CROA

Accidental Criminals: When Helping You Hurts Them

Jeffrey S. Hyslip
Jeffrey S. Hyslip
October 22, 20242 min read

The Double-Edged Sword

Debt collectors have a hard job. They are trying to get money from people who often don't have it. To sweeten the deal, they sometimes offer a carrot: "Pay us, and we'll wipe this from your credit report."

It seems like a good customer service move. But legally, it's a disaster for them. By offering to improve your credit history in exchange for money (the debt payment), they inadvertently become a Credit Repair Organization (CRO) under federal law. And that subjects them to a whole new set of rules they are rarely prepared to follow.

Legal Trap: The moment a collector links payment to credit score improvement, they step into a minefield of federal regulations.

The "Accidental" CRO

The Credit Repair Organizations Act (CROA) defines a credit repair organization broadly. It doesn't matter if their main business is debt collection. If they say, "Give us money, and we will improve your credit," they are a CRO. Period.

What Happens When They Cross the Line?

Once they step into that trap, they must:

  1. Provide a detailed disclosure statement before you sign anything.
  2. Give you a written contract with specific terms.
  3. Wait 3 days before accepting performance (payment).

If they take your payment over the phone immediately after promising to delete the tradeline? Violation.

Silhouette of a businessman tripping over a glowing red CROA laser tripwire
Debt collectors often trip over CROA regulations without realizing it, giving you powerful legal leverage.

Your Leverage: Voiding the Debt

Why does this matter? Because CROA has teeth. If a contract violates CROA (and a verbal agreement to pay-for-delete almost certainly does), that contract is void. You may be entitled to:

RemedyBenefit to You
Full RefundGet back every penny you paid them under the void contract.
Punitive DamagesThe court can award extra damages to punish the collector.
Attorney FeesThey have to pay for your lawyer, making it free for you to sue.

The next time a collector tries to be "helpful" with your credit score, take notes. They might just be handing you the keys to a lawsuit.

Think you have a CROA claim? Contact us for a free case evaluation or read more about The Pay-for-Deletion Trap.

Jeffrey S. Hyslip
About the Author

Jeffrey S. Hyslip

Jeffrey S. Hyslip is the founding attorney of Hyslip Legal, where he focuses exclusively on consumer protection law. With over a decade of experience fighting debt collectors, credit bureaus, and financial institutions, he has helped thousands of clients recover damages and restore their peace of mind. He is admitted to practice in Ohio and multiple federal courts.

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