|Received:||10/22/2009 5:44:17 PM|
|Commenter:||William R. Mitchell|
|Organization:||Quality Survey Services|
|Agency:||Federal Trade Commission|
|Rule:||16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments|
|Attachments:||543670-00187.pdf Download Adobe Reader|
Comments:Telemarketing Sales Rule – Debt Relief Amendments, R411001 William R. Mitchell Logan Retoske, LLP Attorneys for Quality Survey Services Quality Survey Services (“QSS”) is an independent consumer research firm. QSS was retained by certain members of The Association of Settlement Companies (“TASC”) to conduct client exit interviews of consumers who (i) were enrolled in a debt settlement program, and (ii) had terminated the program before completion or had completed the program. The members of TASC provided to QSS a list of all clients who have terminated or completed the program. The list contains the name, contact information and data related to the client. QSS called each client on the list and makes three telephone calls before it ceased efforts to reach a client. QSS recorded all consented calls and archives all recorded calls. QSS interviews the client based on a questionnaire. During the call, the interviewer circles the answers and fills in the information provided by the client. QSS maintains all completed questionnaires. QSS conducted 691 interviews and the results of these client exit interviews are outlined in the TASC Exit Survey 2009, attached hereto. The primary findings of the client exit interviews are as follows: 1. Seventy-six percent (76%) of all settled accounts experienced a reduction in the amount owed on the account of greater than forty percent (40%); 2. Ninety percent (90%) of the clients enrolled in a debt settlement program remained in the program for at least thirteen (13) months and twenty-eight percent (28%) remained in the program for more than thirty-six (36) months; 3. Eighty-eight percent (88%) of the clients were satisfied or very satisfied with the experience in the debt settlement program; 4. Eighty-two percent (82%) of the clients interviewed rated the experience as good or excellent; and 5. Ninety percent (90%) of the clients interviewed stated that they were glad they chose debt settlement as a method of getting out of debt. QSS was retained by Nationwide Support Services, Inc. (“NWS”), a TASC member, to conduct exist interviews of consumers who were enrolled in a debt settlement program administered by NWS. The NWS Surveys, attached hereto, quantified the results of the participation in the program and the consumer’s satisfaction with the program. QSS conducted a survey of 329 consumers enrolled in a NWS supported program following the completion of the program. The notable findings are: • 91% of consumers remained in the program for more than one year; • 83% of consumers settled their credit card accounts at a discount of at 40% or more of the outstanding balance; • 78% of consumers rated their experience in the program as good or excellent; and • 91% of consumers were “glad’ they had chosen the debt settlement option. QSS also conducted a survey of 129 consumers enrolled in a NWS supported program who had cancelled after completing 50% of the program. The survey states that the two primary reasons for cancellation were that the consumer could no longer afford the program (33%) or they decided to settle the accounts on their own (32%). Only 9% of the consumers stated that they cancelled due to dissatisfaction with the program. QSS conducted a survey of 105 consumers enrolled in a NWS supported program eight months following completion. This survey was designed to track their use of credit following participation in the program, and found: • Only 62% of those surveyed still use credits cards; • 78% now have a savings or investment account; and • Only 38% used a credit card for a major purchase. These results highlight the effectiveness of NWS debt settlement program’s financial literacy components. QSS encourages the FTC to review the recorded calls in order to not just verify the data reflected in the surveys, but to hear the clients recite the experience they had while enrolled in the program.