This checklist is an operational reference, not legal advice. Review your program with qualified counsel in every state where you do business.
Before you charge
- Written contract executed and a copy provided to the consumer.
- Required federal disclosure statement delivered before the contract is signed.
- Cancellation rights clearly stated with the required notice period.
- No fees collected for services that have not been fully performed.
Ongoing recordkeeping
- Retain signed agreements, disclosures, and cancellation notices for the required retention period.
- Keep a dated record of every dispute sent and every response received.
- Log all client communications against the file.
- Maintain an audit trail of who changed a record and when.
Advertising and claims
- No guarantees of specific score increases or item removals.
- No claims that accurate, current negative information can be removed.
- Testimonials must reflect typical results or disclose that they do not.
Systems help here: when disclosures, contracts, and audit trails are generated by the platform rather than assembled by hand, compliance stops depending on individual diligence.