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TASCs

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The Association of Settlement Companies

TASC™ Standards for Preferred & Accredited Members

I. SCOPE

The goal of this document is to establ ish Industry Standards for members of TheAssociation of Sett lement Companies (TASC™). W i th this goal in mind, TASC™

recognizes the di f ferences in the pract ices of potent ial TASC™ member companies andspecifically includes Pr incipal Members as the fo l lowing:

a) a m e mber company who markets and sells a debt set t lement p r og ram;b) a me mber company who provides customer service and negot iat ion; and

c) a m e mber company who provides markets and sells a debt set t lement program andprovide customer service and negot iat ion.

In addition, TASC™ also recognizes Members as vendors who sell , provide or of fer to

provide goods or services to Pr incipal Members and Industry Al l iance Members who workin conjunction with the debt set t lement industry in some manner.

The following Standards apply to al l Pr incipal Members. T h ese Standards include theTASC™ Member Licensing Agreement, the TASC™ Disclosure Document and the TASC™

Web Disclosure Document, al l of which are at tached. Member adherence to these

S tandards wil l be noted by one of two designations; Preferred or Accredited. T h edesignations are def ined below in Sect ion II , Def init ions.

All Preferred and Accredited Members and their Representatives shal l adhere to thestandards required of their designation at al l t imes while engaging in the business of

providing Debt Sett lement Services to consumers. Fai lure to do so can result in thecancellation of the TASC™ membership.

II. DEFINITIONS

Accreditation:A process conducted by an independent third party accreditat ion and/or cert i f icat ion

company approved by TASC™ to demonstrate a member's adherence to these Standards.

Members must comply with a min imum yearly accreditat ion review process by the abovementioned independent third party accreditat ion and/or cert i f icat ion company.

Accredited Members:Member companies wil l be known as Accredited Members and (subject to the terms and

conditions of logo usage) wil l be able to d isplay the TASC™ Accredited logo oninformational and market ing mater ials once their mater ials and operat ions have beenAccredited by an a p p roved independent third party accreditat ion company. This

Accredited status must be renewed annual ly.

16 N. Carroll Street, Suite 900 I Madison, sNI 53703 I Phr 888-657-8272 I Fsu 888-482-3791 I www.tascsite.org

Members:Any TASC™ member, whether an indiv idual or an ent i ty, currently operat ing as a DebtSettlement Services Provider.

Affiliate Members:Affiliate Members are companies providing front end services to a backend TASC member

company. To become an af f i l iate member, you must al ready be associated with a backendTASC company and you must l ist the name of the backend company on your appl icat ion.

Vendor Members:Vendor Members are companies providing services to debt sett lement companies such as

lead generation, software, legal services, etc.

Industry All iance Members:

An Industry Al l iance Member works in concert with the debt set t lement industry in somemanner. Th is membership includes creditor, col lector and debt buyer companies, creditcard marketing and card industry companies and others associated in some manner wi th

the debt sett lement industry. A n I ndustry Al l iance member is act ively looking to ef fectpositive interact ion among al l part ies while support ing TASC standards and guidel ines.

C ancellat ion /Terminat ion :Used interchangeably, both "cancellat ion" and/or "termination" shall be col lect ively hereinreferred to as "cancel", "cancelled", or "cancel lat ion". This refers to any point in t ime,

following the r ight of rescission period, in which ei ther the Member or its Cl ient givesnotice to the other of their intent to end the agreement or program.

Creditor:A creditor or creditors is def ined as a person or ent ity al legedly owed a debt by a

consumer. Th is may inc lude authorized representatives of the creditor, and any otherperson or ent ity that has lawful authority to col lect such al leged debt or account.

C ustomer or C l i en t :Any consumer(s) that contracts with or otherwise agrees to obtain debt sett lementservices from a Debt Sett lement Services Provider.

Debt Settlement Services:Offering to negot iate or negot iate a compromise to reduce the unsecured debt obl igat ions

or the credit extended by others between a c l ient and a credi tor to less than the fu l lprincipal amount owed. T h ese serv ices may also include f inancial educational materials,advice, and customer service throughout the term of the program.

Debt Settlement Services Provider:Any individual or ent ity who advocates on behalf of consumers in f inancial distress by

providing or offer ing to provide debt sett lement services.

