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The Credit RecordAn independent record of credit repair and debt settlement companies

Last reviewed: 14 September 2026

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How we check

These are the rules and sources behind each result in Find a company. Our standard is several published standards, each tied to specific federal rules or plainly checkable facts — not a subjective "quality" score. A company either meets a point or it doesn't, and we say which, and why. Credit repair and debt settlement share one standard below; debt consolidation loans, nonprofit credit counseling agencies, and credit-builder products are different products with different risk profiles, so each is checked against a separate standard of its own further down this page.

The standard describes how we check. It is not a list of companies — for results, go to Find a company. New here? Start with the credit repair and debt settlement checklist just below: each point says what we check.

Credit repair & debt settlement: the checklist

  1. No advance fees before resultsFails if any main fee is charged before a specific promised outcome (a settled debt, a removed item) is actually delivered. This is the Credit Repair Organizations Act's core prohibition (15 U.S.C. § 1679b(b)) for credit-repair services, and the FTC's Telemarketing Sales Rule Advance Fee Rule (effective 27 October 2010) for debt-settlement services sold by phone — two separate rules for two related business models. We check them separately: a debt-settlement company's main success fee tied to actual settlement can be lawful even though a small recurring "account servicing" fee that starts on day one, regardless of results, is a different thing we log and disclose on its own — not folded into a single pass/fail.
  2. No guaranteed-results claimsFails on any specific, quotable promise of a score increase or the removal of accurate negative information — both are prohibited claims under CROA regardless of whether a fee was charged in advance. "Guarantee" isn't one thing in this industry, so we score three variants differently: a satisfaction-only refund that explicitly disclaims promising any outcome (the most defensible form), a refund conditioned on an outcome actually occurring (closer to the prohibited territory), and a "we'll keep working free" service-extension promise (not a refund at all, and worth knowing which one a company is actually offering before assuming "guarantee" means your money back).
  3. CFPB complaint history disclosedComplaint volume and resolution pattern, sourced directly from the Consumer Financial Protection Bureau's public Consumer Complaint Database, not self-reported by the company.
  4. FTC / state AG / self-regulatory enforcement historyAny open or settled action against the company or its principals, current or historical, checked against FTC and state attorney general litigation records — and, since it's a real and citable middle tier of evidence between "no action" and full government enforcement, adverse findings from industry self-regulatory bodies like the National Advertising Division (NAD), when one exists and is publicly documented.
  5. Published, flat fee scheduleFails on "call for pricing" or a fee that scales with unstated variables.
  6. State registration / bonding where requiredMost states require credit-services organizations to register and/or post a bond. Verified against the relevant state's own registry — not taken from the company's own claim.
  7. Dispute-process transparencyDiscloses what it actually files — which bureaus, which items, on what legal basis — rather than treating the process as a proprietary black box.
  8. Named company, real address, working contact, clean ownership historyAnonymous ownership, a PO-box-only address, or no working contact method is an automatic fail. We also check whether the current entity is a successor to, or an operating name (d/b/a) of, a company with its own enforcement history — a brand can carry a clean recent complaint record while operating under new ownership after a predecessor entity was penalized or went bankrupt, and we treat that history as the same company's for this check.
  9. Cancellation-rights disclosureCROA's mandated three-business-day right to cancel is stated plainly in the contract, not buried in fine print.

What a passing score means — and doesn't

Passing every point means a company's public-facing practices and complaint record didn't show a violation of these specific, checkable facts as of the date we looked. It is not a guarantee the company will get you a specific result — no legitimate company can promise that, which is exactly point 2 above. It also isn't a claim that we've reviewed every contract that company has ever issued; see the Register for how findings are dated and re-checked.

Why this is checkable at all

Most predatory industries operate in a genuine gray area — "was this claim misleading" is a judgment call. Credit repair is different: charging an advance fee is either true or false, a specific guarantee claim either exists in writing or it doesn't, and a CFPB complaint count is a public number. That's what makes a standard like this possible without it collapsing into opinion.

Debt consolidation loans: a separate standard

A debt consolidation loan isn't a paid service to fix or negotiate your existing debt — it's an actual extension of credit, a new loan used to pay off old ones. That's a different product from credit repair or debt settlement, with a different risk profile: not an advance-fee-for-a-service-not-rendered problem, but a predatory-lending one — an undisclosed real cost, a fee quietly taken out of the loan itself before you see the money, or a rate that would be illegal in your state if not for the particular bank behind it. So it gets its own nine-point standard below, adapted from the checklist above but not identical to it — a company here is checked against the standard that actually fits what it sells, not against a checklist written for a different business.

