Tying It All together: What to do first?
What to Charge?
Because of the TSR (Telemarketing Sales Rule) you do not need to obtain a merchant account anymore. We recommend Credzu.com to handle all of your billing. What are other benefits? It removes monthly invoices, trying to get a credit system to handle monthly renewals or withdrawals. You also can focus or target items your clients want to remove. This way you may not have to spend a lot of time with analysis. In addition, when they see an item removed and a score boost, they are very happy with the results and willing to pay. But most of all, it can protect you from federal or state violations. Another way to earn additional revenue s to freeze your client information for them for a fee. Freezing personal information can be a viable credit repair tool to slow down verification. Credit bureaus usually verify information using id analytics. Freezing with multiple sources challenge all name variations can be tedious and time-consuming. You can charge a separate fee for this service FIRST before challenging anything with your client. It could take up to two hours for each client with multiple name variations. You can charge them $75 to 200 or charge $250 and include the analysis to their credit report and freezing personal information
The Interview Process (Building a Case)
NOTE: Make sure that your client is a good candidate for Credit Repair Services. For example, if they are not financially able to pay all of their bills on time or do not have income, they are usually not a good candidate for credit repair services. If someone comes to you stating that I need to “Start repairing my credit” the first question you should ask is if they are caught up on all bills and have been paying them on time for at least 3 to 6 months. If not, THEY ARE NOT a good candidate and should only come to you after they are financially sound to pay their bills on time.
PLEASE NOTE: Do not let that client go if they are not a good candidate for credit repair. You can assist them in other matters e.g. help them set up a budget, write debt settlement letters or reduce payment letters. Also, you can offer financial literacy education service. You are in the credit business and all of these services will help you grow and earn a living. They will become credit repair client soon enough.
IMPORTANT: If a client is seeking a mortgage as their goal, it is important to understand how any action that you take could affect them, from settling collection debts to waking up old collections accounts. Any collection account over 4 years old, according to the FCRA the collector cannot send you any letters or call you. It is considered harassment; if they do reach out to you, it is considered a fair Debt collection violation and Telephone Consumer Protection Act. However, If you contact them by mail or fax, it can start the collection procedures all over again. Nothing in the act prohibits you from speaking with them verbally. Bu when collections accounts are paid after four years they are re-aged. It is important to negotiate and make verbally settlement. There are ways to settle in conjunction with a mortgage underwriter to do this that will NOT affect the score and help your client close their mortgage loan. Reach out to a credit help desk consultant for more details.
If they are a good candidate, then you will follow the next steps.
1- Just ask the client what are their goals or is there anything they are attempting to purchase that requires the use of their credit. Ask if they have ever used a credit repair company to dispute any items before or have they personally disputed any items before. This is a very important question for the sake of consistency and to build your case. If a dispute is different than previous ones, the credit bureau will have proof that you have lied previously to them and it will hurt your case.
2-Then make sure you obtain your client’s credit reports and scores; never take their word on what is on their credit report. Say to them that you understand and that you will take a look to see how you can help. Many pulling sources may have different information but if pulling from a monitoring service, we like using MyFICO.com to pull credit reports. Here are some other sources: Several banks and credit unions, including Bank of America, Citi, and Pentagon Federal, allow some or all cardholders to view free FICO scores. Or you can sign up for Credit Scorecard from Discover for a look, even if you don’t have a Discover card. The site uses information gathered from Experian. Most other services show you your VantageScore, based on information in your TransUnion report, though Credit Karma displays scores from both Equifax and TransUnion. Also: Get credit scores for all 3 bureaus for $1 on a 14 days trial. This is an excellent way to obtain scores for all the bureaus for your credit analysis. Just make sure your client cancel prior to the 7 to 14 days trial. Go to www.freescore360.comHowever, clients can get a free copy and have to pay for their scores with annualcreditreport.com We like MyFico because they will already do the analysis for you and you won’t have to figure out why a client score is low. If seeking complete accuracy, you can get the credit report directly from the credit bureau dispute links. TRANS UNION: https://dispute.transunion.com/dp/dispute/landingPage.jspEQUIFAX: https://www.ai.equifax.com/CreditInvestigation/initLoginDisputePage.actionEXPERIAN: https://www.experian.com/consumer/cac/InvalidateSession.do?code=CDIRESELLER&rid=R045These sources will provide you the accurate contents. However, we have done amazing jobs just from using Credit Karma or other services.
