U.S. Code » Title 15 » Chapter CHAPTER 41— CONSUMER CREDIT PROTECTION › Subchapter SUBCHAPTER II–A— CREDIT REPAIR ORGANIZATIONS

15 U.S.C. § 1679b

Prohibited practices

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(a) In generalNo person may—(1) make any statement, or counsel or advise any consumer to make any statement, which is untrue or misleading (or which, upon the exercise of reasonable care, should be known by the credit repair organization, officer, employee, agent, or other person to be untrue or misleading) with respect to any consumer’s credit worthiness, credit standing, or credit capacity to—(A) any consumer reporting agency (as defined in section 1681a(f) of this title); or(B) any person—(i) who has extended credit to the consumer; or(ii) to whom the consumer has applied or is applying for an extension of credit;(2) make any statement, or counsel or advise any consumer to make any statement, the intended effect of which is to alter the consumer’s identification to prevent the display of the consumer’s credit record, history, or rating for the purpose of concealing adverse information that is accurate and not obsolete to—(A) any consumer reporting agency;(B) any person—(i) who has extended credit to the consumer; or(ii) to whom the consumer has applied or is applying for an extension of credit;(3) make or use any untrue or misleading representation of the services of the credit repair organization; or(4) engage, directly or indirectly, in any act, practice, or course of business that constitutes or results in the commission of, or an attempt to commit, a fraud or deception on any person in connection with the offer or sale of the services of the credit repair organization.(b) Payment in advance

No credit repair organization may charge or receive any money or other valuable consideration for the performance of any service which the credit repair organization has agreed to perform for any consumer before such service is fully performed.

(Pub. L. 90–321, title IV, § 404, as added Pub. L. 104–208, div. A, title II, § 2451, Sept. 30, 1996, 110 Stat. 3009–456.)Editorial NotesPrior Provisions

For a prior section 404 of Pub. L. 90–321, see note set out under section 1679 of this title.

Statutory Notes and Related SubsidiariesEffective Date

Section applicable after the end of the 6-month period beginning on Sept. 30, 1996, except with respect to contracts entered into by a credit repair organization before the end of such period, see section 413 of Pub. L. 90–321, as added by Pub. L. 104–208, set out as a note under section 1679 of this title.

