances to give enough relief to the consumer. So, maybe data like this can shed some light on the fact that pressure should be put on the creditors to help us out a little more and help consumers out a little more. There are all kinds of data points in here that we’re looking to improve on, and I know for a fact as these reports come out each quarter, we’ll go up and down with some of these numbers. They will have quarters where we haven’t performed as well as we have the quarter before, but we’ll look at that, try and get to the root cause of why we may not have performed as well for our consumers or consumers didn’t perform well on the plans and try and build on that to heighten that experience for the consumer and the staff here at Cambridge. It’s a work in progress, steve.

Steve Rhode: the recent FTC hearings last year that the debt settlement industry went through and their apparent inability to provide performance numbers, was that an eye opener for you that – keeping those numbers secret or not providing them was not helpful?

Christopher Viale: It wasn’t helpful at all, and that really was the first, I guess, wake-up call that I took personally to say, “Wow, these guys got scolded.” They got scolded for the right reasons. We know that the debt settlement industry, for the most part, the majority of the industry, the bigger players weren’t playing very fairly with consumers, so it wasn’t a shock to me they got scolded. But, the fact that they couldn’t produce any data at all and McCaskill and Rockefeller sort of centered in on that, that was an indication of things to come. With the new Consumer Protection Bureau and Elizabeth Warren’s group and their power, it’s much more overreaching than the FTC, so for folks not to think that any debt relief provider or any type of relief service isn’t gonna have to weigh in on numbers and actual back up those numbers, again, they’re just being foolish.

Steve Rhode: Are you willing to talk to anybody in the debt relief world about the benefits of transparency and how to collect this data even if they aren’t necessarily a credit counseling company?

Christopher Viale: Absolutely. I looked at – right now, there are a few states that are looking at different legislation for our space, our industry, and TASC most recently in the state of Delaware submitted testimony that I almost threw up after I read it. That’s how pathetic they sorta portrayed the experience consumers have from a fee standpoint and from a cost standpoint from credit counseling to debt settlement. And it’s that type of garbage that’s being released by some of the debt settlement folks that’s really making it difficult for anyone that’s trying to navigate through this and legislate properly to put laws in place that can protect consumers, but give consumers choice. It just muddies the water. 

I mean, it’s making it impossible for these lawmakers to weigh in and actually have some evidence and some facts to come out on the other end, and a lot of these hearings and a lot of these legislative battles, they just get put off. And if they keep – continue to get put off, then you’ve got as some of the debt – the bad debt settlement providers and bad credit counseling providers call them, they’ve got their green states where there’s no real laws to oversee the industry, and they focus in on those consumers in those states. So, yeah, by all means, my door is wide open to talk to anyone. I’ll do my best job to explain what we’ve done here at Cambridge. My doors are open for folks to come in and take a look at the quality assurance program that we have in place and understand the data points and the metrics behind how we have produced the data. All of that’s wide open.

Steve Rhode: So, even if they’re a debt settlement company, they can still come and visit you and call you?

Christopher Viale: Yeah. Some of my colleagues in the credit counseling space don’t like that, but absolutely. I mean, we can’t – our solution, credit counseling, the DMP product for consumers is only 23 percent of the consumers we talk to, or 30 percent. Thirty-four, I think, overall we offered the plan to, but only 23 sign up. There’s another 66 percent out there that need some other form of relief. Maybe 20 percent of those folks can handle their debts on their own; they just need the advice and guidance to recast their budget and do a little bit better job on their spending monthly. 

But, 30 percent of the people that Cambridge talked to, we can’t set up a relief program that’s effective for them ‘cause we can’t get their payments low enough, and they either don’t wanna file bankruptcy or have filed bankruptcy and can’t file bankruptcy again. So, by all means, credit counseling is not a one-all solution, so for my industry to not openly embrace debt settlers that are compliant and trying to do the right thing by the consumer, again, I’m gonna call that a foolish event. We should be working somewhat hand in hand. At the end of the day, the credit counseling industry is very hopeful that we’ll have a product that can replace the debt settlement providers. Whether or not that ever comes to fruition, we’ll see, but it’s years away. 

It’s not tomorrow, so there are plenty of consumers that go unserved or get served in a bad way by bad providers, so I’d rather be open and transparent and talking to as many good providers as I can from both our side and also the debt settlement side.

Steve Rhode: so, what happens between credit counseling and debt settlement? It seems that for many the point is lost that it needs to be about the consumer first.

