16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments #543670-00006

Submission Number:
543670-00006
Commenter:
Tim Harris
Organization:
CDS
State:
CA
Initiative Name:
16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments
I am a partner at a well established Debt Settlement company. We have successfully been helping consumers with credit card debt since 2006. As a company, we believe strongly in full disclosure, and making decisions based on whats in our clients best interest first and foremost. We spend a great deal of money on servicing each client (they get a dedicated Debt Specialist assigned to them, and stretch our service fees over (at least) half the program length. The vast majority of our expenses are incurred within the first 12 months of the program. A sizable chunk of those expenses go toward attaining new clients, but also a considerable amount goes toward GOOD service. Those expenses include paying the representative that explains all the options to client, the verification representative that reviews the program a final time with the client to make sure they fully understand how it works (etc.), the processors that handle the paperwork and help establish the account, the assigned negotiator that reviews the accounts and formulates a game plan, and the settlement coaches that do a 30-60 minute "Welcome Call", and bi-weekly coaching calls there after. Even stretching our service fees over 50+% of the program is financially straining. If we had to change how and when we collect service fees as proposed, we would not be able to stay in business. Nor do I believe it possible to provide the quality service required as proposed. We run a good, clean business, and feel good with the knowledge that we are helping people that are experiencing financial hardship- and our clients have provide testimonials on a weekly basis with their gratitude.