Daniel Rosen, founder of Credit Repair Cloud, was sued by the CFPB in 2021 for telemarketing violations and settled in 2024. The Telemarketing Sales Rule prohibits phone sales of credit repair services when charging advance fees. Rosen recommends switching to online signups, chat, email, and in-person meetings instead.
Questions this video answers
2021
2024
Any fees charged before six months after the completion of services and proof of results.
Any phone calls or video conferencing with consumers (including consultations or credit audits) that lead to the sale, hiring others to call, ads that invite calls, or communications encouraging recipients to call.
Switch to self-service online signups and payments (no phone/video sales) and remove phone numbers and calls-to-action that drive calls.
Chapters
I was sued by the cfpb and today I'm going to reveal everything you need to know about the lawsuit. Big changes for the credit repair industry and the crucial steps you must take to keep your credit repair business compliant and safe. And I'm also going to give you a TSR compliance checklist to protect your business, so you better stick around. Now, before I get into this, understand that I and Credit Repair Cloud are not attorneys and we are not providing legal advice. Please don't take anything I'm saying here as legal advice and consult an attorney if you have questions. Here's what happened. Three years ago in 2021, the CFPB, which is the Consumer Financial Protection Bureau, they sued me and Credit Repair Cloud over something called the tsr, which stands for the Telemarketing Sales Rule. We don't telemarket, we don't have any salespeople and our software doesn't dial. But they allege that we broke the TSR and CFPA rules by providing CRC tools and services to users who violated the law. Getting sued was really scary. It's been the most stressful time of my Life. But now, three years later, in 2024, I can now share that we finally have closure and and we have agreed to a settlement with the cfpb. I haven't been allowed to talk about any of this publicly for this whole time. So this means that I finally get to share some really important info and updates with you. And more importantly, I want to help you and to avoid potential issues in your business. So let's talk about the tsr. The Telemarketing Sales Rule was created to protect consumers with clear guidelines and restrictions for telemarketing. Under the tsr, it's illegal to telemarket credit repair services and then charge advanced fees. What does that mean? Well, let me break down that legalese for you. Telemarketing means any phone calls or video conferencing with any consumers before the sale of services. Advance fees are any fees charged before six months after the completion of services and proof of results. So if you telemarket and then charge advance fees, you may be running an illegal business under the tsr. But if you do not telemarket, you may be able to charge typical fees for credit repair services as permitted by law. I want to be really clear here. The TSR prohibits any kind of call or encouragement to call, including initiating telephone calls or hiring others to call potential customers, running ads that feature a number to call for more information, emailing or mailing a letter that encourages recipients to call or learn more about your credit repair service, or hiring someone to engage in telemarketing for you. It even prohibits having any kind of consultation or credit audit made over a call or video conference that leads to the sale of credit repair. I will note that if you wait until six months after the credit repair work is done and you can prove the that the score did increase, you are allowed to speak to leads on the phone. The trouble is, that's not feasible for most businesses and it's very difficult to prove the increase since you can't easily pull a consumer's score six months after your work is finished. So the best solution is to not telemarket and I'm going to give you some recommendations on how to do that later in this video. Here's how this relates to us. Recently, the CFPB has stepped up their enforcement of the TSR across the entire credit repair industry. You may have seen headlines with other big names being sued as well. So here's what this means. If you are doing credit repair, you must be TSR compliant. The TSR applies industry wide to every single credit repair organization no matter how many clients you have, no matter what software you use. The CFPB also now requires credit repair business providers like Credit Repair Cloud to enforce TSR compliance among its customers. If we find that the user is breaking the tsr, the CFPB requires us to permanently revoke that user's access to all of our services. I'm really proud that Credit Repair Cloud will be the first of its kind to be fully TSR compliant. These are big changes, but as industry leaders in credit repair software, I know just how important they are and I want to help you every step of the way. Here's what you need to know. The big thing is that you can't sell or talk to leads or sell your services over the phone or on zoom calls. Remove all phone numbers. Do not have a phone number on your website or in any of your marketing. Don't