CRO Form – Organization for Consumer Credit Advocacy and Mediation

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We are OCCAM

A SAFE PLACE TO GET REAL HELP

OCCAM CR Company application

Company's legal name

Is this company a Law firm?

Yes

Company Type

Please provide your Company’s physical address, including city, state and zip code

(You must include all addresses where any work is going to be performed, clients will call or will be called from).

Provide all physical addresses which Company and staff utilize to make calls or to receive calls from consumers, use to conduct or will conduct business such as marketing or all other related company business with consumers and for consumers.

Please list all business names, trade names, fictitious business names and/or DBAs under or through which the Company has marketed or intends to market the services for which it seeks O.C.C.A.M. membership.

Primary business description

Description of all service and/or product offerings for which the Company seeks O.C.C.A.M. Membership.

Please list all website URLs your Company uses or intends to use to market its services and /or products for which the company seeks O.C.C.A.M. membership. (if you use a lead generation service or you purchase leads from third parties you must include their web address and any landing pages they use to generate leads for your company). Please state “N/A” for none or not applicable

URLs

Please provide at least 2 trade references that company has or is currently doing business with within the last year.

Business/Trade Reference	Contact Name	Contact’s Telephone Number

Bank Reference

Contact Name	Contact’s Telephone Number

Please provide a complete list all owners of the Company with 5% or more ownership interest in the Company and their identifying information

Full Name	Ownership %	Social Security Number	Date of Birth

Please provide the names and addresses of all banks and/or payment processors utilized by your Company during the preceding one year

Full Name	Address

Please briefly describe your consumer complaint intake and management system/process

Please provide the following data for the preceding two years

Total number of consumer complaints resolved with refunds

Total number of consumer complaints pending resolution

Has the Company and/or any of its owners with 5% or more ownership interest in the Company ever been the subject of an investigation or any legal action by any state or federal law enforcement agency?

Yes

If “Yes”, please provide additional details below

Does your company claim that it complies with the FTC’s Telemarketing Sales Rule – Debt Relief/Credit Repair Rule (“TSR”)?

Yes

If you answered “Yes” above, please complete the following sections and provide the requested information and documents.

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Please provide a detailed description as to why your Company’s model or practices comply with the TSR

Does your company claim to qualify with the face-to-face exemption pursuant to the FTC’s Telemarketing sales Rule -Debt Relief Rule (“TSR”)

Yes

Please provide a detailed description as to why your Company’s marketing acts or practices do not constitute Telemarketing, as defined by the TSR, or otherwise are not subject to the TSR:

Please describe how your Company conducts its face-to-face meetings, including a description of the content, length, location, and other circumstances surrounding the face-to-face meetings that are held with your Company’s potential clients

Does your Company utilize employees or independent contractors to conduct the face-to-face meetings

Employees

Independent Contractors

Both Employees and Independent Contractors

If your Company utilizes independent contractors to handle face-to-face meetings, please provide a list of all such independent contractors

Contractors

Please provide all materials utilized in the training of your Company representatives who conduct face-to-face meetings with prospective clients.

Please provide a list of all telephone Numbers used for inbound and outbound calls by company

Does company obtain background checks for Employees that have access to consumer sensitive data? Please elaborate

Does your company keep consumer files with sensitive information in locked file cabinets?

(Please explain security measures in place to secure sensitive data and documents).

Does your company keep consumer files with sensitive information in locked file cabinets?

(Please explain security measures in place to secure sensitive data and documents).

Does Company keep consumer files in an electronic format? And how do you keep them secure from non-authorized personal and outside threats?

(Please explain data security protocols).

Does Company keep all computer terminals secured with password encryption and network encryption?

IF company is a Law firm or any owner of company is an attorney, provide name of all attorneys, BAR Number, the States they are licensed to practice law, disclose any complaints relating to such attorneys and any nonconfidential information about the complaints or disciplinary proceedings against those attorneys.

Do you or your company comply with the CROA?

Yes

Describe your fee collection methodology (How and when fees are taken)

Describe your credit repair service and strategies used (General Overview)

Which states do you operate or sell your products?