Fee or Fees:

The good and/or valuable considerat ion given to a Debt Sett lement Service Provider by oron behalf of a Cl ient .

Members:All Principal or Associate Members who are current in their monthly TASC™ membershipdues and are in compl iance with al l other membership requirements.

Principal Member:Any TASC™ member, whether an indiv idual or an ent i ty, currently operat ing as a DebtSettlement Services Provider.

Standards, Policies, Procedures:

16 N. Carroll Street, Suite 900 I Madison, sNI 53703 I Phr 888-657-8272 I Fsu 888-482-3791 I www.tascsite.org

Written measures, condit ions, act ions and parameters of conduct adhered to by Preferredand Accredited Members and their Representatives to avoid any discr imination or disparityof provided services.

Principal Location:The primary physical locat ion which includes the Member's name, physical address, and

telephone number associated with that physical address.

Program:

The system of Debt Sett lement Services specific to a Cl ient wil l be known as a Program. Itshall not be cal led a Plan because neither the t ime nor the needed amount for set t lement

can ever be guaranteed.

Rescission Clause:

A clause that al lows cl ients to cancel the program without f inancial penalty within three (3)days of signing the contract is cal led a Rescission Clause. This Clause should be locatedi n the immediate proximity of the Cl ient's s ignature block wi thin the master contract . I t

should include the fo l lowing statement; "You may rescind this agreement without

penalty or obligation at any t ime before midnight of the 3rd business day after thedate on which you signed the agreement."

Representatives:All member off icers, directors, employees, agents, af f i l iates, contractors and sub­

contractors related to providing Debt Sett lement Services.

Third Party Accreditation Company:

An entity that of fers an accreditat ion program approved by TASC™.

Vendor:Any individual or ent ity that markets, sel ls, provides or of fers to provide goods or serv icesto Principal Member ent i t ies or other ent i t ies in the debt set t lement services industry.

III. BASIC REQUIREMENTS

a) Me mbers are companies (subject to the terms and condit ions of logo usage) who

will be able to d isplay the TASC™ logo on approved informational and market ing

materials upon jo ining TASC™ and who have agreed to submit wr i t ten company

materials to TASC™ representatives for ver i f icat ion of membership. T h is rev iew

will determine if the company's wr i t ten materials adhere to these standards. A

member company that fa ils to submit information for such approval, or whose

materials indicate non-compliance with these standards, shal l not be a l lowed to

display the TASC™ approved logo.

b) A l l Members and their Representatives shall comply with al l Federal and State

laws, regulatory opinions, rul ings and determinations including, but not l imited to

the privacy of Cl ient's personal conf idential information and company registrat ion

as required by appl icable State law.

c) A l l Members shal l maintain a f ixed "br ick and mortar" locat ion.

d) A l l Members shal l make avai lable on their websites a st reet address for their

headquarters, a main te lephone number, an email contact address and the TASC™

Web Disclosures Document.

16 N. Carroll Street, Suite 900 I Madison, sNI 53703 I Phr 888-657-8272 I Fsu 888-482-3791 I www.tascsite.org

e) All Members shall have wr i t ten agreements with al l Cl ients which include the

official and a p p roved TASC™ Disclosure Document and the wr i t ten requirements

described under the CLIENT AGREEMENT sect ion below

All Members shall be open for business a minimum of 40 dayt ime business hours

Monday through Friday and wil l post their hours of operat ion clearly on their

website.

g) All Members shall have formal and cont inual training for each of its appl icable staff

in Sales, Operation, Negotiat ion and Customer Service which wil l inc lude access

to a copy of the Fair Debt Col lect ion Pract ices Act .

h) No Member shall direct a potent ial or current c l ient to stop making monthly

payments to their creditors.

All Members shall offer and apply Debt Sett lement Services to al l indiv iduals in a

nondiscriminatory manner.

All Members shall advocate the needs on behalf of their c l ients while conduct ing

themselves in the highest ethical standards and pract ices.

k) A TASC member company may not of fer credit repair, loan modif icat ion or pay day

lending services in conjunct ion with debt sett lement services. The TASC logo can

not be displayed on any website except a TASC member company website or

domain name.