3-They will provide suggestions on how to increase the score and you can follow that process. Even though clients can have the same information, they won’t understand it as you will. Especially when you will have the Credit Score Manual as your guide.
4-Again, once you get the credit report, often the services you used to pull them will tell you where the client is having problems.
5- Evaluate the report and list all negative items that are affecting their credit. You can use the Credit
6-Collect your Credit Report Analysis or Audit Fee. $99 – $250. This fee for service rendered and no advice. You will audit their credit report and provide an analysis of what you found. You can also add the freezing service. You will start the interview process with the client going line by line on the credit report asking your client about everything from names, address to accounts. You will look at your client’s current utilization rate and the balances on their credit reports. Compare this to the date they were last reported. Then compare this to what the actual balance on their credit cards is right now. Why? if those balances are not reported yet and are higher and reported later, it will change their utilization rate and could drop their scores. This is why you should determine how your client is currently using credit cards or planning to make a purchase. Advise them on how this could affect your approach.
7-ASK YOUR client about each negative item(s) within the credit report and what happened. Take their word for each item because you are building a case for them in case you discover violations where they are able to sue. This also protects you from a regulator that may try to accuse you of making up lies and sending in false disputes. NEVER lie on your dispute letter, we will cover this later.
8-But in evaluating the report FIRST VERIFY and Check to see if there are any recent past due accounts. If they are, this client is NOT a good fit for repair until they are caught up on their bills and have been current for at least 3 months. If you see all accounts are paid up to date and there is only one account past due, find out the problem and maybe this can be resolved.
9-Check to see if anything is outdated on the report meaning over 7 years or 10 years in case of bankruptcy as well as If they are outdated, it will be easy to write a dispute letter to point this out and have it removed. Check for collections and revolving accounts because these are hurting their scores the most.
10-Check for the missing dates, missing amounts, last date of payment activity or when the last time the furnisher reported to the credit bureau. This is an important credit repair tool. Sometimes one may get a client to pay an account that hasn’t reported to the credit bureau within the last 6 1/2 years and that one payment will start the 7 years clock ticking again. Make sure you notice this so that you can advise your client to wait it out until the account is outdated.
11-Again, check for personal information that is incorrect. It may be a good idea to challenge outdated and incorrect personal information first but since you will be sending a detailed letter, in the beginning, you can skip disputing this first; unless you have another strategy in mind.
12-Next, you must figure out what is affecting their credit scores from what’s keeping them from reaching that goal and again using services like MYFICO or other monitoring services to obtain their credit will assist in this area. Also, the credit report will show what is negative up front. Write down these accounts or mark them directly on the credit report that you printed out and this where you will start coming up with your strategy. (NOTE THESE ARE PRIVATE DOCUMENTS AND IF YOU ARE PRINTING YOUR CLIENT’S REPORT, MAKE SURE THEY ARE NOT AVAILABLE FOR ANYONE TO STEAL THEIR IDENTITY.
Nuances regarding The Credit Report
Mortgages and Car loan inquiries within a 30 day period are combined and considered as one. FICO does not count all of them separate. Credit inquiries will hurt so make sure that your client DO NOT apply for any credit period during the credit repair process and really they should stop until their credit issues have been resolved. Also, check for collection accounts that are under two years old and open revolving accounts.
The Dispute Process
First here is what happens when a dispute letter is sent to a credit bureau?
- Once a dispute letter is received is first scanned via OCR and converted to text.