Christopher Viale: Yeah, well, we have a four – well, let’s – our – both sides of the industry right now in the profession are struggling with consumers intake. We have less and less consumers to talk to. With the freeze of credit for the past three to five years, the bombardment of debt settlement ads for a good two-, three-year period, the consumer pool out there is a lot lighter. There are some reports that I’ve seen that counseling sessions are down as much as 60 percent from last year at this same time, so when you’ve got a competitive environment, even though the credit counseling side is nonprofit, we still have bills to pay and operations to run and salaries to pay. It’s a very competitive environment right now to try and find those last Joe Smiths that are out there that need some sort of relief product. 

So, it’s – I think it’s a little more difficult when you have such a competitive environment to try and work – for groups to work together to try and really have the consumer first rather than their own needs first. I think that’s one of the problems that we have right now, Steve.

Steve Rhode: I hear from the debt – every month now for the past few months I have been publishing search data, search trends for debt relief words, and what I hear from the debt settlement side of the aisle is the reason their business is down is because of the regulation they went through and the bad PR that the industry got. But, what I hear you saying is that’s not necessarily true, because the demand for debt relief services is down across the board.

Christopher Viale: It’s absolutely correct. Now, the debt settlers are probably right, because now – to a degree, they’re right. Most of their advertisements are online. They’re dealing with consumers with an average debt load of 30,000 plus. Those consumers are Internet-savvy people, for the most part. 

Credit counseling deals with consumers with less debt, and maybe the profile of our consumers is slightly different than the profile of a debt settlement consumer. So, if you’ve got basically an Internet-savvy consumer profile, it doesn’t take much to find bad news about that settlement, so if a consumer’s researching their options and they’ve run across an ad that sounds good and they’re talking to a debt settlement provider, they’re gonna have a lot of questions to be answered. And I’m sure that if you were to pull any of the debt settlement groups, even ours, even at the credit counseling side – the main question we used to have to answer years ago was, “How is this gonna affect my credit?” and, “How much is this service gonna cost?” Now we hear, across the board, “How can I trust you?” and, “What is all this news?” and, “How do I know you’re gonna pay my bills?” it’s a different environment that we hear when we’re talking to consumers, so I’m sure when you hear that notion from the debt settlers that they’re right, but at the end of the day, there’s a ton less of consumers to draw from. 

There are no new consumers coming into debt issues, because there were no credit cards being issued for years. Or credit lines were froze or reduced, so when the Credit CARD Act came into play, most of the major banks, whether they agree or not, re-priced most of their consumers back in ’06, ’07. That was the surge that we all got, because consumers were pretty angry with their credit card companies for reducing the credit lines, which in turn lowered their credit scores, which in turn allowed for creditors to increase their interest rates, which doubled their payments. I mean, we – that’s all we heard on the phone for a good year and a half. All the people that were in debt made those reach-outs in that ’07, ’08, ’09 timeframe. 

No new debt was being issued. No new credit was being issued, so we had no new – no true new debtors coming into play. It’s common sense that there’s a lot less people to draw from right now.

Steve Rhode: So, once that mess was kind of addressed, as one debt settlement company said to me at one time, “You know, we might’ve collected a lot in advance fees, and we took a lot of money up front, but at least we got them to bankruptcy quicker.”

Christopher Viale: – anyone makes a comment like that really doesn’t belong in our space.

Steve Rhode: But, that pool of consumers, there’s still a lot of consumer debt that’s out there that’s reported by the Fed, but what I hear you saying is that the pool of consumers that were in trouble and falling into default and needing some sort of intervention, that pool is significantly smaller.

Christopher Viale: It’s significantly smaller, and I don’t know – I haven’t seen this as of yet, but I don’t know what the signup rate or closing rate or whatever, whatever phrase they use on the debt settlement side on credit counseling for someone who is eligible for a DMP and it’s the right solution, generally we’re gonna have a 50 percent signup rate, maybe 60 at the highest, for folks that are eligible for it. The debt settlement in their best of days, there was no suitability test. I mean, they would just sell, and you could still eliminate your debt. I mean, there was no real test, so anyone they talked to with debt, they were trying to sell that consumer on their product. From what I understand, they may have only had a five percent enrollment rate or ten percent enrollment rate, so for all of the folks that made phone calls to these debt settlement providers that didn’t sign up, they didn’t sign up for a couple reasons. 

They did the smell test and realized they were being sold a bill of goods that really probably wasn’t that – wasn’t gonna come true, or they got persuaded not to do it by family members or friends. Those folks have lost their confidence in any debt relief product, so for them to reach out again, and if they were to reach out to an ad that it’s on TV for credit counseling, it’s gonna seem similar to them, or an online ad, it’s gonna seem similar to the experience they had with the salesperson at the debt settlement company in the heightened days when they were getting hundreds of thousands of calls into their call centers. So, folks have lost confidence. They’ve lost trust, so not only do we have a lot less people to draw from, but even the folks that are out there that might be struggling are a little scared to make a phone call or even reach out, because they’ve tried it once, and they did their either due diligence, smell test, whatever you wanna call it, and never signed up.

