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

15 U.S.C. § 1679f

Noncompliance with this subchapter

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(a) Consumer waivers invalidAny waiver by any consumer of any protection provided by or any right of the consumer under this subchapter—(1) shall be treated as void; and(2) may not be enforced by any Federal or State court or any other person.(b) Attempt to obtain waiver

Any attempt by any person to obtain a waiver from any consumer of any protection provided by or any right of the consumer under this subchapter shall be treated as a violation of this subchapter.

(c) Contracts not in complianceAny contract for services which does not comply with the applicable provisions of this subchapter—(1) shall be treated as void; and(2) may not be enforced by any Federal or State court or any other person.(Pub. L. 90–321, title IV, § 408, as added Pub. L. 104–208, div. A, title II, § 2451, Sept. 30, 1996, 110 Stat. 3009–459.)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 19 cases (5 in the last 5 years), 2005–2026 · leading case: Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010).
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Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). · cites it 26× “However, the plain text of 15 U.S.C. § 1679f encompasses waivers of "any protection" or "any right" under the CROA-categories which are much broader than mere noncompliance.”
Gay v. CreditInform, 511 F.3d 369 (3d Cir. 2007). · cites it 3× “15 U.S.C. § 1679f. Gay also refers to the CSA anti-waiver provision which provides: (a) Waiver&emdash;Any waiver by a buyer or borrower of the provisions of this act shall be deemed contrary to public policy and shall be void and unenforceable.”
Alexander v. U.S. Credit Mgmt., Inc., 384 F. Supp. 2d 1003 (N.D. Tex. 2005). · cites it 5× “15 U.S.C. § 1679f(a). It is notable that the statute provides for avoiding both discrete components of a contract (i.”
James Robertson, Sr. v. Intratek Comput., 976 F.3d 575 (5th Cir. 2020). “” 15 U.S.C. § 1679f(a). Nonetheless, the Court rejected the notion that CROA “provide[d] consumers with a ‘right’ to bring an action in court.”
Reynolds Ex Rel. Est. of Picard v. Credit Solutions, Inc., 541 F. Supp. 2d 1248 (N.D. Ala. 2008). · cites it 3× “15 U.S.C. § 1679f(a) (emphasis added). Based on these two sections, Picard argues that she has a right to sue under CROA that cannot be waived.”
Picard v. Credit Solutions, Inc., 564 F.3d 1249 (11th Cir. 2009). “15 U.S.C. § 1679f(a). Whether CROA prohibits arbitration is an issue of first impression in this Court.”
Zimmermann v. Cambridge Credit Counseling Corp., 529 F. Supp. 2d 254 (D. Mass. 2008). “Plaintiffs also argue that the disclaimer in the Service Agreement stating that "[t]he CLIENT’S credit rating is outside of the scope of this Agreement” constituted an attempt to get consumers to waive their CROA protections in contravention of 15 U.S.C. § 1679f(b). The court…”
Taylor-Burns v. AR Resources, Inc., 268 F. Supp. 3d 592 (S.D.N.Y. 2017). · cites it 2× “15 U.S.C. § 1679f(c). The CS360 Agreement' failed to comply with the ‘following provisions of the CROA: • Failure to include the required written statement with the contract as " set forth in'15 U.”
Greenwood v. Compucredit Corp., 617 F. Supp. 2d 980 (N.D. Cal. 2009). · cites it 4× “15 U.S.C. § 1679f (a). In Green Tree, the Supreme Court considered whether claims under the Truth in Lending Act (TILA) were arbitrable.”
Polacsek v. Debticated Consum. Counseling, Inc., 413 F. Supp. 2d 539 (D. Md. 2005). “See 15 U.S.C. § 1679f(b). 6 . In fact, the Court has been advised that since this litigation began, the IRS determined that AmeriDebt's § 501(c)(3) status should be revoked.”
Rex v. CSA-Credit Solutions of Am., Inc., 507 F. Supp. 2d 788 (W.D. Mich. 2007). “One of the required disclosures is: You have a right to sue a credit repair organization that violates the Credit Repair Organization Act. This law prohibits deceptive practices by credit repair organizations.”
