TSR Could End Your Credit Repair Business Overnight, Here’s What You Can Do

Just because the CFPB is in hot water right now and they may be shut down or temporarily paused. They're not the only governing agency out there that can enforce these laws. It is in law right now, so we must follow that. It's still a law in place until something changes.

Three years ago, I was sued by the cfpb and it was over something called the tsr, which is short for Telemarketing Sales Rule. And it was the most stressful time of my life. And the crazy part, we don't telemarket, we don't have salespeople, and our software doesn't even dial. But they alleged that we broke the TSR and CFPA rules simply because our software was being used by some folks who violated the law. It was really scary. I thought everything that I built, Credit Repair Cloud, our movement and our community, I thought that everything was about to be destroyed. But after a three year battle, we finally reached a settlement with the cfpb. And I can finally talk about it and help you to avoid the same nightmare. Some people think that because the CFPB is now in trouble that the TSR doesn't apply anymore. But that is dead wrong. If you're in credit repair, the TSR still applies to you. It always has, it always will. The CFPB still exists, and enforcement is also handled by the FTC and state regulators, which means if you're not compliant, your business is at risk. But don't worry, because today I'm bringing you something very, very important. It is exclusive footage from our recent Mastermind event where we talk with top credit repair pros about the latest on compliance and the risks that can shut down a business fast. So in a minute, you'll hear from Troy Hitt. He is our head of customer success at Credit Repair Cloud, and he's also a former credit repair business owner who knows this industry inside and out. Troy also has a Millionaires Club award, so you know that he knows what he's talking about. Now, before I get further into this, understand that Troy, myself and Credit Repair Cloud, we are not attorneys and we are not providing legal advice. So please don't take anything that I'm saying here as legal advice and consult an attorney if you have any questions. Okay, now that that's out of the way, if you want to protect your business, Troy is the guy to listen to.

All right, well, awesome. It is absolute pleasure to be here. I couldn't wait to talk to each and every one of you about this industry shift. But before I dive into that just a personal thanks to Daniel for fighting for us, fighting the good fight for everyone in this room and the industry as a whole. What Daniel went through changed the industry forever. If it weren't for him fighting, we wouldn't have these guidelines because they were. Oh, they were hard to get. It's like, give us some clarity. So now we have it. So thank you, Daniel, for that and I'm going to share a little bit of that today. But first, I just want to share a little bit of my story and how I ended up here. So I was in your space, in your shoes for 15 years, as Daniel mentioned, and now it brings me here, full circle, to help thousands of credit repair organizations to succeed and continue to succeed in this new environment. So this is me in Air Force. This is basically a story about the evolution of my beard. As you can see, I did not have one back in those days. That's babyface Air Force Troy right there. I was a bit of fly by the seat of my pants person. Always have been, no pun intended with the Air Force. But my wife and my daughters are certainly a lot different. They're big planners. But that dynamic has definitely kept me successful throughout my journey. I served nine years in the Air Force, but not, not in the way you expected. Yes, I was trained in combat readiness, but I was also trained in sales and marketing and public speaking. The Air Force hand picked me to be a recruiter and Air Force recruiter. So suddenly I was the face of the air force for 5,000 square miles in a rural place in Texas. I'm from Houston, Texas, where I'm based right now. But after traveling thousands and thousands of miles and being successful, I realized that there was, it was not much different than building a business. I didn't know this was what was happening to me, but I was being transformed into an entrepreneur. So things were very similar, like networking with key community figures. I, you know, I spoke to judges, mayors, police officers, firemen, teachers, counselors, everyone who had an influence on potential recruits. Those are the ones that I spoke to. I had to stay top of mind through marketing. We did mail outs, phone calls, email lists, you name it. We did a good old fashioned way be school visits, office visits, home visits, we were all over the place. But most importantly, I had to deliver value before asking for a commitment. And I think that that's where you'll find some relevance in what TSR is asking us to do now. That I had to do back then. But all this effort worked. I was one of the top recruiters in the nation. I was only second to a guy who was sitting right outside of an Air force base saying, hey, see that? Want that sign here? So it all worked, but I wasn't done yet. That gave me the entrepreneur bug. And so after I got out of the Air force, I tried to get in the recruiting business. So I thought, hey, I was a recruiter, let me go into healthcare recruiting did really well, but you know, you just got a bigger corner office. It wasn't really for me. I started moving business with big old semi trucks, even started a fencing company with one of my golfing buddies. And nothing really clicked. But during this time my wife was, she was a loan processor for a couple mortgage companies. And one of the things she did realize, everything was done by paper those days. Any of you who's been around long