Last reviewed: 15 October 2026

Can credit repair companies charge upfront fees?

Short answer: No. Under the federal Credit Repair Organizations Act, a credit repair company can't charge or take payment for a service until that service has been fully performed (15 U.S.C. § 1679b(b)).

Is a "setup" or "first work" fee legal?

If it's charged before the promised work is done, it falls within that ban. Calling it something else doesn't make it allowed.

What if I signed up over the phone?

The FTC's Telemarketing Sales Rule goes further. The seller can't ask for or take payment until (i) the time frame it promised for the services has passed, and (ii) it has given you a consumer report, issued more than six months after the results were achieved, showing those results (16 CFR 310.4(a)(2)). In CFPB v. Progrexion, the federal court in Utah ruled on March 10, 2023 that the defendants violated the TSR's ban on upfront fees. A stipulated final judgment was entered on August 30, 2023.

What other rights do I have?

• No false promises. Misleading claims about the services are prohibited (§ 1679b(a)).
• A written contract and a 3-day right to cancel. You can cancel before midnight of the 3rd business day after the day you sign the contract (§ 1679e; written contract, § 1679d).

Red flags

1. A fee charged before any work is delivered. 2. A promise of a specific score jump or "guaranteed deletion." 3. Advice to dispute information you know is accurate, or to create a "new credit identity." 4. No written contract, or no cancellation notice.

Can I do it myself for free?

Yes. You can dispute errors directly with each credit bureau at no cost. You can also check your report from each of the three bureaus once a week for free at AnnualCreditReport.com.

How we check companies

We check every company against these rules on our standard. We don't name companies that fail; see the Register. Request a review. Reviews are free, and requesting one doesn't guarantee we'll review, list or pass a company.

Identical to guides/croa-upfront-fees.md (accessed Oct 14 2026):

• 15 U.S.C. §§ 1679b, 1679d (LII, Oct 14 2026); § 1679e: https://www.law.cornell.edu/uscode/text/15/1679e (accessed Oct 15 2026)
• https://www.ecfr.gov/current/title-16/part-310/section-310.4
• https://www.consumerfinance.gov/enforcement/actions/pgx-holdings-inc/
• ECF 508 and ECF 600, via the Wayback URLs in the source guide
• https://consumer.ftc.gov/articles/free-credit-reports

References

1. [1] 15 U.S.C. § 1679e (LII; accessed 2026-10-15). https://www.law.cornell.edu/uscode/text/15/1679e
2. [2] 15 U.S.C. § 1679b (LII; accessed 2026-10-14). https://www.law.cornell.edu/uscode/text/15/1679b
3. [3] 16 CFR 310.4, Telemarketing Sales Rule (eCFR; accessed 2026-10-14). https://www.ecfr.gov/current/title-16/part-310/section-310.4
4. [4] CFPB enforcement action, PGX Holdings / Progrexion (accessed 2026-10-14). https://www.consumerfinance.gov/enforcement/actions/pgx-holdings-inc/
5. [5] FTC, Free Credit Reports (accessed 2026-10-14). https://consumer.ftc.gov/articles/free-credit-reports