  1. Real APR disclosed, not just an "as low as" rateFails if a company's marketing headlines a single low starting APR without showing, in the same breath, the full range a typical applicant could actually be offered. The Truth in Lending Act (15 U.S.C. § 1601 et seq.; Regulation Z, 12 C.F.R. Part 1026) requires the actual APR on a specific loan offer to be disclosed clearly before signing — this point asks whether the up-front marketing is honest about the range, not just whether the legally-required fine print eventually is.
  2. No origination fee disguised as a cut of the loan itselfAn origination fee isn't automatically a violation — it's standard across this industry — but this point fails if the fee isn't disclosed as a clear percentage before the applicant accepts the loan, or if the amount actually disbursed isn't stated plainly alongside the loan's face value. The FTC's 2021 case against LendingClub is the clearest illustration of exactly what this point exists to catch: the FTC alleged applicants were told they'd get a loan "with no hidden fees" while origination fees of $1,000 or more were deducted before the money ever reached them, disclosed only behind a small question-mark icon.
  3. NMLS licensing verified directlyChecked against the lender's own record on NMLS Consumer Access (nmlsconsumeraccess.org) — not the company's self-reported license number. Many companies in this space are a technology platform or a brand name operating through one or more partner banks or credit unions that are the actual licensed lender of record; we identify and check that entity specifically, not just the consumer-facing brand name.
  4. CFPB complaint history disclosedComplaint volume and resolution pattern, sourced directly from the CFPB's public Consumer Complaint Database, not self-reported.
  5. FTC / CFPB / state AG enforcement historyAny open or settled action against the company, its principals, or its direct corporate parent — current or historical.
  6. State usury-cap compliance and lending basis disclosedMost states cap the interest rate a lender can charge; many online debt-consolidation lenders instead operate through a chartered partner bank, whose federal preemption lets a loan carry a rate that could exceed the borrower's own state cap for a state-licensed lender. That structure isn't automatically a violation — courts and regulators are still actively working out exactly where the line is — but this point fails if a company doesn't plainly disclose which bank actually made the loan, and that a bank-partner arrangement, not a direct state license, is the legal basis for the rate charged.
  7. Prepayment penalty disclosureFails if a loan carries a prepayment penalty that isn't disclosed clearly before signing. Passes whether or not a penalty actually exists, as long as the answer is stated plainly rather than left to a reader's assumption.
  8. Total cost-of-loan disclosureThe full amount a borrower will actually repay — principal, interest, and fees, over the full term — has to be shown clearly before the loan is accepted, not just a monthly-payment figure that can make two very differently priced loans look identical.
  9. Named company, real address, working contact, clean ownership historyThe same standard as point 8 of the credit-repair/debt-settlement checklist above — anonymous ownership, or a concealed successor-entity relationship after a predecessor's enforcement action, is an automatic fail.

This debt-consolidation-loan standard is new methodology, published for the first time today. As it's applied to more companies over time, we expect to refine it the same way the original nine-point standard above has been refined since this site launched. See the Register for the companies already checked. Seven debt consolidation loan records have been checked against this standard so far; none is currently on the public list.

Correction, 30 September 2026: an earlier version of this section said debt-consolidation-loan assessments were "underway" and would be reflected in the Register's public presentation in a future update. That understated where things stand and implied a presentation we have not committed to. The Register's records show six debt consolidation loan companies already assessed, none of which is on the public passing list. We replaced the sentence with that description.

New methodology — proposed, not yet reflected on the Register's public stat row. The section below is a separate, adapted standard for a different kind of product (secured cards and credit-builder loans) and a different kind of "pass." It has not yet been used to add or remove anything from the Register's public list or aggregate counts — that's a deliberate, separate step. Flagging it here for review before it feeds the Register.

A separate standard for credit-builder products

A secured credit card or a credit-builder loan is a legitimate financial product, not a service with a scam-risk profile — see our explainer for how each actually works. There's no advance fee to police here in the credit-repair sense (you're paying a bank or lender for an actual financial product, not for a promised dispute outcome), and CROA's cancellation-rights disclosure doesn't apply to a card or loan agreement the way it does to a credit-repair contract. What replaces those checks is real: whether bureau reporting, fee structure, and fund-security claims a provider makes are actually true, verified directly rather than taken from marketing copy. Because most legitimate providers in this space already do these things correctly, expect most products we check here to pass — the point of this category is helping pick the best legitimate option, not catching fraud. We'll still say so plainly if a product doesn't hold up on a specific point, the way the checklist below is built to catch.