- Once converted to text it goes to a special database to determine if another letter was previously received regarding that account or accounts or the letter was matched by previously similar letter received in their system. In a nutshell, information is matched with previous letters.
- If the letter is matched to a previously received letter or similar letter without any additional documentation, it will be processed, and a response letter is generated. It sill be a Frivolous or Suspicion response letter or in most cases, a general stall letter. This is why it is IMPORTANT to ask your client if they have disputed with the credit bureau before.
- If no letter is matched the converted text is processed down to a two-digit code and goes through eOscar Automated Credit Dispute Verification (ACDV)
- The dispute will go to the furnisher
- They have anywhere from 15 to 20 days to investigate and verify the account.
- The will send an e-response back to the credit bureau, verify, updated, remain, or delete
- If they do not respond within 20 days, the credit bureau will automatically remove the account.
How To Write Custom Dispute Letters?
- Again, circle all of the inaccurate accounts you are disputing on the actual credit report and you can send it along with your dispute letter and make reference to the circled accounts. Give detailed explanations on each account disputed, why it is inaccurate or incomplete without admitting guilt, and why it should be removed. Example: “XXZ shows that I was late twice in month two and eight, however, my records show that I paid this account on time promptly as agreed, I am being injured and according to federal law can be awarded damages. Therefore, please certify and attest that you have conducted the proper investigation and have this item remove at once. The months showing me late were actually paid on time and here is the proof.” Show them the payment activity of that month and here is why. Often a report will show a payment late but sometimes get the month wrong and you can show that that month was paid on the due date and posted by going online and getting that payment date history and all history must be wiped away. It works on occasions when you may have been late. Showing proof is amazingly powerful and gets things deleted. The more details provided the best chance for a thorough investigation.
- When you start challenging accounts. Look for closed negative accounts with zero balances, first since they may not be verifiable. Open accounts are usually easily verifiable. It is also best to start with old closed accounts.
The 10 Step Dispute Formula
FIRST PROCESS
PLEASE NOTE: Make sure you obtain credit scores and get on a credit monitoring plan. The only way to keep score with our progress in the credit repair business is to know the before and afterward outcomes. It’s why having a credit monitoring service of all 3 bureaus is so important and worth the investment while working on your client’s credit.
Focusing on deletions can cause more harm if one is not equipped with the necessary information. For example, a lot of time new consultants make the mistake of just disputing negative information. Often, many accounts are many old accounts may be dormant and may have not been updated in a while. FICO, in these cases those accounts are not weighing down your score as much as once did when it was fresh. BUT a fresh new round of disputes can wake up that account to become actively reporting again and cause an effect on your score. This is why one needs to understand the credit score factors and determine whether or not to challenge or dispute dormant negative accounts that could be helping your score mix or length of time. Keep score by maintaining a credit monitoring service. Please keep this in mind.
Second Process
- An excellent way to start is to freeze your client’s information prior to challenge in our opinion some clients may not need this but it can still be effective for all. This is great for those with lots of collection, charge-offs and public records. However, It is also still a great ideal to send and letter to the Credit Bureau challenging personal identification information on a client’s credit report to have some success in getting those first deletions and removals. This way, when challenging/disputing accounts, it could help greatly if there is not associated address or information connecting the item.
- First, look for violations based on the 13 common FCRA errors on the credit report we provide here and if they are there, pass them directly over to the law firm we have listed for you to sue the credit bureau. Remember the credit gets one opportunity to correct an error.
- If they are not there, you will start your dispute process with the credit bureau. Use the McCarthy Law Firm Dispute Handbook to help you build your client’s case.
- Did they respond? Keep in mind that you have to depend on your client to provide this information and sometimes they lose mail. Therefore, you can send a reminder alerting them that it was not received. I would fax this reminder.
- If they respond, you must ask for their method of verification. The bureau must respond with the furnisher’s information:15 U.S. Code § 1681g – Disclosures to consumers
The question is what to do if NOT.