Steve Rhode: So, debt settlement companies are saying that credit counseling is getting a free pass in many of these states because they’re exempt from legislation. Is credit counseling the lucrative landfall that debt settlement people think that it is?

Christopher Viale: Lucrative? No. I don’t know of many credit counseling companies that are operating at a break even for the past couple years. All of our client bases are shrinking. As far as we’re getting a free pass, if you’re in the credit counseling space, for the most part, almost all of us are gonna be 501(c)(3), and to these we’ve got as much regulation over our heads as the debt settlement folks do. The FTC through TSR rules, we’re exempt from that, but still, we fall under the purview of the creditors with the mandates of what we can and can’t do. 

We fall under the purview of 501(q), which is very clear. The rules are written very clearly now about how you need to operate in a 501(c)(3) space, and the various states, they’re – I mean, if I go into my lobby on our wall, I think we have 28 licenses. We’re exempt from certain states, and there’s still states that haven’t enacted legislation, but I think we have – I think it’s 28 separate licenses that we have to – we get audited against or have to reapply every year for those licenses. So, to say that credit counseling is unregulated is a complete misstatement, absolute misstatement. For you to be able to have proposals accepted to be able to offer a DMP plan, you’ve gotta adhere to the code of practice, which is an AICCCA/ISO code of practice that’s in place. 

That’s another set of rules that you have to follow, or if you’re an NFCC member, you have to follow COA accreditation, which is a whole ‘nother set of rules that you have to follow. If you misstep on any of the rules, charge fees outside of the scope of what you’re able to do, don’t have the technology in place to transmit proposals electronically and – I could on and on and on – you can’t be in this credit counseling space, because you can’t get proposals accepted. And if you can’t get proposals accepted, you don’t have anything to offer a consumer. So, for folks to think that we’re unregulated and we have a free pass is ludicrous. I have 14,000 active clients – well, a little over 13 now, thousand active clients. I’ve got a staff of 70, and I have a staff of 3 full-time people that are in my compliance division, so…

Steve Rhode: And they just make sure that things are runny smoothly?

Christopher Viale: It’s just for – running smoothly, the reporting that it takes to hold the licenses in the various states that we’re licensed in. We’re now on the verge of getting into our EOUST approval. We’ve got our application in, so that’s a another whole set of regulations and rules we have to follow. We’re a HUD-approved agency, which is another whole set of rules that we have to follow, so that – there’s no free pass in the credit counsel world.

Steve Rhode: So, on top of that, you mentioned earlier about the CFPB, the Consumer Financial Protection Bureau, coming, and that’s gonna regulate both debt settlement and credit counseling groups, is that right?

Christopher Viale: That’s correct.

Steve Rhode: So, that’ll be yet another layer, or will the CFPB regulations replace any of the regulations that you’re under now?

Christopher Viale: Well, I can’t see them – well, if we’re not transparent about the services that we’re offering, if there’s not an effort to make sure Elizabeth Warren and her staff understand the true results of our programs, there could be a whole new set of requirements on disclosures prior to enrollment that we’ve never seen before, and they could dictate what those requirements are if we don’t get in front of the game. So, I do see that as a opportunity today. If not acted on, we could see this as another layer of additional regulations or rules that we have to follow that may be unreasonable. We don’t even know. We don’t know where the CFP will come out with this, because the only thing they have is all the bad information about that settlement.

Steve Rhode: Yeah, it seems that with the CFPB potentially so close to rolling out that the credit counseling industry would be embracing the distribution and reporting of data, but what I hear you saying is that even though you’ve made this effort, for the most part, the industry is resistant.

Christopher Viale: They’re resistant from what I understand. Now, if there are initiatives that are happening that are outside of my vision and I don’t know about it, it could be. Some of the larger agencies, like the Novadebt, Money Management International, and Take Charge, they have strong teams in place that should be able to report everything the way Cambridge is reporting, or in some variation of that. And they be – they may be working individually with the CFPB, I don’t know. I’ve tried to ask that information, but it just falls on deaf ears.

Steve Rhode: All right, well, thank you so much for your time today, Christopher, and I appreciate it, and if a debt settlement or a credit counseling group wants to reach out to you, how do they get you?

Christopher Viale: They can e-mail me at cviale@cambridgecredit.org or they can call me on my direct line here at 413-821-6919. You can go to our main page on the website and the transparency project is there with all the contact information, and I’m here to help in any way I can.

Steve Rhode: All right, thank you, Christopher.

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