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CreditRepairPrecheck面向信用修复机构与代理商:信用修复文案 vs CROA 公示义务
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面向信用修复机构与代理商:信用修复文案 vs CROA 公示义务

Methodology: CROA duties · fee & contract logic · human review

Paste your credit-repair marketing wording or the contract you plan to use. Get a scored pre-check report — a “guaranteed score increase” or “new credit identity” claim, an upfront fee charged before the work is done, a missing “you can dispute yourself for free” disclosure, or a contract with no three-day cancellation right — based on the Credit Repair Organizations Act (CROA, 15 U.S.C. § 1679 et seq.). A heads-up, not a legal opinion.

1. The anchor: the CROA statute, not a CFR rule

CreditRepairPrecheck pre-checks for-profit credit-repair advertising and contract wording against the Credit Repair Organizations Act (CROA), 15 U.S.C. § 1679 et seq. — the § 1679b ban on misrepresentations (a false claim about what a consumer's credit will be, a "new credit identity / fresh file / TIN" scheme, or an implied government affiliation) and on charging before the service is performed to the consumer's satisfaction (§ 1679b(c)), the § 1679c consumer-rights disclosures (the "dispute inaccuracies yourself at no cost" and no-government-affiliation statements), and the § 1679d written-contract, material-terms, and three-business-day cancellation duties (with § 1679e voiding any waiver of those rights). 16 CFR Part 310 is the FTC's Telemarketing Sales Rule — it is NOT the credit-repair standard. Because CROA is a statute rather than an FTC legislative rule, it has no separate implementing CFR part; Part 310 appears here only as a labeled advisory for the phone channel, and state credit-repair licensing regimes (and the FCRA consumer-dispute backdrop) are advisories only, never quoted.

2. What the engine owns

Severity-ranked findings from pasted credit-repair wording against heuristics derived from the published CROA duties. Check families: misrepresentation and government-affiliation claims (§ 1679b); advance fees collected before the service is performed to satisfaction (§ 1679b(c)); a missing "you can dispute yourself for free" / consumer-rights summary (§ 1679c); contract defects — no written contract, missing material terms, or no three-business-day cancellation right (§ 1679d); and void rights-waivers (§ 1679e); plus context advisories (the phone-channel Telemarketing Sales Rule note, the legal-services boundary, and the FCRA / state-licensing backdrop) that never invent facts. Scores dock per HIGH/MEDIUM/LOW finding (advisories never dock); a claim that bills only after performance, carries the § 1679c disclosures, and uses a written contract with a three-day cancellation right is not docked. The required non-endorsement line ("we are not affiliated with any government agency") is treated as a disclosure present, never as a government-affiliation claim. Signals are matched as whole phrases. The statute snapshot is dated by the engine version — it is not synced with regulator pages in real time. Demo is labelled Rule-based — never silent mock.

3. What optional AI may do

Explain or polish findings when a key is configured. Upstream failure returns 502. No invented findings, no quotes from copy you did not paste, and no fee-timing, contract-delivery, or state-license check the engine did not run.

4. What you must do

  • Review findings against your own fee, disclosure, and contract practices — only you know whether a fee was actually charged only after performance and whether the § 1679c rights summary was actually delivered.
  • Apply fixes in your own ads, landing pages, and contracts — CreditRepairPrecheck never publishes and never connects to a billing system, a CRM, or a state licensing registry.
  • Treat output as decision-support, not a credit-repair-compliance certification, a license, or legal advice.

5. What we deliberately do not do

  • Fee-timing, contract-delivery, or state-license verification — whether the fee was collected only after performance, whether the disclosures were delivered, whether the contract actually has every § 1679d term, and whether you are licensed all live outside the pasted text.
  • Continuous monitoring of live pages or automated publishing.
  • Compliance probabilities or enforcement-prediction numbers — outside the FTC nobody can compute what it will decide.
  • Legal review — CROA checks read wording patterns, not your full obligations. The Telemarketing Sales Rule (Part 310), the FCRA, and state credit-repair licensing appear as labeled advisories only; credit-repair programs under enforcement scrutiny need a qualified professional.

Heuristic pre-check — not a credit-repair-compliance certification, not a license, and not legal advice. Federal basis is the CROA statute (15 U.S.C. § 1679 et seq.); 16 CFR Part 310 is the Telemarketing Sales Rule, not the credit-repair standard; state credit-repair licensing law is advisory only. No fee-timing, contract-delivery, state-license, or enforcement verification performed.

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