Allrepco Claims to Be TSR Exempt from Credit and Debt Help

A reader brought to my attention. The tipster (send in your tips here) wanted to know how a debt relief site could proclaim, “We are proud to state that we are federally exempt from the CROA (Credit Repair Organization Act) and the TSR Federal Debt Settlement Rule to serve consumers in all 50 states.” Good question. is owned by:

Credit Restoration Brokers LLC
12995 S. US 41
Suite 243
Fort Myers, Florida 33907

The Administrative contact is Sam Sky and the other sites on this server are:

The site sells a monthly service package that costs between $99 and $140 a month for services that include credit repair and debt negotiation services.

Debt Negotiation Services

o We negotiate your debt at a 60% savings or greater – off the alleged amount owed.
o We negotiate the options for you to pay (for your convenience and savings) monthly installments or a one time payment to settle your debt for less than what is owed.
o We communicate with Creditors and Collectors for you.
o In our negotiations, we send letters, we speak to the Creditors and Collectors on the phone, we communicate all offers to you that are at a 60% savings or better and we negotiate payment arrangements on your behalf.

Credit Repair Services

o We prepare dispute letters to all 3 Major Credit Bureaus (and Subsidiary Bureaus) every 30-45 days to legally dispute negative tradelines – such as credit cards, collections, inquiries, excessive addresses, excessive places of employment, AKAs, etc.
o We offer in house credit monitoring.
o You will receive a copy of “The Credit Book” and “It’s OK not to Pay”, by author Sam Sky.
o We provide credit education and legal tricks to boost your credit score.

On the face of it it seems the idea is the services they offer they want to claim are free as part of some larger membership bundle.

The package is said to include:

  • Found Money
  • Advice on Foreclosure, Short Sales and house payments
  • Food Stamp Product (eligibility requirements differ from state to state)
  • Debt Negotiation Services
  • Credit Repair Services
  • Joe the Consumer Games
  • Section 8 Housing
  • Financial Aid for College students
  • Secretarial Services – Source

What makes the statement and sales of the services even more astounding is that in 2010 Sam Sky settled with the FTC and agreed to stop offering credit repair and debt relief services. The FTC announcement at the time said:

A promoter of credit repair and debt relief services has agreed to settle Federal Trade Commission charges that he deceived consumers into paying thousands of dollars based on false promises that he could help solve their credit and debt problems.

According to the FTC, the promoter falsely told consumers he could improve their credit reports by removing negative information such as judgments, foreclosures, tax liens, bankruptcies, repossessions, and child support delinquencies, from the reports regardless of how old or accurate the information is. The FTC’s complaint also alleged that he and his lawyer falsely told consumer reporting agencies, as a reason to dispute negative items, that consumers were identity theft victims.

The FTC complaint charged that the marketer, Sam Tarad Sky, and his companies illegally charged consumers up to $2,199 before performing any services and failed to tell customers they could cancel the contract within three business days. He also falsely told consumers who bought debt relief services that they could satisfy their debt by paying much less than the full amount owed, such as 30 cents on the dollar.

The proposed settlement order against Sky and his companies bars them from deceiving consumers about any credit repair or financial good or service, and requires them to back up any debt relief claims they make, inform consumers that they have a right to cancel, and tell past clients how to have their escrowed funds returned. The order against Sky’s attorney, Kurt A. Streyffeler, and Streyffeler’s law firm, Kurt A. Streyffeler, P.A., bar them from misrepresenting any credit repair or financial good or service, and from violating the Credit Repair Organizations Act. All of the defendants are barred from selling or otherwise disclosing customer information.

The orders impose judgments of almost $2.5 million against Sky, Credit Restoration Brokers LLC, and Debt Negotiations Associates LLC, and $100,000 against Streyffeler and his law firm. The judgments will be suspended because of their inability to pay. The full judgments will become due immediately if they are found to have misrepresented their financial condition. – Source

In April of 2011, the FTC filed contempt charges against Sky and his enterprises, including Sam Tarad Sky, Allrepco LLC, Credit Restoration Brokers, LLC, and Debt Negotiation Associates, LLC.

The Federal Trade Commission has filed contempt charges against a promoter of credit repair and debt relief services and three of his companies, alleging that they continued their deceptive marketing practices in violation of a federal court order. The FTC charged that the defendants tried to take advantage of financially strapped consumers by falsely telling them that almost anyone can qualify for food stamps, and by encouraging them to mislead the government about their finances to qualify for the food stamp program.

As part of the FTC’s ongoing efforts to protect consumers in financial distress, the agency seeks to ban the defendants from selling credit repair, debt relief, or government-related goods or services, and make them pay compensation to consumers.