  1. Reports to all three bureaus — source-checked directlyConfirmed against the provider's own current disclosures, not just a claim repeated across review sites. Some credit-building products report to only one or two bureaus, or added a bureau only recently — both are worth knowing before signing up, since a tradeline only one bureau can see helps less than one all three can.
  2. Genuine fee transparencyAny annual fee, application fee, or monthly membership charge is published plainly, not buried in fine print or omitted from headline marketing. Fails if a real recurring cost exists that a reader comparing the advertised monthly payment or "no annual fee" claim would reasonably miss.
  3. For secured cards: is the security deposit genuinely refundable, and under what conditions?Checked against the issuer's own stated conditions for getting the deposit back (account closure in good standing, graduation to unsecured, etc.) — not "eventually, maybe." N/A for products that aren't secured cards.
  4. For credit-builder loans: are funds held in a locked, insured savings account released at completion — the standard structure — or something else?The standard, legitimate structure is an FDIC- or NCUA-insured account the borrower can't access until the loan term is paid off. Fails, or is flagged, if a provider uses a materially different or less transparent arrangement. N/A for products that aren't credit-builder loans.
  5. Real APR/interest-cost disclosureA genuine annual percentage rate or total finance charge is disclosed — in dollars where possible, not only a monthly payment or a bare percentage — consistent with the Truth in Lending Act's disclosure requirements. A product with no interest at all (some secured-card and revolving-credit-line structures) should say so plainly; that's a pass on this point, not a gap in it.
  6. No deceptive "guaranteed credit score increase" marketingA legitimate product doesn't need to claim this. We distinguish a prohibited-style guarantee from a disclosed, individual-results-vary average outcome statistic (a legitimate track-record claim, the same distinction our 9-point standard draws for credit-repair guarantees above).
  7. Graduation path (secured cards)Does the issuer offer, and actually operate, a real path from a secured card to an unsecured one with the deposit returned — documented on the issuer's own site, not only in secondary marketing describing a graduation path the issuer doesn't actually offer. N/A for credit-builder loans and other non-card products, where there's no secured-to-unsecured mechanic to check.

As with the 9-point standard above, an inapplicable point is marked N/A with a stated reason rather than silently skipped or forced into a "pass" — a credit-builder loan has no security deposit to check, and a secured card has no locked-savings structure to check, and we say so explicitly rather than glossing over the difference.

New methodology — proposed, not yet reflected on the Register's public stat row. The section below is a separate, adapted standard for a different kind of organization (nonprofit credit counseling agencies) and a different kind of "pass" (an accreditation and disclosure check, not an advance-fee check). It has not yet been used to add or remove anything from the Register's public list or aggregate counts — that's a deliberate, separate step. Flagging it here for review before it feeds the Register.

A separate standard for nonprofit credit counseling agencies

A debt management plan (DMP) through a nonprofit credit counseling agency is a genuinely different product from credit repair or debt settlement — see our explainer for the mechanism. Because the business model is different, the checkable facts are different too: there's no advance fee to police in the credit-repair sense (a DMP fee isn't conditioned on a specific dispute outcome), and CROA's cancellation-rights disclosure doesn't apply to this business model the way it does to a credit-repair contract. What replaces those checks is real: whether the "nonprofit" and "accredited" labels are actually true, source-checked against the accrediting body's and the IRS's own records rather than the agency's self-description — the exact gap our nonprofit-counseling explainer warns can hide a "sham nonprofit" operating like a for-profit telemarketing shop. The two points from the 9-point standard above that do carry over in adapted form are enforcement history (point 4) and named-company/clean-ownership (point 8); we score those the same way. Everything else below is new.

