Product: Checking or savings account

In late XX/XX/XXXX I began the process of a Debt Settlement Program. I was instructed not to pay my debts enrolled in the program because it would give the company better leverage for negotiation. I was paying {$750.00} on the XXXX of every month beginning XX/XX/XXXX. In XXXX and XXXX, after fees were paid to the debt settlement program and Global client services, there was only {$130.00} in my dedicated account even though I paid {$1500.00} for those months. From XXXX through XXXX {$110.00} of the {$750.00} was added each month to my account. In nine months I had only {$850.00} available for debt negotiations after paying {$6500.00}. In those nine months {$5900.00} were paid as fees. The first negotiation and payment to a creditor occurred in XXXX. Payment was issued on XX/XX/XXXX and sent by overnight delivery. 

Obviously, the entity that benefited most was the debt settlement company. These upfront payments are illegal breaking the TSR laws. Many of these companies have stated that they are exempt. However, over and over the courts have found that they are not exempt and held them responsible. Payment processing companies like Global Client Solutions have been found responsible for releasing these payments knowing that upfront fees are illegal, even though they act as if they dont know that they are illegal. They also have knowledge when creditors have begun receiving payment since they are the ones issuing the payments. 

Global is already known to the CFPB who filed a case against them and their chief executives, XXXX and XXXX. A Stipulated Consent order was entered into for {>= $1,000,000} in redress penalties to CFPB as well as another {>= $1,000,000} in civil penalties to CFPB. Lengthy rules dealing with policy expectations, vetting of business affiliations, reporting to CFPB and monitoring by CFPB were involved. This occurred in XX/XX/XXXX. 

Global has disregarded all of the rules that they agreed to follow in the Consent Order, as my simple math illustrates. Global releases the payments. Their responsibility should be to the consumers who own the accounts. They need to follow the law and not make fee payments until the legal requirements are met. The law states that no advanced fees can be made until : 1.settlement negotiations are reached with the creditor ; 2.the settlement is agreed to by the customer ; and 3.at least one payment has been made to the creditor. 

As I stated previously, the first payment was made on XX/XX/XXXX by overnight delivery. You can view all of the payment activity on the attached record of my dedicated account with Global Client Solutions, beginning XX/XX/XXXX through XX/XX/XXXX when I closed my account. 

Their accounting can be difficult to follow : - A Retainer Fee of {$150.00} for two months, then {$100.00} for six months ; - An Administration Fee of {$89.00} for every month you are in the program ; and - A Service Fee of {$430.00}, which is 17 % of the entire debt enrolled in the program divided into 22 monthly payments. 
These fees should not have been released until the program had completed the negotiation with each creditor. Only when negotiations are completed for each debt, can fees for each debt be released. 

Global has blatantly disregarded the enforcement the CFPB enacted in XXXX. I am hopeful that there are ways to be sure that these payment processing organizations can be taught that complicity in breaking the law and setting customers up for failure is unacceptable and punishable. 


Thank you very much for your attention to this matter, XXXX XXXX