After you have done these steps here is the formula for each client.
6.Remember that the credit bureau is governed by regulators and business too. Therefore you can file a complaint and should do so for all of the below at the same time on behalf of your client using the failure of the Disclosures to consumer clause of the FCRA
Consumer Financial Protection Bureau CFPB https://www.consumerfinance.gov/complaint/getting-started/
File a Complaint to the Federal Attorney General’s office
http://www.ncdoj.gov/Consumer/2-2-12-File-a-Complaint.aspx
The Better Business Bureau in the state that they reside.
https://www.bbb.org/consumer-complaints/file-a-complaint/get-started
7.Contact an FCRA attorney. Because you have prepared a case for your client from the beginning, you will be able to share with them what is your argument. They will either say that you have a case or not.
If there is not the case, you can send one more round of dispute on behalf of your client but this time dispute them online, via fax and mail at the same time.
8.If no response, you can try a cool down period for 90 days and restart the process from start to finish.
9.It is time to close the client file and provide them with the reason. Then educate them on methods of rebuilding their credit.
10.If things do not go as the customer planned, they may take action against you. This is why we believe the pay-per-deletion method, in the beginning, is best. Because they could sue you. You can place your client on a client progress monitoring plan where they stay under your umbrella being accountable to you in reaching their credit score goal. You will reach out to them monthly regarding reviewing their progress. You will charge a nominal monthly fee for this service.
More Tips:
You can open an account with Letter Stream to mail all of your credit disputes.
If you get stuck, just ask us what you should do next here at the help desk and will help. You can upload a scanned image too if you need us to take a look at what you are seeing on their report. If you are having problems posting a message, just send us an email at help@credithelpdesk.org and we will still respond. Please include a phone number in case a consultant can’t respond in writing but could do so via phone. This sometimes happens for those who have purchased live phone coaching.
Now for the Nuances of the credit repair process, we will repeat some things here with a little more information:
2-First STEP: What is their goal? Mortgage, Car, (Bank Card can be obtained via a secured card). Never promise to clean up their credit report. See if you can work from an established goal; this will make you an even more effective credit consultant.
3-If they are seeking a car loan, then you should approach the credit repair process from that goal. Read this http://credithelpdesk.org/auto-enhanced-score/
4-If their goal is to obtain a Mortgage, this is a different process. You need to know: ‘when are they ready to buy?” Will it be an FHA or conventional loan? Also If it is soon then read http://credithelpdesk.org/more-on-rapid-rescore/. If time is not a major issue, you can take a long-term approach to raise their scores to optimum levels.
5-Once you know the goal you must see how their credit scores are affecting this goal. How many points they need to obtain a mortgage e.g. 680 and some programs can work with lower scores.
6-What is affecting the score? There are what if’ simulators you can use to ascertain the dispute process: http://credithelpdesk.org/kb/credit-score-what-if-simulator/
7-Your attack should be from these levels. You may have to attack it with the creditors first in some cases or settle in others. The trick is to understand procedures and attack from those angles.
8-Remember, that one of your first questions to ask your client is whether or not they used a credit repair firm or disputed items on their credit report within the last year. This is important for the sake of consistency. If a dispute is different than previous ones, it will stagnate the credit repair investigation; meaning that the CB will usually not verify those disputed items again.
9-Remember to send letters to the credit bureau as if the client is sending the letter. Do not put your information on letters.
10-Never DISPUTE an item on a credit report it is NOT listed on their report. Just because they are on one or two credit reports, if it is NOT on the one you are working on, do NOT dispute it!
11-If you use third-party sites to pull a credit report, you can still a dispute to the credit bureaus based on the content of these reports, they have the same information.
12-When you have your client’s credit report pulled from either annualcreditreport.com or another source, the addresses to send disputes will be listed within.
13-The best way to have tough items deleted is to catch the furnisher in a violation and construct the letter to reflect you are aware of this violation.
