4770 NW 2nd Avenue. SUite D
Boca Raton, FL 33431
Telephone: 866-597-0730
Facsimile: 866-428-1108
September 17, 2009
Federal Trade Commission
Office ofthe Secretary
Room H-135(Annex T)
600 Pennsylvania Avenue, NW
Washington, DC 20580
Re: Debt ReliefAmendments
Debt Remedy Solutions, LLC ("DRS") is very pleased that the Federal Trade
Commission ("FTC") is seeking to address the abusive practices of a few bad actors
within the debt settlement industry. As an accredited member ofThe Association of
Settlement Companies ("TASC"), DRS is aware of the need to protect consumers and to
provide them with the services they've contracted for. To this end TASC, whose goals
are to promote good practice in the debt settlement industry and to protect the interests of
consiuners, has effectively managed to self-regulate its members.
DRS believes that a well informed consumer is our best customer, and to this end we
provide all prospective customers with ample information related not only to our program
but to the overall dynamics ofdebt settlement. A prospective customer of a TASC
member company is afforded the opportunity to make an educated decision. Likewise,
TASC member companies are discerning, declining to enroll consumers who are deemed
not to qualify for our services. DRS is proud of its program and the valuable assistance it
has lent to its customers.
DRS hopes that the efforts of the FTC to better regulate the debt settlement industry does
not inadvertently have the opposite effect - draconian or otherwise unrealistic regulations
that effectively shut down the debt settlement industry. For example, a "back-end" fee
requirement would likely have a grave impact upon the viability of the industry. Most
debt settlement programs are long-term, and the suggestion that a company delay
(possibly delay for several years) just and fair compensation until some later date is at
best untenable. While DRS can appreciate in the abstract the spirit of the back-end fee
requirement, the affect will at a mini