IV. CLIENT AGREEMENT

All Members shall provide the cl ient a copy of the Cl ient Agreement and maintain a copy

of the agreement for a per iod of three (3) years af ter the c l ient ei ther completes orterminates the program. Al l Cl ient Agreements shal l include:

The TASC™ Disclosure Document.

A comprehensive l ist of every debt at the t ime of enrol lment including the

Creditors' names and ident i fy ing information.

The approximate total of al l such debts.

The total amount of al l fees, or the method for calculat ing such fees, to be paid by

the Client to the Member or to any other person, over the term of the agreement.

The estimated amount of money needed to fund sett lements.

The estimated number of instal lments necessary to fund the Program.

The name, physical address and te lephone number of the Member.

A description of the services to be provided by the Member.

Clearly defined cancel lat ion pol icies and procedures.

10. A clear and conspicuous rescission statement in the contract with the heading

'Notice of Rescission' and an accompanying form for such rescission. This form

will contain instruct ions on how to communicate with ease the c l ient's decis ion to

rescind the agreement.

11. The full legal name and legal address of the Services Provider.

16 N. Carroll Street, Suite 900 l Madison, Wl 53703 l Phr 888-657-8272 l Fsu 888-482-3791 l www.tascsite.org

12. The Client Agreement containing al l of the above terms must be reviewed by a

company representative for appropriateness and completeness and s igned by the

Client.

V. MARKETING STANDARDS

a) A l l Members shal l publ ish on al l websites owned by the Member the appropriate

TASC™ logo with the l ink to the publ ished TASC™ Web Disclosure Document and

will ensure internally that the l ink is act ive.

b) No Members shal l engage in any sales or market ing that uses any unfair or

deceptive representations including unsubstantiated performance or savings

statements. U n substant iated statements are those that cannot be supported by

objective and unbiased data for the industry and/or the Member.

c) A l l Members and their Representatives shal l only provide Debt Sett lement

Services to a Cl ient who is qual i f ied based upon the f inancial review of the

information provided by the c l ient .

d) A l l Members shal l disclose verbally to a prospect ive cl ient al l the prescr ibed

TASC™ disclosures pr ior to any s igning of a Cl ient Agreement.

e) A l l Members shal l conduct an in i t ial comprehensive review of a consumer's debts

and his/her monthly budget.

f) A l l M e mbers shal l descr ibe the methodology of the Debt Sett lement program to

each potential cl ient so that he/she can make an informed decision as to whether

or not a debt set t lement program is a v iable and affordable opt ion.

g) A l l Member advert is ing content (and data support ing the c la ims made) shal l be

saved for a minimum of f ive years.

h) TA SC™ st rongly recommends and encourages al l Members to provide discounted

and/or free debt sett lement services to consumers who otherwise wil l not be ab le

to afford their services.

VI. FEES

All Fees shall be in compl iance with state law when appl icable and in other instances shal l

be fair and reasonable.

VII. FINAL ACCEPTANCE

Members must fu lly evaluate pr ior to f inal acceptance of each Cl ient Agreement that aDebt Settlement Program is an af fordable and viable opt ion for each potent ial c l ient .

VIII. SERVICING THE CLIENTS AND SERVICE DELIVERY PROCEDURES

16 N. Carroll Street, Suite 900 l Madison, Wl 53703 l Phr 888-657-8272 l Fsu 888-482-3791 l www.tascsite.org

Members shall have wri t ten pol ic ies and procedures that include, but are not l imited to,the following elements:

a) Job descr ipt ions for al l hourly and supervisory personnel;

b) Days and Hours of operat ion;

c) M e t hods of communication with Cl ients;

d) Gu ide l ines for t imel iness and accuracy of serv ice;

e) The ma intenance of records in a re t r ievable format;

f ) T h e d o cumentat ion of communications with Cl ients and act ions taken on their

behalf;

g) An i n ternal c l ient dispute resolut ion pol icies and process that provides for prompt

resolution of any Cl ient dispute;

h) The p rocess to be used to measure the performance of c l i ent serv ice and service

delivery

i ) T h e a c ceptable benchmark for the above performance ;

j) The feedback communication of the above performance to staff and managers

k) The es tabl ishment of a performance improvement review process; and

I) W r i t ten procedures to prevent unauthorized access to or misuse of a Cl ient 's

confidential information.