have any calls to action on your site or ads or emails that drive a potential customer to a phone call or video conference. Don't do phone sales. Don't make any sales calls or speak to any consumer on a call or video conference until they are a paying client with a signed agreement. And no, paying for a credit audit does not count as becoming a paid client. A credit audit leads to the sale of credit repair services, so that cannot happen over a call. So how do you run a business this way? You instead switch to self service checkout, which I'm going to explain later in this video. These changes are crucial to ensure compliance and avoid penalties. I know this is a lot of information, so I've created a helpful checklist for you to use. It clearly shows what you can and can't do to stay TSR compliant and you can download the checklist for free@creditrepaircloud.com TSR and I'm also going to put the link down there in the show notes. We'll also be providing more and more training materials, resources and answering questions. And I wasn't supposed to say anything yet, but we're also building really cool tools and features into Credit Repair Cloud to help you to stay compliant with while still growing your business. They don't know I was going to say that, but I just couldn't keep quiet any longer. Remember, my team and I are here to help, but ultimately being compliant is your responsibility. You need to take this stuff seriously. The CFPB is demanding compliance and they will go after smaller and smaller CROs and credit repair software providers and anyone and everyone associated with the credit repair industry. So what can you do? Well, here's where things get exciting because there are ways to grow your business while remaining compliant and as the industry leader, Credit Repair Cloud is here to help you. Anything that would lead to a phone call you need to get rid of it. But here are two things you definitely should do. Automate your sales process with self service signup. This means that leads can sign up and pay for your credit repair services right on your site without speaking to anyone on the phone or on video conference. Build up your self service website. Have a web form that signs people up as clients rather than giving them a phone number to call. You can even use the sign up only template from Credit Repair Cloud. It's really easy to just copy the code and paste it into your website. And by using that form, which works with CRC billing, you can have self service sign up on your website today and use other methods to connect with prospects before receiving payment and a signed contract. This gives you a great opportunity to sell in other ways. Focus your efforts on your social media content and direct messaging, email chatbots, video on your site and live text chat. You can even meet prospects in person to carry out consultations and credit audits. Make that as great as you can offer to answer questions and provide value even if it's free. Show your potential clients that that you know what you're talking about and you can help them with their credit issues if you want more tips and resources about how to automate your sales process and how to connect with leads without phone calls, check out the tips I provide in the free TSR Compliance Checklist. The link is down there in the show description. You'll also want to make sure you're using a TSR compliant business model. Here's an example of one that is not compliant. A lead that receives a free consultation over the phone or video conference who then signs up for your services. That's a no no. Instead, here's a TSR compliant model. A lead goes to your website and completes a self service sign up online. They pick a plan, they provide payment details and sign an agreement. It's okay to offer chat or email support during that process. You can. You can even have a video on the page guiding them, but you cannot pick up the phone or do zoom. However, once the lead submits their payment information online and officially becomes your client, then you can talk with them on the phone as much as you like. You can even have an onboarding call to kick off your services. Working this way you won't be looking over your shoulder worrying if you're going to get sued or shut down by the cfpb. And the good news is you don't have to do phone sales. Many successful companies have self service signups. It just takes a mind shift. Here's my final point. It's really important that you adhere to the TSR to ensure compliance. Non compliance may result in not only legal action or fines but also in credit repair, cloud revoking access to our software and services. These are really big changes for everyone in the industry. So take a minute to make sure that you really understand them and then take action to ensure that you're compliant. And then focus on all the other awesome and time saving ways that you can grow your business and change more lives. So again, to make this as easy as possible for you, download the free checklist that I've created to easily keep track of do's and don'ts. Get your copy right now@creditrepaircloud.com TV TSR and the link is also down there in the show notes. So take care Credit Hero and keep changing lives.
