16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments #543670-00324

Submission Number:
543670-00324
Commenter:
Thomas Papp
Organization:
Debt Remedy Solutions, LLC
State:
FL
Initiative Name:
16 CFR Part 310 Telemarketing Sales Rule- Debt Relief Amendments
Ms. Brown: Attached find my responses to the questions contained in your letter dated December 18, 2009, which you sent in response to my public comment filed in connection to FTC’s rulemaking proceeding regarding the Telemarketing Sales Rule - Debt Relief Amendments. Please note that we were unable to provide answers to all of your questions due to the manner in which we collect and track data. We do not wish for you to interpret the absence of a response to a particular question as being due to any unwillingness to provide the requested information. I trust that this response is adequate and will assist you in your rulemaking proceeding regarding the Telemarketing Sales Rule - Debt Relief Amendments. 1. (a) 45 months (b) No 2. (a) Not available (b) Not available (c) $44.2MM (balance as of time of settlement) / $36.9MM (original balance as of date of enrollment) (d) Not available 3. (a) 44% (average of monthly results Jan-07 through Dec-09) (b) 53% (average of monthly results Jan-07 through Dec-09) 4. 20% 5. (a) 15% flat fee based upon enrolled balance (b) No (c) We start collecting the fee within 30 days of the customer signing the contract. Service fees are usually divided over the course of 15 months. (d) No (e) 15%. Amount varies by customer given variance in amount of enrolled debt (f) Amount varies given that it is entirely dependent upon what amount customer has paid at time of cancellation and amount of refund (if applicable) 6. (a) Not available (b) Not available 7. (a) Not available (b) Not available (c) Not available