Short answer
The Telemarketing Sales Rule is the FTC regulation that governs debt relief services sold by phone. Since 2010 it has banned charging a fee before a debt is settled, required specific disclosures, and set rules for dedicated accounts. The 2024 amendments extended recordkeeping to five years and added call-detail, consent and do-not-call records.
Telemarketing Sales Rule (TSR) explained
For a debt settlement firm the TSR sets three operating constraints. Fees can only be collected after a settlement is reached, the client has agreed to it and at least one payment has been made to the creditor. Client funds must sit in a dedicated account the client controls. And records of calls, consents, disclosures and payments must be kept, now for five years rather than two.
In a CRM this means fees should be tied to settlement records in the data model, consent and disclosures should live on the client record, and call records should be retained and auditable. Salesforce Shield's field audit trail and event monitoring are the usual tools for the audit side.
How Vantage Point helps: we design debt settlement data models where fees cannot post before the settlement they belong to and where the compliance record is attached to the client.
Frequently asked questions
Does the TSR apply if clients come from the web rather than phone calls?
Most debt settlement sales involve a phone conversation at some point, which brings the sale under the TSR. Firms generally design to the TSR regardless of lead source.
What changed in the 2024 TSR amendments?
Recordkeeping went from 24 months to five years, the list of required records grew to include call-detail records, prerecorded messages, consent and do-not-call records, and business-to-business calls came under the misrepresentation rules.