The FTC charged that Sam Tarad Sky, Allrepco LLC, Credit Restoration Brokers LLC (CRB), and Debt Negotiations Associates LLC (DNA) violated the terms of a March 2010 court order that resolved charges that the defendants deceptively marketed credit repair and debt relief services, and illegally charged an up-front fee for credit repair services. The court order bars them from deceptively marketing any good or service and from violating the Credit Repair Organizations Act.

Despite the court order, the FTC alleges that Sky and his companies used two websites to promote a food stamp application guide that falsely promised it would show how “almost everybody” or “virtually everyone” can “legally apply for food stamps” or “legally get [food stamps] for free.” The defendants sold the guide for either a one-time fee of $99, or as part of “Financial Solution Package” that cost consumers a monthly recurring fee of up to $139.

According to the FTC, under longstanding government restrictions, only low-income households can qualify for the federal food stamp program. In the guide, however, the defendants repeatedly tell consumers to provide the government with misleading information in order to inflate their chances of being deemed eligible – advising them, for example, to have high-income residents briefly move out of their household. The FTC charged that following this advice could leave consumers open to civil or criminal charges by the government.

In addition, the FTC charged that the defendants marketed the food stamp application guide throughout the United States, without telling consumers that the guide contained information about the application process in only one state – Florida.

The FTC also alleged that the defendants charged up-front fees for credit repair services, failed to make required disclosures about their debt relief services, and failed to fully report Sky’s business activities, all in violation of the court order.

The FTC says that following the original action against Sky he was to provide compliance reports but failed to disclose information about his new ventures, including the Allrepco site.

Pursuant to the Stipulated Settlement Order, Sky submitted two compliance reports to the FTC; however, these reports omit crucial facts about his new business practices, most notably his sale of food stamp services. In his 180-day compliance report submitted in August 2010, Sky did not disclose his new food stamps venture, did not reveal the existence of Allrepco, LLC, and did not list any of his websites. Rather, he merely acknowledged his continued involvement with CRB and DNA and mentioned a new fictitious business named Florida Consumer Assistance.1 (Burton Decl. Att. BB). Moreover, in his annual compliance report, submitted in January 2011, Sky continued to conceal his food stamps venture and related websites. (Burton Decl. Att. CC). Sky did mention Allrepco, LLC for the first time, but he again did not describe its business.

And even though the FTC spotted the credit repair and debt relief services offered on, Sky continues to offer them.

On,10 Sky and his companies bundle his food stamp guide with other
purported products and services in a “Financial Solution Package” for a monthly recurring
charge of between $99 and $139.

Specifically, Sky offers nine products and services in this package: credit repair services; debt relief services; credit and debt games; the food stamp guide; found money searches; secretarial services; advice on foreclosures; Section 8 Housing advice; and college financial aid advice. Id. Consumers may purchase the package online merely by providing contact and payment information. As discussed below, Sky takes immediate payment before performing any credit repair services or fully making required debt relief disclosures.

Of the nine products and services, Sky features his credit repair and debt relief services most prominently. Indeed, his top two marketing pitches on the website homepage highlight these services with large button-style hyperlinks labeled “Need Your Credit Report Improved?” and “Need Your Debt Reduced To A Low Amount?” Sky elaborates upon his credit and debt services with express promises such as:

  • We negotiate your debt at a 60% savings or greater – off the alleged amount owed.
  • We will negotiate your unsecured debt for 40 cents on the dollar or less, guaranteed.
  • We prepare dispute letters to all 3 Major Credit Bureaus (and Subsidiary Bureaus) every 30-45 days to legally dispute negative trade lines . . .
  • We provide credit education and legal tricks to boost your credit score.
  • We provide constant, in house credit monitoring, to keep your credit in perfect
    shape for future credit purchases.

Incredibly, despite the monthly membership charges of up to $139, Sky’s website claims that his much-lauded credit and debt services, but not the other seven products in the package, are actually “free.” Belying his “free” assertion, however, Sky pitches several detailed “reasons” to enroll in his Financial Solution Package. Id. His top three reasons address only his credit and debt services, not any of the other services bundled in the program. – Source

And you would think the matter would wrap up quickly and there is no way someone would continue to sell debt relief services in the face of such clear FTC action and guidance. Especially to sell those services under the brazen claim, “We are proud to state that we are federally exempt from the CROA (Credit Repair Organization Act) and the TSR Federal Debt Settlement Rule to serve consumers in all 50 states.”

But on October 17, 2011, the court granted Kurt Streyffeler’s, Esq. request to withdraw as counsel for Credit Restoration Brokers and Debt Negotiation Associates. The court did say that Sam Sky could represent himself in this ongoing matter with the FTC.

In his representation Sky has made a number of filings, including:

I don’t know about you but the continued offering of any debt relief services seems like a less than optimal game plan by Sky.


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Damon Day - Pro Debt Coach

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