List all social media accounts used by company

Do you or your company have a Compliance Management System?

Yes

Do you or your company have a policies and procedures manual or handbook?

Yes

Does your company use a CRM?

Yes

which CRM(s) do you currently use

List ALL secondary or service upsells currently being sold by your company

Please list your pricing below. If multiple options/services, please describe/list these

List any Certifications, awards or completion certificates held by company or officer

STATEMENT OF TRUTH AND ACKNOWLEDGMENTS

being duly sworn, say that I have read the foregoing Application and Know the contents thereof, and that the same are true; that the same contains a full and true account of the information requested; and that I executed the same freely and voluntarily and for the uses and purposes therein mentioned, and with the full knowledge that misrepresentation or failure to reveal information request may be deemed sufficient evidence for refusal to issue, revocation of, OCCAM Membership applied for and should membership applied for be granted, will abide by all city, county, state and federal laws, and fully understand that failure to do so may result in membership revocation proceedings and or penalties.

Further, I attest that:

I am the applicant who is submitting this application form.
I personally supplied the information contained in this form.
I understand and read the English language, or I have had an interpreter read, explain and record the answer to each question on this application form.
Any document accompanying this form that is not an original document is a certified copy of the original document.
I swear (or affirm) that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, or misleading they will be documented and could result in denial of OCCAM membership.
I understand that in case this application is withdrawn or denied, there shall be no refund of any investigation fees paid.
I agree to provide and disclose any information that reasonably relates to this application, the applicant’s qualifications, acceptability or fitness for OCCAM membership.

I do hereby agree that OCCAM may obtain information from my past and present employers, criminal justice agencies, financial institutions, Federal, State and local government agencies and other persons and entities and agree to release such information to OCCAM for use in connection with this application.

I do, for myself, my heirs, executors, administrators, successors and assigns, hereby release, remise and forever discharge OCCAM and its agents and employees from all manner of actions, claims and demands whatsoever, known or unknown, in all or equity, which I ever had, now have, may have to claim to have against OCCAM or its agents or employees, arising out of its use of the information provided in this application or discovered during any investigation thereof.

STATEMENT OF TRUTH AND ACKNOWLEDGMENTS SIGNATORY

I understand and agree to the above Statement of Truth and Acknowledgments

Full Name

Company Name

Date

This form must be completed in its entirety if any portion does not apply to your company, you must fill it with “N/A”, then forward to O.C.C.A.M. with the following documentation:

If you do not have or have not created any of the following items, please notate that and move to the next item.

A legible copy of a government issued ID for all owners holding at least 10% ownership in your Company (driver’s license/passport/military ID)
Sample copy of your Company’s current consumer agreement(s)
Sample copy of your Company’s current marketing materials
All consumer complaints and information relating to the resolution (if any) of such complaints, up to a maximum of the 200 most recent complaints, made by or on behalf of any Company customer and received by the Company in the preceding one year.
Certificate of Good Standing other or proof of current active status with the Secretary of State in all states in which your Company is registered to conduct business.
Copy of all business licenses required to operate on your city or State where you conduct business. 7. IF your company is an LLC, copy of LLC Operating agreement. If company is a C corporation or S corporation, a copy of the Bylaws to be reviewed.
A copy of company lease agreement for physical addresses that company operates from. 9. Copy of contracts if company uses third party lead generation company to market. 10. If company utilizes independent contractors for face to face meetings with prospective clients provide copy of current contracts with such contractors.
Provide a copy of all materials utilized in the training of your company employees. 12. Provide a copy of your telemarketing scripts for review, including FAQs, Rebuttals, and approved verbiage used for emails.
Provide a sample of all materials provided to prospective clients prior to their execution of an agreement with your company.
Provide a copy of company’s compliance management plan.

Purpose: OCCAM Alliance and (“Disclosing Party”) wishes to pursue a membership opportunity of mutual interest and in connection with this opportunity wish to execute this “Agreement”.