enough, there were big files just full of documents and always in this big old folder was a credit report. All this processing she was doing, they weren't closing loans because they had bad credit. So she began repairing a couple of the clients credit to test it out. And then I'm like, you know, what are you doing? She's like, I'm doing this. I said, well, maybe there's an opportunity here to turn this into a business. And so we wanted to take this to the next level. That's how our first credit repair business was launched in 2002. It was called financing available. Because anybody with bad credit cringes when they see those words financing available because they know they're not going to get approved. We later rebranded to improve my credit usa but it started out as financing available. We started out dialing for dollars back to back in 150 square foot office surrounded by filing cabinets. But I was in my mind, I was thinking like, how can we take this to another level? So I remember some of those marketing efforts I had as an Air Force recruiter, putting thousands of miles and mail outs and emails and I'm like, we need some exposure. So I found this guy around town, he was renting neon signs and I think it might have been 150 bucks a month or something. A couple hundred bucks a month. It wasn't much, but he would put the sign out in front of your office and we had a real busy street and people would have enough time to write down our phone number and our phones began to ring and the business began to grow and it kept growing. And soon after that, filing cabinets were not enough. So we needed a software that we used to do this all on Word documents and Excels and It was crazy and big old filing cabinets. But we knew there needed to be a software. So I went to the first ever credit repair bootcamp. I believe it was in Tampa, Florida if I remember, and swiped my credit card for software I knew nothing about. And then one day I realized what software can do, they can break. And it, it did. We had over 1500 clients in our system at that time. And we logged in one day and it was just blank. And there was no clients in there. And so as much as we were excited about the success, this was a big giant failure. And so we needed a change. And that's when we found crc. I eventually started talking to Credit Repair Cloud. I already kind of knew who they were because we actually used Daniel's first product, the credit aid software. They white labeled it. We used to use this as a downsell for our business for clients who didn't pay for our. Our services were like, well hey, you can do it yourself with this cool little download. So you had a little white label product. And there's the actual image. I went and found that from years ago. Daniel. That's the actual image we used to have on our website. So I already knew of them. So Daniel and Keenan answered all my questions. I grilled them. Daniel can tell you personally he was always concerned when he saw calls coming in from me because we were asking a lot. We were asking to move our whole business over to a new platform. I mean the other CEO from that software company was begging to have a stay. But the transition wasn't easy. But we did it. They answered all our questions and we moved over to CRC. And we never looked back from that point. By 2014 and 15, we eclipsed the million dollar revenue mark. We were in the millionaires club before there was even a millionaires club. So if you look at the date stamp on this, this is back when CRC first pretty much launched. It was in their very early stages. So it was a big ask to move all 1788 clients over to CRC. But it got done. Having the success as a CRO led to me having success. I got. People started reaching out to me to come consult for them. So again I found myself now traveling the country again, putting in miles, going out and helping other CROs scale their business. But what I really found was my true passion and that was helping entrepreneurs succeed. After having all that success, we did sell our CRO and started moving into other new ventures. I found like I was started to get fascinated with the digital marketing world and the software space. And I realized it really helped helping businesses grow, but not just my own. So I joined, I joined a fast growing marketing software. Many of you may have heard it, it's called Click Funnels. Anyone's heard Russell Brunson's name and Sales Funnels. I joined on over at Click Funnels as the head of customer success and business development. It was a big shift for me all of a sudden and I began helping other entrepreneurs build their company while working inside of this company. So there was a huge dynamic. So we approached this with the same entrepreneurial mindset, but we started building a team of intrapreneurs. So I started recruiting like minded professionals who had the same mindset as entrepreneurs but also were successful in the established company. So it was really cool dynamic. We got to work with copywriters, funnel builders, gym owners, other CROs. At the time it was funny how I ran into other CROs when I was in this digital marketing space. And so we traveled across the country, we went to marketing events, we went all over the country sharing these skills. And those are some of the times we crossed paths with Daniel and Keenan. So I found my passion of helping software companies connect with their customers and create a real impact. So that dynamic of an entrepreneur working in a company became intrapreneurs. So this experience was invaluable. So it led me to my next big step. So after five years working in that space, I did get a chance to reconnect with Daniel at a major industry event. We found ourselves talking, chatting it up again. And they were curious as to what I was doing in my current role because again, I was working for a software company