Notes of Decisions
Cited in 70 cases (26 in the last 5 years), 1998–2026 · leading case: Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006).
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Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). · cites it 32× “Plaintiff also contends that Defendants made untrue or misleading representations regarding their credit repair services in violation of 15 U.S.C. § 1679b(a)(3). 3 Final *495 ly, Plaintiff asserts a state law claim for unjust enrichment.”
Poskin v. TD Banknorth, N.A., 687 F. Supp. 2d 530 (W.D. Pa. 2009). · cites it 9× “15 U.S.C. § 1679b. The language of the statute indicates Congress intended that only consumers may pursue claims under those provisions of § 1679b.”
Zimmerman v. Puccio, 613 F.3d 60 (1st Cir. 2010). · cites it 5× “an attempt to commit [] a fraud or deception on any person in connection with the offer or sale of the services of the credit repair organization” under 15 U.S.C. § 1679b(a)(4).”
Whitley v. Taylor Bean & Whitacker Mortg. Corp., 607 F. Supp. 2d 885 (N.D. Ill. 2009). · cites it 5× “(“Blue Horizon”), Oswald Ochoa (“Ochoa”), John Frey Ospina (“Ospina”), Anita Logan (“Logan”) and Favian Cardenas (“Cardenas”) (collectively “Defendants”) alleging violations of the Credit Repair Organizations Act, 15 U.S.C. § 1679b (“CROA”), the Real Estate Settlement Procedures…”
Fed. Trade Comm'n v. Keith H. Gill Richard Murkey, 265 F.3d 944 (9th Cir. 2001). · cites it 3× “False Representations As a preliminary matter, violation of the CRO Act’s prohibition against making or using any untrue or misleading representation of the services of the credit repair organization is not only a violation of the CRO Act, 15 U.S.C. § 1679b(a)(3), but also an…”
Baker v. Fam. Credit Counseling Copr., 440 F. Supp. 2d 392 (E.D. Pa. 2006). · cites it 3× “15 U.S.C. § 1679b(a)(3). • Engaging, directly or indirectly, “in any act, practice, or course of business that constitutes or results in the commission of, or an attempt to commit, a fraud or deception on any person in connection with the offer or sale of the services of the…”
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). · cites it 2× “See 15 U.S.C. § 1679b(a)(3) (prohibiting the making or usage of "any untrue or misleading representation of the services of the credit repair organization”).”
Plattner v. Edge Solutions, Inc., 422 F. Supp. 2d 969 (N.D. Ill. 2006). · cites it 6× “In those cases, however, the plaintiff alleged violations of 15 U.S.C. § 1679b(a), which states that "[n]o person may” violate the provisions of that section; hence, the courts held that person is broader than credit repair organization, and that a finding that the defendant was…”
Fed. Trade Comm'n v. Gill, 71 F. Supp. 2d 1030 (C.D. Cal. 1999). · cites it 5× “” 15 U.S.C. § 1679b(a)(3). Plaintiff argues that the elements needed to prove a violation of section 404(a)(3) of the CRO Act are analogous to those needed to prove a violation of Section 5 of the FTC Act prohibiting unfair or deceptive practices.”
Philip Rannis v. Peter Recchia, 380 F. App'x 646 (9th Cir. 2010). · cites it 2× “§ 1679 (b)(2), and certain provisions in 15 U.S.C. § 1679b(a) specifically require a deceitful or misleading intent, one need not engage in fraud either to qualify as a credit repair organization or to violate other provisions of the statute.”
Zimmermann v. Cambridge Credit Counseling Corp., 529 F. Supp. 2d 254 (D. Mass. 2008). · cites it 3× “15 U.S.C. § 1679b(a)(4). The Puccios were certainly engaged in a “course of business .”
Fed. Trade Comm'n v. Stephen Lalonde, 545 F. App'x 825 (11th Cir. 2013). · cites it 5× “PER CURIAM: Stephen Lalonde, proceeding pro se, appeals from a magistrate judge’s grant of summary judgment in favor of the Federal Trade Commission (“FTC”) on its claims that Lalonde violated the Credit Repair Organizations Act (“CROA”), 15 U.S.C. § 1679b(a)(3), (b); the…”
Show all 70 citing cases →
— 15 U.S.C. § 1679b(2) — 1 case
Alexander v. U.S. Credit Mgmt., Inc., 384 F. Supp. 2d 1003 (N.D. Tex. 2005).
— 15 U.S.C. § 1679b(a) — 12 cases