Confidential Information: Confidential Information means any information disclosed by one party to the other, either directly or indirectly in writing, orally or by inspection of tangible or intangible objects, including without limitation documents, business plans, source code, software, documentation, financial analysis, marketing plans, customer names, customer list, customer data. Confidential Information may also include information disclosed to a party by third parties at the direction of a Disclosing Party. Confidential Information shall not, however, include any information which the Receiving Party can establish;

(i) was publicly known and made generally available in the public domain prior to the time of disclosure;

(ii) becomes publicly known and made generally available after disclosure through no action or inaction of Receiving Party; or

(iii) is in the possession of Receiving Party, without confidentiality restrictions, at the time of disclosure by the Disclosing Party as shown by Receiving Party’s files and records immediately prior to the time of disclosure. The party disclosing the Confidential Information shall be referred to as “Disclosing Party” in the Agreement and the party receiving the Confidential Information shall be referred to as “Receiving Party” in the Agreement.

Non-use and Non-disclosure: The Receiving Party agrees not to use any Confidential Information for any purpose except to evaluate and engage in discussions concerning a potential business relationship between the parties hereto. Receiving Party agrees not to disclose any Confidential Information to third parties or to its employees, except to those employees who are required to have the information in order to evaluate or engage in discussions concerning the contemplated business relationship. The Receiving Party shall not reverse engineer, disassemble or decompile any prototypes, software or other tangible objects which embody the Disclosing Party’s Confidential Information and which are provided to the Receiving Party hereunder.
Maintenance of Confidentiality Information: The Receiving Party agrees that it shall take all reasonable measures to protect the secrecy of and avoid disclosure and unauthorized use of the Confidential Information. Without limiting the foregoing, Receiving Party shall take at least those measures that Receiving Party takes to protect its own most highly Confidential Information and shall have its employees, if any, who have access to Confidential Information sign a non-use and non disclosure agreement in content substantially similar to the provisions hereof, prior to any disclosure of Confidential Information to such employees. The Receiving Party shall not make any copies of Confidential Information unless the same are previously approved in writing by the Disclosing Party. The Receiving Party shall reproduce the Disclosing Party’s proprietary rights notices on any such approved copies, in the same manner in which such notices were set forth in or on the original. The Receiving Party shall immediately notify the Disclosing Party in the event of any unauthorized use or disclosure of the Confidential Information.
No Obligation: Nothing herein shall obligate either party to proceed with any transaction between them, and each party reserves the right, in its sole discretion, to terminate the discussions contemplated by this Agreement concerning the business opportunity.
No Warranty: ALL CONFIDENTIAL INFORMATION IS PROVIDED “AS IS”. NEITHER PARTY MAKES ANY WARRANTIES, EXPRESS, IMPLIED OR OTHERWISE, REGARDING ITS ACCURACY, COMPLETENESS OR PERFORMANCE.
Return of Materials: All documents and other tangible objects containing or representing Confidential Information and all copies thereof which are in the possession of Receiving Party shall be and remain the property of the Disclosing Party and shall be promptly returned to the Disclosing Party upon the Disclosing Party’s request.
No License: Nothing in this Agreement is intended to grant any rights to either party under any patent, mask work right or copyright of Company, nor shall this Agreement grant Receiving Party any rights in or to Confidential Information except as expressly set forth herein.
Term: This Agreement shall survive for a period of 3 years from the date of disclosure of the Confidential Information.
Remedies: The Receiving Party agrees that any violation or threatened violation of this Agreement will cause irreparable injury to the Disclosing Party, entitling the Disclosing Party to obtain injunctive relief in addition to all legal remedies.
Miscellaneous: This Agreement shall bind and inure to the benefit of the parties hereto and their successors and assigns. This Agreement shall be governed by the laws of Arizona, USA, without reference to conflict of laws principles. This document contains the entire agreement between the parties with respect to the subject matter hereof. Any failure to enforce any provision of this Agreement shall not constitute a waiver thereof or of any other provision hereof. This Agreement may not be amended, nor any obligation waived, except by a writing signed by both parties hereto. Any and all disputes arising under or related to this Agreement shall be mutually negotiated.

THIS NON-DISCLOSURE AGREEMENT (“Agreement”) is made and entered into as valid between OCCAM, it’s agents, contractors and advisors, (“Receiving Party”) and

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