at that time and I started telling what I wanted to do. And I'll never forget what Daniel said next. He said, we need that, can you help? And I said, well, of course I can help. So that, that, that landed me the first opportunity, first project with CRC to help build their onboarding process. It was a huge success. And so it was so much so that they were like, hey, look, we want you not to help our team. We want you to be on the team. And it was pretty clear they weren't going to take no for an answer. So I joined CRC and I've been out here for nearly three years and here it is, full circle. It's just amazing how the same company that I was with that helped helped me build the success in the CRO, I am now back here working. Oh, and in case you're wondering, I did final get that plaque. It only took 11 years later to get it, but I did get that. So it, it's been a, it's been a pleasure to be around this for three years and it's exciting to go into the next venture. So wanted to share the little bit of that journey, how I got here, because I wanted you to be able to relate that the industry never stops changing. If it's from going from a software, going from a procedures, tactics, regulations, those things aren't going to go away. Change is not going to go away. What got you here might not get you there. And that's what we're going to talk about today. So now we're at another turning point where the CFPB is now cracking down specifically on TSR and forced us to shift the way we operate. Many of you are like me and in their business they built a, a business based on free consultations and sales calls. But that's not an option anymore. So what do we do? I'm here to help you do that. I'm here to help navigate some of this and hope to have some more conversations with y' all in the future. So what is TSR and how is impact you? This is a lot of legal jargon on here, but I'm going to go through this. But one of the things I want to call out here, we can all remember what our most favorite lead magnet was at the time. Free consultation, free credit analysis, free free credit report. These are all the big the buzzwords that we were sending out here to generate leads. Our big lie we were telling ourselves when we heard about TSR originally was like, oh, it's okay to call everyone if as long as we stay within our state. Well, that's not an option anymore either. So all of these lead magnets that we used to have to bring in business are no longer an option. We've got to shift the way that we do business the way that we onboard potential clients and dialing for dollars of the days of your phone blowing up and calling and talking to leads are over. What is telemarketing? What is TSR as it pertains to credit repair businesses? It prohibits using telemarketing to solicit clients and charging advance fees. And charging advance fees. I'll talk a little bit more about that. Telemarketing includes phone calls, video conferencing with potential clients before the sale of a service. So essentially before they're a client, this means that any outreach to prospect over phone via video platform like Zoom or Google Meet or any of those is prohibited before they're A client. Advanced fees. Advanced fees. This is a real big kicker. A lot of you are familiar with how you currently bill with your system. But if you violate tsr, advance fees are defined by any fees charged before six months have passed after completion of service. And proof of results. And proof of results. So this means even if you've completed the service completely, you can't charge after six months. And you can't charge unless you provide results after six months. There's no business that can operate that way. Many of you, I'm sure, have never operated that way. And, and it makes it more difficult. And that's essentially why this ruling came down, is to make it more difficult, but not impossible. The simple is if you don't telemarket, it doesn't apply to you. You can do business as usual, right? Many of you have models that will work with. As long as you don't tell the market. As long as you call potential clients over the phone, right. Let them sign up first. If you don't tell the market, you're okay. Just don't tell the market. So I just want to make it simple that if you don't tell the market, you're good, okay? All the other same operations apply like you used to how you charge your fees based on your local and government laws. All right, now that we've got the legal stuff out of the way, don't worry. We created a cool little checklist. I'll take a moment here. Everyone can scan this on a QR code. We've created a checklist that gives you a step by step on what to look for. Not only your website, but in your business as a whole. Some do's and don'ts. What are some of the best practices? We're going to dig into a little bit of the best practices. The good news is that many of our most successful CROs are kind of already doing this. As we were started talking to folks about TSR and what's going on, a lot of them already had some of these things already in place. So adjusting your sales and onboarding while ensuring yourself to be compliant is the utmost importance. And you hear self service signup flow talked about a lot. It is the one of the best ways to remain compliant throughout your business. Embedded checkout forms. I know many of you are here have embedded checkout forms. You're good there. You can use our CRC billing now for self service sign up flow. And as Keenan mentioned earlier, we've have other gateways that are coming on board currently. NMI is is a Gateway we can, we can implement right now. So if you have an NMI gateway, make sure I'm going to give you my scheduling link here at the end. So anyone could have a conversation with me about implementing that. To bring it into CRC and direct all your called actions to a self service