Sample Questions - Credit Counseling


Applications for exemption and miscellaneous determination requests are assigned to Exempt Organizations specialists for review. If additional information is necessary to make a determination, a specialist will contact the organization for the information. Here’s a list of questions that might be asked on this topic.

  1. Provide the following about your interactions with clients:
    1. A list of the types of interactions with clients from the first encounter through the completion of the relationship with the client. For each interaction, state the name of each party involved (for example, your telemarketer, your service provider, you or any other party involved).
    2. A list of information you collect from clients before or during their initial interview with you.
    3. A description of your presentation to clients during the initial interview, including topics covered and options discussed.
    4. The criteria your employees use when choosing services for a client.
    5. The number of times you meet with a client before recommending an approach.
    6. Whether you provide all your clients with a written budget analysis.
  2. Submit the following documents relating to your client interactions:
    1. Client contracts for counseling services
    2. Client questionnaires used during the initial inquiry
    3. Prepared scripts used during the initial inquiry
    4. Sample copies of written budget analyses
    5. Material provided to clients who decline a counseling session or a debt management plan
    6. Lists of qualified assistance agencies or individuals that you provide to clients
  3. Describe in detail [workshops, classes or seminars on financial planning, budgeting, credit/debt relief or other educational programs] you offer to the public. For each program, provide:
    1. A list of past and scheduled sessions at which there were attendees; include fees charged
    2. A sample of the syllabi and all written materials
    3. If sessions were offered in partnership with other entities, the name of each entity, the terms of the partnership, and any limitations on attendees
  4. State whether you provide debt management plans (DMP) directly to clients. If so, provide a copy of a typical DMP customer contract.
  5. If you refer your debt management plan clients to another entity rather than provide the service directly, provide a copy of the customer referral and agreements between you and the client, and you and the entity you refer to. Additionally, describe contacts you have with clients once a referral has been made.
  6. State whether you include client accounts in a debt management plan if the creditor will not pay a fair share. If so, provide specific examples when this occurred and indicate the percentage of those accounts in your portfolio.
  7. Do you provide services to clients who are unable to pay? If so, describe your policies for those who don't have to pay, including the factors you rely on to make the determination. Show the percentage they represent to your total client base.
  8. For each year, list the following number of clients who:
    1. Completed your debt management plan (DMP) program
    2. Are continuing to participate in your DMP program
    3. Dropped out of your DMP program
  9. State whether you require participants in your debt management plan program to participate in ongoing educational programs during their plan. If so, describe that activity in detail.
  10. State whether your employees provide continuing assistance through telephone calls. If so, send a copy of the scripts they use. If they don't use scripts, describe the content of the calls.
  11. Send us samples of periodic assessments you perform during the duration of a debt management plan. G12. List all other individuals or organizations, including for-profit and nonprofit, with which you work or refer clients. State how you select them and send us copies of your contracts with them.
  12. Describe the business and personal relationships between you and the property owner of each facility you use to provide your services. Send us a copy of the lease for each facility.
  13. Provide the following information about your employees:
    1. A list of all categories of employees (for example, counselors, administrative or staff)
    2. The number of employees in each category
    3. A written description of each category
  14. Describe your employee compensation process. Include how you determine base compensation for all employees, bonuses or incentives, and how employees qualify for bonuses or incentives. If this system has changed since you began operations, please explain.
  15. Provide written agreements your employees must sign, including employment contracts.
  16. Describe the training or experience each counselor has and which training they received during their employment with you.
  17. State the average amount of time your counselors spend speaking with each client during the initial inquiry, subsequent calls, and after the client has enrolled in a debt management plan.
  18. Send us copies of your advertising materials such as:
    1. Flyers and letters distributed (or to be distributed) through printed media (for example, newspapers, magazines, local circulars), social media or internet advertising
    2. Current or prospective radio, television and phone call scripts
  19. Send us a list of internet sites on which you advertise or that you link to or plan to link to for advertising.
  20. State whether you receive referrals from banks, credit-offering entities, local service agencies or other organizations. If so, describe each referral arrangement and send us written documentation relating to the arrangement.
  21. State whether you buy or plan to buy “leads” or names of prospective clients. If so, provide:
    1. From whom you buy the lists
    2. The terms and conditions of your arrangements with the seller
    3. Copies of all contracts with each seller
    4. The seller's monthly fee
  22. State whether you sell “leads” to others. If so, indicate to whom and the price you charge. Provide copies of contracts with the buyers.
  23. Explain whether you charge a separate fee to improve a client's credit record, credit history or credit rating. If so, describe in detail what you do to improve credit records, histories or ratings.
  24. Describe how you allocate the client's first payment, which may include, for example, a set-up fee, service fee, contribution or debt service fee. Send copies of reports you provide clients showing how you allocate their initial fees.
  25. Explain if you solicit contributions from potential clients during the initial inquiry, subsequent counseling sessions, or at any other time during which they are receiving services from you.
  26. For each grant you received:
    1. State the source, amount and purpose of the grant
    2. Identify grants from lenders who participate in your programs
    3. Attach copies of grant requests and applications
  27. List the names and addresses of sources that gave you, or promised to give you, start-up funds, including the terms and conditions of each contribution.
  28. State whether you offer, or plan to offer, any additional services or products other than credit counseling, such as [loans, credit repair, credit negotiation, bankruptcy counseling or down payment assistance]. If so, list those services.
  29. Send us the following information about your past and present directors:
    1. The length of terms.
    2. The number of directors currently on your board.
    3. The number of directors with voting rights who are employed by you in a capacity other than director.
    4. A description of the financial benefits directors receive, either directly or indirectly, through your activities (excluding reasonable directors' fees). For each director who receives benefits, provide a description of the type of benefit they receive.
    5. A description of your directors’ special knowledge or expertise in credit or financial education.
    6. The names of directors who are public officials, acting in their official capacities as such, or are community leaders.
    7. Whether any directors are acting in their official capacity as a public official, such as from the federal, state or city government. If so, describe.
  30. Describe your relationship with each past or present board member, officer or key employee who:
    1. Served on the board of an organization with whom you do business
    2. Has an ownership interest in a for-profit entity that does business with you
    3. May be a disqualified person due to their relationship with either of the above
  31. State whether you applied for or obtained certification from the United States Trustee Program to be a nonprofit budget and credit counseling agency under the Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. If so, send a copy of the application and the ruling on the application or certification.
  32. Explain whether you have a 35% or more interest in any corporation, partnership or trust or estate that is in the trade or business of lending money, repairing credit or providing debt management plan services, payment processing or similar services. Don't include ownership interests in IRC Section 501(c)(3) organizations. Provide the organizations’ or individuals' names and describe the relationship.
  33. State whether you or members of your governing body have ever been the subject of an investigation, complaint or lawsuit by any of the following entities:

    • State Attorney General
    • State Office of Consumer Protection
    • Better Business Bureau
    • Federal Trade Commission
    • Department of Housing and Urban Development
    • Any other local, state or federal agency

    If so, describe the issue. State where and when it was started and describe the result.

Additional information

See the complete list of Applying for Exemption/Miscellaneous Determination Sample Questions by topic.