IX. NEGOTIATION OF CLIENT DEBTS

All Principal Members except those involved solely in market ing or sel l ing a debt

settlement program shall demonstrate their abi l ity to achieve sett lements of consumerdebt that are mutually agreeable to both Cl ients and Creditors if the Member has been inbusiness for more than 1 year .

Members shall have in p lace and wr i t ten documentat ion of :

a) A p r ocess to obtain a Cl ient's approval for each sett lement unless the authority to

settle a cl ient's debt is provided for by contract or by statute.

b) An i n ternal procedure for the per iodic review of a Cl ient's progress through i ts

Program.

c) The p rocedure to obtain wr i t ten sett lement agreements that contains language of

f inal debt forgiveness or sat isfact ion before payment is made to the Creditor.

d) A w r i t ten procedure describing the necessary steps for handl ing an account in

which the creditor is represented by an at torney.

e) The process to not ify the Cl ient or to ensure Creditors are paid on or before the

due date(s) set forth in the set t lement terms.

f ) T h e i n te rnal procedure to provide Cl ients with copies or access to copies of each

settlement agreements achieved and if appl icable, proof of payment.

16 N. Carroll Street, Suite 900 l Madison, sNI 53703 l Phr 888-657-8272 l Fsu 888-482-3791 l www.tascsite.org

X. CREDITORS

Principal Members shal l :

a) Es tab l ish Creditor Pol ic ies and Procedures and adhere to their own set of systems

of communications with creditors. This system shal l include standards for

response time to communications from var ious creditor inquir ies.

b) Be open to credi tor inquir ies and have readily avai lable by phone and in wr i t ing an

explanation on how debt set t lement works.

c) No t rece ive compensation in any form or manner from a Cl ient's creditors for

handling that part icular cl ient's creditor account.

XI. CLIENT FUNDS

No Principal Member shal l receive money directly f rom a c l ient or exercise di rect

control over funds of a c l ient for the purpose of d istr ibut ing payments to or among oneor more creditors of the c l ient in ful l or part ial payment of the c l ient's obl igat ions. Ifthe client has entered into an agreement with a th ird party as part of h is/her savings

program, any funds held, escrowed or d istr ibuted by a th ird party wil l be for thepurpose of sett l ing the debts of the c l ient with the intended creditor(s) or for thepayment of certain fees ( i .e. sett lement savings fees) specif ied in the Cl ient

Agreement.

XII. INSURANCE COVERAGE

Members shall maintain reasonable insurance coverage or surety bond to protect theMember, its employees, and Cl ients as required by the appl icable state law.

XIII. RESELLER AND SUBCONTRACTING REQUIREMENTS

Members shall adopt pol icies and procedures to ensure that subcontractors, with whom

they contract, comply with al l appl icable standards and take appropriate act ion to remedyany non-compliance.

XIV. RECORD KEEPING REQUIREMENTS

All Members shal l :

a) f o l low a record retent ion pol icy that ensures records of al l Cl ient contracts and

transactions including those stored electronically are preserved for a min imum of

three (3) years from the date the Cl ient completes or otherwise terminates the

Member's Program;

b) ma in tain a record keeping system to account for al l c l ient contacts and

transactions;

c) p r event records from being al tered or destroyed;

d) p rov ide pol ic ies and procedures for correct ing erroneous information in records;

e) sa feguard records from damage or deter iorat ion;

f) r e c o ver or reconstruct damaged or deter iorated records; and

16 N. Carroll Street, Suite 900 l Madison, Wl 53703 l Phr 888-657-8272 l Fsu 888-482-3791 l www.tascsite.org

g) p ro tect records from unauthorized access.

XV. PERIODIC REVIEW

a) Me mbers shal l be reviewed for compl iance with approved Standards at a t ime and

place at the discret ion of TASC™.

b) Me mbership status shal l be reviewed annually by TASC™.

16 N. Carroll Street, Suite 900 ( M adison, sNI 53703 ( Ph r 888-657-8272 ( F s u 888-482-3791 ( www . tascsite.org