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Federal Credit Repair Organizations Act
Missouri state law provides, in sections 407.638(1) and 407.639, that advance fees may be collected if a bond or letter of credit is posted. Stated differently, if you post the bond or letter of credit and charge advance fees, you will not violate Missouri law. However, you should be aware that the Federal “Credit Repair Organizations Act” explicitly prohibits charging any advance fees prior to the services being fully completed and no exception is made whether a bond is posted or not. We do not offer an opinion whether your proposed arrangement is an advance fee within the meaning of federal law but we do note that should your actions be found to violate the federal law, those actions might be found to be unfair and deceptive practices per Chapter 407 RSMo.
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