signup button. This is basically again instead of call now there's so many of your websites say call now or they did before. It's like call now and they click that and and you know it launches a call. Don't do that. Sign up now. Get started. Now this is a button, it's a call to action to get signed up instead of a phone number. And then of course you can provide secure agreements to sign up online. Most of you have agreements already. CRC applies that. So again you'll see some similarities. We just gotta remove that telephone conversation in the front. Here's an example of removing that telephone in the front. Notice that all your ads, every however you drive your traffic, whether it's email campaigns, you know, paid for ads, whatever it is, how you get your traffic, they all will come into an opt in form. This is the first step in the signup process. You basically get their, their information name and email is usually at. It's okay to collect their phone number too. It's not against the rules to collect their phone number, it's just against the rules to call them. So then after you collect their information you can reach out to them via chatbot. You can reach out to a messenger or Facebook messenger, WhatsApp. There's lots of ways to do that to move them through the process. Some successful CROs here just have an email campaign. We'll talk a little bit about that. But if you can see the first steps are getting them to that agreement and once they assign that collect their payment, get them to the agreement and the thank you page, then you can engage in phone zoom or meet any way you want to. That's it. Notice I didn't say collecting any money because you don't want to collect money early on until you have a chance to talk to folks. You collect payment details, you get an agreement. I see a lot of folks talking about, well it's hard for charging them before, before we get a talk. No one said about charging them before they talk to you. So I don't encourage, we don't encourage that model. You might want to, but we don't encourage that model. We got to give it some time for them to absorb what you're doing. So typically one to three days after they sign up is a good opportunity to give you some space to talk to your existing clients. Here's just one example. I think this CRO is in the room. They may or may not be. This is one example of a self service signup flow that was pretty slick on their website. Enroll now instead of call now. Right? Enroll now and it takes them to. They select their plan, they put in their payment information that leads them to a phone call. Pretty easy peasy, right? It doesn't cost any money to get started. It's $0 to get started. You'll see some of that in our self service signup flow. So speaking of automated onboarding, these are just some simple tactics that you can use to automate instead of using phone based consultations. Enable built in lead capture. We talked about that design just a moment ago. Let me go back two slides. Enable automated lead capture. All right. On your onboarding forms chatbots, I've got some examples of that Live chat features. Those are all still good chatbots. Live chat features. You can talk to people via chat. That's all perfectly fine, just can't do it over the phone. So make sure that you, you adjust your websites to handle those chats to handle those inquiries via chat and not a phone period. Dot here's an example. What you currently have in crc. If you're on our billing platform, we have a self service signup link that basically models everything I showed you today. So if you're on our billing platform right now, it will take them completely through the signup process. It will capture them as a lead, it will ask them to select a plan, it collects their payment information, signs the agreement and then takes them to secure client access portal to upload their documents and also sign up for credit Hero score. All that happens in the self service signup flow. At first everyone was like hell, I have to take my phone number off your website. Well, it's a, it's a good idea to take the phone number off your website and we'll talk about that in a minute. But replace what would normally be a phone call with digital communications prerecorded sales call. Sales videos are a great one. If someone opts in, you send them pre recorded sales video. Alicia Alt is in this room right now. I know she has. She sends potential clients sales videos, explains the signup process to them so they know what they're getting into before they even sign up. I encourage that. Explainer videos are a great, great way, a great next step to get people into your self service signup flow. We talked about social media Messaging, Facebook, Instagram, WhatsApp. Implement those on your site. And email is not dead. Email is not dead. Email sequences work. You want your email sequences to push everybody into that self service signup flow. Even if someone calls you on the phone, you're going to want to let them know that you cannot talk about their credit situation. It's designed to protect me and it's designed to protect you because we're going to be looking at sensitive information. I'm going to email you a link to get signed up. As soon as you go through that process to get signed up, we will schedule an onboarding call with you as a client. This is designed to protect both of us. Legally. I can't talk to you about your credit situation over the phone. Boom. You're gonna send everybody over to your self sign up. That's how you handle inbound calls. Just a little snippet right there. And of course, anybody who has brick and mortar. I used to have brick and mortar. I know there's not a lot of those left out there. In person consultations are absolutely okay. You can still do everything in person. But square footage is expensive. So that's all I can say about that. All right, and