Best Practices Guidelines

The following "Best Practices Guidelines" of AAA Fair Credit Foundation (FCF) are to ensure integrity, fairness and professionalism in the delivery of our services.

I. LEGAL STATUS

1. The organization is a registered 501(c)(3) tax-exempt not-for-profit organization.
2. The organization shall maintain all applicable licensing, registration, bonding and statutory requirements in states where business is conducted.
3. The organization shall maintain an independent Board of Directors, the majority of which cannot be employees, or related to other board members or employees of the organization.

II. ACCESS AND AVAILABILITY

We shall extend our services to all who request assistance without respect to any legally protected status, age, creed, color, sex, sexual orientation, marital or financial status, religion or other considerations of the applicant. We provide access to services within a reasonable period of time after a request for such services is received and at times and through venues that are convenient to the general public.

III. FINANCIAL COUNSELING

1. Counselors must be properly trained and qualified to provide clients with a quality financial education experience.
2. Counselors must be certified by an independent certification organization within 6 months of the date of hire.
3. Counselors shall provide a comprehensive, one-on-one money management counseling interview following a prospective client's request for counseling services, and provide a written assessment and action plan to the client as applicable to the service provided.
4. Counselor compensation cannot be based on outcome of counseling process.
5. A complete budget assessment with review of income, expenses, and debt must be conducted prior to submission of creditor proposals or creditor mediation is initiated.
6. The organization requires all lines of credit be closed upon implementation of a Debt Management Plan and that no future lines of credit be obtained without prior consent or approval from FCF.
7. The organization does not provide cease and desist notices on any consumer's behalf.

IV. SERVICE FEES AND CONTRIBUTIONS

1. All services are available to the public regardless of a consumers inability to pay service fees and at no time should a person be refused service due to an inability to pay.
2. Any fees charged for services rendered are fair and reasonable and in accordance with applicable state laws.
3. The organization does not solicit contributions from consumers during the initial counseling process or while the consumer is receiving services from the organization.

V. EDUCATION

1. The organization provides community resources for educational materials and information concerning personal finance and debt-related issues.
2. The organization shall allocate a reasonable percentage of operating expenses to develop, foster and/or provide a variety of consumer educational programs (beyond counseling) on money management, budgeting, home buyer education, and the wise use of credit.

VI. ACCREDITATION

FCF is accredited by an industry approved third-party; BSI (ISO 9001:2000 and Sector Certification for Consumer Credit Counseling). FCF is re-certified semi-annually through regularly scheduled surveillance audits. FCF is also an accredited business member with the Better Business Bureau (BBB).

VII. FISCAL INTEGRITY

1. All financial books and records of all accounts shall be audited annually by an independent certified public accounting firm and in accordance with auditing standards generally accepted in the United States of America and by the reporting guidelines of Statement of Financial Accounting Standards (SFAS) No. 117, Financial Statements of Not-For-Profit Organizations. Tests of compliance and evaluation of controls associated with this audit are to be applied to client deposits and activity as well as the operating accounts and statements of the members, and shall be noted by the auditor(s).
2. The organization shall exercise diligence in their fiduciary capacity as custodians of client funds entrusted to them. Client funds are deposited into a separate trust account(s) and segregated from general operating account funds. Client funds will be deposited in a federally insured financial institution.
3. The organization shall carry adequate insurance coverage and be bonded in an amount appropriate to cover potential loss.

VIII. RECORD RETENTION
We shall maintain a record of all client trust activity, client contracts and correspondence and other documents directly related to the servicing of client accounts for a period of at least six years after the date of the final financial transaction performed in an individual client account or for such longer period as may be otherwise required by law. A record may be made in any tangible physical or electronic form.

IX. BUSINESS PRACTICES

1. The organization shall not engage in deceptive or false advertising and in all cases will adhere to the highest standards of honesty and fairness.
2. The organization does not make loans or negotiate making loans.
3. Debt Management Plans should be established only when they are appropriate, and advantageous to the client. No client will be refused a DMP for minimum balances owed to creditors. No creditor will be excluded from a DMP unless it is beneficial to the client.
4. Any materials discussing Debt Management Plans (DMP's) shall include a disclosure regarding FCF's dual role in serving the needs of consumers and creditors. DMP's are voluntary programs that facilitate this dual role by helping consumers repay their debts and helping creditors receive the money owed to them.
5. Prior to receipt of a client's first deposit for enrollment into a DMP, FCF shall provide each client with a reliable estimate of the length of time it will take to complete the plan. This must be provided in writing and identify all creditors included in the plan, the total debt owed, the proposed payment to each creditor, and the anticipated number of months to liquidate the debt. Client funds received for a DMP must be disbursed to the designated creditors no later than 15 days from receipt of valid funds, or by scheduled disbursement date, whichever is greater.
6. The organization will prorate all accounts which assures no creditor receives preferential treatment in return for financial support.
7. On an annual basis, there will be an internal audit of the agency's operating practices to ensure compliance with these standards. Among other things, the audit will confirm the quality of counseling services delivered (as evidenced by quality assurance reports), as well as ensure the agency consistently conducts thorough client financial analyses, screens clients in order to make appropriate debt management plan recommendations, and conducts regular internal quality reviews to ensure a comprehensive counseling process during and after the counseling session.
8. The organization shall carry adequate D&O, E&O and employee dishonesty insurance with appropriate limits.

X. CUSTOMER COMPLAINT RESOLUTION

All complaints shall be researched and responded to within five (5) business days of receipt of the complaint.

XI. CORPORATE GOVERNANCE

1. To ensure broad-based, non-discriminatory community representation, FCF shall have a diverse, voluntary governing board. No family members or blood relation of the personnel of FCF can serve on the governing board.
2. The organization maintains a quality managemnt system and shall be audited but an independent, certified accredidation organization for compliance with applicable quality management standards.
3. The organization enforces a conflict of interest policy for employees and governing board members.