  1. Real, current NFCC or FCAA membershipVerified directly against the National Foundation for Credit Counseling's own agency directory (nfcc.org) or the Financial Counseling Association of America's own member list (fcaa.org) — not the agency's own "we're accredited" badge or claim. Both organizations require independent third-party accreditation (Council on Accreditation or ISO 9001) behind membership, not just a fee to join.
  2. Genuine 501(c)(3) tax-exempt statusVerified against the IRS's own Tax Exempt Organization Search (or the equivalent record in Form 990 filings indexed from it) — a real, current, non-revoked determination, not a claim on the agency's "about us" page. The IRS's own mid-2000s Credit Counseling Compliance Project found dozens of "nonprofit" agencies operating for the benefit of related for-profit servicers; a live-status check against the IRS's own database is what that history makes necessary.
  3. A real free initial counseling sessionThe budget/debt review that leads to a DMP recommendation is actually free and available before any enrollment or payment, consistent with what NFCC/FCAA membership requires — not a "free consultation" that turns out to be a sales call gated behind a payment step.
  4. Transparent, capped DMP fee scheduleSetup and monthly fees are published (not "call for pricing") and consistent with the fee caps most states set by statute for debt management/credit-counseling fees — caps that vary by state (a flat dollar cap in some states, a percentage-of-payment cap in others) and can change, so a published fee that's in the right range for the client's state, not a single national number, is what we check.
  5. Creditor concession / "fair share" funding disclosedA DMP's reduced interest rates come from concessions creditors already have on file with the agency, and most of an accredited nonprofit's funding comes from creditor "fair share" contributions — a percentage of what's repaid through the plan — rather than client fees. Fails if an agency obscures this funding relationship or implies the plan is run at no cost to anyone rather than disclosing where the money actually comes from.
  6. Accurate framing — a DMP is not relabeled as something elseFails if an agency's marketing blurs a debt management plan into "debt consolidation" language in a way that implies a new loan or reduced principal (neither is true of a DMP — the client still repays the full balance), or otherwise disguises which of the distinct products in this industry it's actually selling.
  7. FTC / CFPB / state enforcement and material civil litigation, disclosedSame evidentiary approach as point 4 of the 9-point standard above: any open or settled government enforcement action, checked against FTC and state AG records, plus material private litigation (class actions, individual suits alleging the agency operated as an unlicensed credit-repair or debt-adjusting business) — dated, and noted as resolved/historical versus current where that distinction matters.
  8. Named organization, real governance, no anonymous operatorSame named-company/real-address/working-contact bar as point 8 of the 9-point standard, plus one addition specific to nonprofits: agencies covered by 26 U.S.C. § 501(q) must maintain a board where a majority of members aren't employees of the organization or related to its officers or employees — a structural check against a board stacked with insiders that a for-profit "sham nonprofit" typically can't or won't produce.

A passing agency here is not held to a higher or lower bar than a passing credit-repair company — it's a different bar, because it's a different mechanism. Expect a higher pass rate in this category than in credit repair or debt settlement: real NFCC/FCAA accreditation is itself a meaningful filter most operators in this space never clear, so a higher share of the agencies actually carrying that accreditation passing our checks is the expected, correct result of the accreditation doing its job — not evidence we went easier here.

References

  1. Credit Repair Organizations Act, 15 U.S.C. § 1679b(b); Federal Trade Commission, Telemarketing Sales Rule Advance Fee Rule (16 C.F.R. § 310.4(a)(5)(i)), effective 27 October 2010.
  2. BBB National Programs, National Advertising Division (NAD) — a national self-regulatory forum for advertising disputes; its published decisions (e.g. a claim-substantiation finding against a national debt-settlement company, October 2025) are a real, citable evidentiary tier this standard treats as distinct from, and short of, government enforcement.
  3. Truth in Lending Act, 15 U.S.C. § 1601 et seq.; Regulation Z, 12 C.F.R. Part 1026 (APR, fee, and total-cost disclosure requirements for closed-end consumer credit, and for the credit-builder standard). Federal Trade Commission v. LendingClub Corporation, N.D. Cal., consent order entered 14 July 2021 ($18 million) — the origination-fee-disclosure case this standard's point 2 is written around. FDIC/NCUA statutory deposit-insurance framework (credit-builder standard, points 4 and 5).
  4. National Foundation for Credit Counseling, Current Members directory, nfcc.org/current-members, and Agency Finder, nfcc.org/agency-finder (nonprofit-counseling standard, point 1); Financial Counseling Association of America, member agency list, fcaa.org.
  5. Internal Revenue Service, Tax Exempt Organization Search, apps.irs.gov/app/eos, and IR-2006-80, "IRS Continues Focus on Credit Counseling Sector" (nonprofit-counseling standard, points 2 and 8); 26 U.S.C. § 501(q).

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