then here's an example of a couple things that are on used for digital communication. On the left here you have WhatsApp. You've got email contact someone and said contact us. Right here is email contact. You've also got a live chat. So there's three good examples of what it looks like by replacing those on there. So if you have multiple services though, and we see this a lot, if you have multiple services, you're still going to want to drive them to a live chat. But don't use like WhatsApp, don't use the voice version. Facebook, don't use the voice or video because CFPB is going to look at that the same way. So make sure if your phone number is listed, it's got has a disclaimer that talks about existing clients. Right. There's no better example than this one right here. This is Lex Tin Law firm. If you have a phone number on your website, which we encourage you to remove it because Lexington Law doesn't have it, let people know why you can't talk to them on the phone. Lex Tin Law says them straight up right here that, that this is unfair regulation, but they can't talk to you. It literally says it on their site. They think it's unfair. They challenge it just like we did. And they were unsuccessful Right. So the rule still stands. So it says some many amateur credit repair companies out there choose to break the law, but we don't. If there is one big fish to model, it's going to be Lex Tin Law. They even talk about it in their second version of saving telephones. Telephones for who actually sign up is the best use of your time as a CRO and I can't disagree with that. I think it's great advice. So that's how they're able to keep their cost down because they're not just talking with tire kickers. And we all know who those are. They want to tell you their whole story. All of a sudden you turn into a bartender, right? And they're telling you a whole story and you have yet to even look at their credit report yet. So Lexington Law takes their process right into chat. So you can't sign up anywhere else but the chat. So if there was one to model, that's the one I would recommend modeling. We talked about removing the phone number but we also didn't talk about your other marketing materials like your. We did talk about your website but like social media marketing materials, flyers, business cards, don't use call to actions like call us for free consultation. Book a call, learn more. Ensure that all your marketing directs everybody towards a self service sign up flow that includes your social ads and your social media because you don't want to be forced to handle those calls that come in. You want your phone to ring with existing clients. I think it's a better experience altogether. Um, and if they have questions about potentially sign up as a client, move everything to a chat or some other platform that's not a video call or a phone call. There are no loopholes. Bottom line, there are no loopholes. Don't speak to prospects leads until after they become a client period. Dot com. Um, and then the last point I want to make again, Lex 10 law. Here's it. I wanted to use their current site because it's changed a lot since we've looked at them. But if you want to start signing up, it takes you to this page and this page only. They have their whole self service signup flow. You can't go anywhere else when you won't go to sign up right here. So when you click in the chat, get started, it takes you this page. They're going to take you through a self service signup flow. So if there's a model that you should go after, that would be the one. I highly encourage that. All right, last step is just stay Informed. Things are ever changing across the industry. Conduct regular audits with your team. Conduct regular audits on your website. It's important that if you have contractors, many of you have VAs that help run and process your business, that they are well informed about tsr. All your employees are well informed. And a big disclaimer here. Just because the CFPB is in hot water right now and they may be shut down or temporarily paused, they're not the only governing agency out there that can enforce these laws. It is in law right now. So we must follow that. It doesn't matter who's in if the, if the, the governing body is getting shut down. It's still a law in place until something changes. And we feel like that is a potential any government agency just pick up the, pick up the where the CFPB left off. So if it's cfpb, FTC doesn't matter who it is, it is written into law right now and this is the way we must navigate the industry. And if there's one thing you learned today that the industry is ever changing, it's time to evolve. We all remember what happened to blockbuster. So don't be a blockbuster. Don't get left behind. You just want to evolve, make the changes that are necessary. We all have to do it if you want to navigate in in this industry now. It's just the way it is.

Here's my final point. At the end of the day, compliance isn't optional. It's the only way to move forward. The TSR is being enforced and the rules have not changed. Even if the CFPB is in trouble, state regulators and the FTC are stepping up. So now is the time to make sure that your business is bulletproof. And that's why we're building so many new tools in CRC like self service signups and a whole lot more to help you to be compliant with the law. Don't wait until it's too late. Adjust your process, switch to self service signups and protect everything that you've worked so hard to build. And I'll end by saying if you want to learn how to grow your business without getting sued, tune in here. And if you'd like to improve your credit score and discover how to earn extra income repairing credit for others, check out my brand new Start Repairing Credit Challenge. So sign up right now@startrepairingcredit.com and keep changing lives.