Barnes v. FGL Clearwater, Inc. (In Re Barnes), 397 B.R. 149 (Bankr. N.D. Ala. 2008). “15 U.S.C. § 1679f(a). There are only four rights expressly identified within the CROA Act and those rights are listed in § 1679c, entitled “Disclosures.”
Show all 19 citing cases →
15 U.S.C. § 1679f(a): 10 cases
Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). “However, the plain text of 15 U.S.C. § 1679f encompasses waivers of "any protection" or "any right" under the CROA-categories which are much broader than mere noncompliance.”
Alexander v. U.S. Credit Mgmt., Inc., 384 F. Supp. 2d 1003 (N.D. Tex. 2005). “15 U.S.C. § 1679f(a). It is notable that the statute provides for avoiding both discrete components of a contract (i.”
James Robertson, Sr. v. Intratek Comput., 976 F.3d 575 (5th Cir. 2020). “” 15 U.S.C. § 1679f(a). Nonetheless, the Court rejected the notion that CROA “provide[d] consumers with a ‘right’ to bring an action in court.”
Picard v. Credit Solutions, Inc., 564 F.3d 1249 (11th Cir. 2009). “15 U.S.C. § 1679f(a). Whether CROA prohibits arbitration is an issue of first impression in this Court.”
Reynolds Ex Rel. Est. of Picard v. Credit Solutions, Inc., 541 F. Supp. 2d 1248 (N.D. Ala. 2008). “15 U.S.C. § 1679f(a) (emphasis added). Based on these two sections, Picard argues that she has a right to sue under CROA that cannot be waived.”
15 U.S.C. § 1679f(a)(1): 1 case
Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). “However, the plain text of 15 U.S.C. § 1679f encompasses waivers of "any protection" or "any right" under the CROA-categories which are much broader than mere noncompliance.”
15 U.S.C. § 1679f(b): 4 cases
Greenwood v. CompuCredit Corp., 615 F.3d 1204 (9th Cir. 2010). “However, the plain text of 15 U.S.C. § 1679f encompasses waivers of "any protection" or "any right" under the CROA-categories which are much broader than mere noncompliance.”
Zimmermann v. Cambridge Credit Counseling Corp., 529 F. Supp. 2d 254 (D. Mass. 2008). “Plaintiffs also argue that the disclaimer in the Service Agreement stating that "[t]he CLIENT’S credit rating is outside of the scope of this Agreement” constituted an attempt to get consumers to waive their CROA protections in contravention of 15 U.S.C. § 1679f(b). The court…”
Polacsek v. Debticated Consum. Counseling, Inc., 413 F. Supp. 2d 539 (D. Md. 2005). “See 15 U.S.C. § 1679f(b). 6 . In fact, the Court has been advised that since this litigation began, the IRS determined that AmeriDebt's § 501(c)(3) status should be revoked.”
Harris v. My Credit Guy LLC, 763 F. Supp. 3d 845 (D. Ariz. 2025).
15 U.S.C. § 1679f(c): 7 cases
Gay v. CreditInform, 511 F.3d 369 (3d Cir. 2007). “15 U.S.C. § 1679f. Gay also refers to the CSA anti-waiver provision which provides: (a) Waiver&emdash;Any waiver by a buyer or borrower of the provisions of this act shall be deemed contrary to public policy and shall be void and unenforceable.”
Taylor-Burns v. AR Resources, Inc., 268 F. Supp. 3d 592 (S.D.N.Y. 2017). “15 U.S.C. § 1679f(c). The CS360 Agreement' failed to comply with the ‘following provisions of the CROA: • Failure to include the required written statement with the contract as " set forth in'15 U.”
Alexander v. U.S. Credit Mgmt., Inc., 384 F. Supp. 2d 1003 (N.D. Tex. 2005). “15 U.S.C. § 1679f(a). It is notable that the statute provides for avoiding both discrete components of a contract (i.”
Reynolds Ex Rel. Est. of Picard v. Credit Solutions, Inc., 541 F. Supp. 2d 1248 (N.D. Ala. 2008). “15 U.S.C. § 1679f(a) (emphasis added). Based on these two sections, Picard argues that she has a right to sue under CROA that cannot be waived.”
Parrott v. Gemini Direct, LLC, No. 3:23-cv-00593 (W.D. Ky. Feb. 15, 2024).
15 U.S.C. § 1679f(c)(1): 1 case
Merchants Credit Corp., V. Litig. Practice Grp. P.c., No. 84104-1 (Wash. Ct. App. Dec. 30, 2024).
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