Whitley v. Taylor Bean & Whitacker Mortg. Corp., 607 F. Supp. 2d 885 (N.D. Ill. 2009). “(“Blue Horizon”), Oswald Ochoa (“Ochoa”), John Frey Ospina (“Ospina”), Anita Logan (“Logan”) and Favian Cardenas (“Cardenas”) (collectively “Defendants”) alleging violations of the Credit Repair Organizations Act, 15 U.S.C. § 1679b (“CROA”), the Real Estate Settlement Procedures…”
Plattner v. Edge Solutions, Inc., 422 F. Supp. 2d 969 (N.D. Ill. 2006). “In those cases, however, the plaintiff alleged violations of 15 U.S.C. § 1679b(a), which states that "[n]o person may” violate the provisions of that section; hence, the courts held that person is broader than credit repair organization, and that a finding that the defendant was…”
Philip Rannis v. Peter Recchia, 380 F. App'x 646 (9th Cir. 2010). “§ 1679 (b)(2), and certain provisions in 15 U.S.C. § 1679b(a) specifically require a deceitful or misleading intent, one need not engage in fraud either to qualify as a credit repair organization or to violate other provisions of the statute.”
Fed. Trade Comm'n v. RCA Credit Servs., LLC, 727 F. Supp. 2d 1320 (M.D. Fla. 2010).
Martinez v. Freedom Mortg. Team, Inc., 527 F. Supp. 2d 827 (N.D. Ill. 2007).
— 15 U.S.C. § 1679b(a)(1) — 4 cases
Karakus v. Wells Fargo Bank, N.A., 941 F. Supp. 2d 318 (E.D.N.Y 2013).
Hurley v. Navy Fed. Credit Union (N.D. Ill. 2024).
Arzate v. Awesome Life Grp., LLC (W.D. Pa. 2025).
United States v. Turbo Solutions Inc. (S.D. Tex. 2025).
— 15 U.S.C. § 1679b(a)(1)(B)(i) — 1 case
Hurley v. Navy Fed. Credit Union (N.D. Ill. 2024).
— 15 U.S.C. § 1679b(a)(2) — 2 cases
Fed. Trade Comm'n v. Gill, 183 F. Supp. 2d 1171 (C.D. Cal. 2001).
Kimmel v. Elderton State Bank (W.D. Pa. 2021).
— 15 U.S.C. § 1679b(a)(2)(B)(i1) — 1 case
Kimmel v. Elderton State Bank (W.D. Pa. 2021).
— 15 U.S.C. § 1679b(a)(2)(B)(ii) — 2 cases
Costa v. Mauro Chevrolet, Inc., 390 F. Supp. 2d 720 (N.D. Ill. 2005).
Poskin v. TD Banknorth, N.A., 687 F. Supp. 2d 530 (W.D. Pa. 2009). “15 U.S.C. § 1679b. The language of the statute indicates Congress intended that only consumers may pursue claims under those provisions of § 1679b.”
— 15 U.S.C. § 1679b(a)(3) — 24 cases
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “Plaintiff also contends that Defendants made untrue or misleading representations regarding their credit repair services in violation of 15 U.S.C. § 1679b(a)(3). 3 Final *495 ly, Plaintiff asserts a state law claim for unjust enrichment.”
Zimmerman v. Puccio, 613 F.3d 60 (1st Cir. 2010). “an attempt to commit [] a fraud or deception on any person in connection with the offer or sale of the services of the credit repair organization” under 15 U.S.C. § 1679b(a)(4).”
Fed. Trade Comm'n v. Gill, 71 F. Supp. 2d 1030 (C.D. Cal. 1999). “” 15 U.S.C. § 1679b(a)(3). Plaintiff argues that the elements needed to prove a violation of section 404(a)(3) of the CRO Act are analogous to those needed to prove a violation of Section 5 of the FTC Act prohibiting unfair or deceptive practices.”
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). “See 15 U.S.C. § 1679b(a)(3) (prohibiting the making or usage of "any untrue or misleading representation of the services of the credit repair organization”).”
Fed. Trade Comm'n v. Keith H. Gill Richard Murkey, 265 F.3d 944 (9th Cir. 2001). “False Representations As a preliminary matter, violation of the CRO Act’s prohibition against making or using any untrue or misleading representation of the services of the credit repair organization is not only a violation of the CRO Act, 15 U.S.C. § 1679b(a)(3), but also an…”
— 15 U.S.C. § 1679b(a)(4) — 10 cases
Zimmerman v. Puccio, 613 F.3d 60 (1st Cir. 2010). “an attempt to commit [] a fraud or deception on any person in connection with the offer or sale of the services of the credit repair organization” under 15 U.S.C. § 1679b(a)(4).”
Zimmermann v. Cambridge Credit Counseling Corp., 529 F. Supp. 2d 254 (D. Mass. 2008). “15 U.S.C. § 1679b(a)(4). The Puccios were certainly engaged in a “course of business .”
Poskin v. TD Banknorth, N.A., 687 F. Supp. 2d 530 (W.D. Pa. 2009). “15 U.S.C. § 1679b. The language of the statute indicates Congress intended that only consumers may pursue claims under those provisions of § 1679b.”