14-Also and this is very important: Credit Bureaus are separate entities. What one is reporting has NOTHING to do with the other. Sending what another credit bureau is reporting is NOT a good strategy. They are competitors and do not care. Make absolutely certain that you deal with what they are reporting in their bureau’s file and give your client the ability to take further actions if inaccuracies are not corrected when disputing. Meaning don’t hurt them with frivolous unsubstantiated disputes
Collections/Judgments:
Are they paid or unpaid? Remember if they are unpaid, they can restart the collection process if you challenge them. Therefore you must warn your client about this issue.
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Getting Certified labels online: https://www.certifiedmaillabels.com
If you need to sue a credit bureau, collector or furnisher:
Marcus Zelman is an excellent choice. 845-367-7146 – http://marcuszelman.com
McCarthy Law – (855)-976-5777 – https://www.mccarthylawyer.com/
Suzanne Begnoche – 919.960.6108 – http://www.begnochelaw.com/practice-areas/fcra/
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Read these next two articles for approaches.
Online Disputing is Bad!!! http://credithelpdesk.org/kb/online-disputing-is-very-bad/ However, there are some extremely effective methods that some consultants are using and having a lot of success with online disputing.
http://credithelpdesk.org/kb/best-stragety/
http://credithelpdesk.org/kb/trans-union-tu-frivolous-letters/
NOTE: There are usually two ways a lender can report to CRA and it is a good idea to know what method they use to get a feel for that company’s internal procedures. This always provides its time frame. The two ways are e-Oscar The Metro 2 format. Metro 2 format meets the requirements for the FCBA, FCRA, and ECOA. e-Oscar provides a historical perspective and has no mail delays.
Faxing Dispute Letters To Credit Bureaus is an excellent way to challenge or dispute items on credit report. Here are excellent sources: My Fax and SMART FAX
Homepage
http://smartfax.com/
Credit Bureaus Addresses:
Experian
P.O. Box 4500
Allen, TX 75013
Experian Phone Numbers:
800-916-8800: Disputes Items & Status Checks
877-322-8228: Free Annual Credit Report
800-888-4213: Purchase Credit Report
888-909-8872: Place a Security Freeze
800-493-2392: Credit Monitoring Customer Support
866-922-2100: Business Services Assistance
610-546-4771: Fax Machine
Dispute fax Numbers: 972-390-5790
Equifax Information Services LLC
P.O. Box 740256
Atlanta, GA 30374
Equifax Phone Numbers:
866-349-5186: Dispute Credit Report Items
800-685-1111: Request Free Credit Report
888-766-0008: Place Fraud Alert on Profile
866-493-9788: Existing Customer Support
888-202-4025: Business Solutions
404-885-8078: Fax Number
Dispute fax Numbers: 888-826-0549 – 888-826-0573 – 888-826-0727
TransUnion LLC
Consumer Dispute Center
P.O. Box 2000
Chester, PA 19016
TransUnion Phone Numbers:
800-916-8800: Disputes Items & Status Checks
877-322-8228: Free Annual Credit Report
800-888-4213: Purchase Credit Report
888-909-8872: Place a Security Freeze
800-493-2392: Credit Monitoring Customer Support
866-922-2100: Business Services Assistance
610-546-4771: Fax Machine
Dispute fax Numbers: 610-546-4605 – 610-546-4771
Credit Laws
Bankruptcy Code
Consumer Credit Protection Act (CCPA)
Credit Repair Organizations Act (CROA)
Equal Credit Opportunity Act (ECOA)
Fair and Accurate Credit Transactions Act (FACTA)
Fair Credit Billing Act (FCBA)
Fair Credit Reporting Act (FCRA)
Fair Debt Collection Practices Act (FDCPA)
Home Ownership and Equity Protection Act
Identity Theft and Assumption Deterrence Act
Texas Finance Code 393
Truth in Lending Act (TILA)