Baker v. Fam. Credit Counseling Copr., 440 F. Supp. 2d 392 (E.D. Pa. 2006). “15 U.S.C. § 1679b(a)(3). • Engaging, directly or indirectly, “in any act, practice, or course of business that constitutes or results in the commission of, or an attempt to commit, a fraud or deception on any person in connection with the offer or sale of the services of the…”
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “Plaintiff also contends that Defendants made untrue or misleading representations regarding their credit repair services in violation of 15 U.S.C. § 1679b(a)(3). 3 Final *495 ly, Plaintiff asserts a state law claim for unjust enrichment.”
— 15 U.S.C. § 1679b(a)(l) — 8 cases
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “Plaintiff also contends that Defendants made untrue or misleading representations regarding their credit repair services in violation of 15 U.S.C. § 1679b(a)(3). 3 Final *495 ly, Plaintiff asserts a state law claim for unjust enrichment.”
Fed. Trade Comm'n v. Keith H. Gill Richard Murkey, 265 F.3d 944 (9th Cir. 2001). “False Representations As a preliminary matter, violation of the CRO Act’s prohibition against making or using any untrue or misleading representation of the services of the credit repair organization is not only a violation of the CRO Act, 15 U.S.C. § 1679b(a)(3), but also an…”
Enriquez v. Countrywide Home Loans, FSB, 814 F. Supp. 2d 1042 (D. Haw. 2011).
Hayrioglu v. Granite Capital Funding, LLC, 794 F. Supp. 2d 405 (E.D.N.Y 2011).
Ware v. Indymac Bank, FSB, 534 F. Supp. 2d 835 (N.D. Ill. 2008).
— 15 U.S.C. § 1679b(a)(l)(A) — 1 case
Fed. Trade Comm'n v. Gill, 71 F. Supp. 2d 1030 (C.D. Cal. 1999). “” 15 U.S.C. § 1679b(a)(3). Plaintiff argues that the elements needed to prove a violation of section 404(a)(3) of the CRO Act are analogous to those needed to prove a violation of Section 5 of the FTC Act prohibiting unfair or deceptive practices.”
— 15 U.S.C. § 1679b(a)(l)(B)(ii) — 2 cases
Poskin v. TD Banknorth, N.A., 687 F. Supp. 2d 530 (W.D. Pa. 2009). “15 U.S.C. § 1679b. The language of the statute indicates Congress intended that only consumers may pursue claims under those provisions of § 1679b.”
Gaudie v. Potestivo Appraisal Servs., Inc., 837 F. Supp. 2d 799 (N.D. Ill. 2011).
— 15 U.S.C. § 1679b(b) — 28 cases
Hillis v. Equifax Consum. Servs., Inc., 237 F.R.D. 491 (N.D. Ga. 2006). “Plaintiff also contends that Defendants made untrue or misleading representations regarding their credit repair services in violation of 15 U.S.C. § 1679b(a)(3). 3 Final *495 ly, Plaintiff asserts a state law claim for unjust enrichment.”
Laverne Jones v. Bernaldo Dancel, 792 F.3d 395 (4th Cir. 2015). “See 15 U.S.C. § 1679b(a)(3) (prohibiting the making or usage of "any untrue or misleading representation of the services of the credit repair organization”).”
Plattner v. Edge Solutions, Inc., 422 F. Supp. 2d 969 (N.D. Ill. 2006). “In those cases, however, the plaintiff alleged violations of 15 U.S.C. § 1679b(a), which states that "[n]o person may” violate the provisions of that section; hence, the courts held that person is broader than credit repair organization, and that a finding that the defendant was…”
Fed. Trade Comm'n v. Keith H. Gill Richard Murkey, 265 F.3d 944 (9th Cir. 2001). “False Representations As a preliminary matter, violation of the CRO Act’s prohibition against making or using any untrue or misleading representation of the services of the credit repair organization is not only a violation of the CRO Act, 15 U.S.C. § 1679b(a)(3), but also an…”
Baker v. Fam. Credit Counseling Copr., 440 F. Supp. 2d 392 (E.D. Pa. 2006). “15 U.S.C. § 1679b(a)(3). • Engaging, directly or indirectly, “in any act, practice, or course of business that constitutes or results in the commission of, or an attempt to commit, a fraud or deception on any person in connection with the offer or sale of the services of the…”
— 15 U.S.C. § 1679b(l) — 1 case
Lopez v. ML 3, LLC, 607 F. Supp. 2d 1310 (N.D. Fla. 2009).
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