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StratFS, LLC f/k/a Strategic Financial Solutions, LLC, et al.

On January 10, 2024, the Bureau and seven state attorneys general—New York, Colorado, Delaware, Illinois, Minnesota, North Carolina, and Wisconsin—filed a complaint and sought a temporary restraining order and preliminary injunction against StratFS, LLC f/k/a Strategic Financial Solutions, LLC, as well as its holding company Strategic Family, Inc.; various of its subsidiaries: Strategic Client Support, LLC; Strategic CS, LLC; Strategic FS Buffalo, LLC; Strategic NYC, LLC; T Fin, LLC; BCF Capital, LLC; Strategic Consulting, LLC; Versara Lending, LLC; Anchor Client Services, LLC; Bedrock Client Services, LLC; Boulder Client Services, LLC; Canyon Client Services, LLC; Carolina Legal Services, LLC; Great Lakes Client Services, LLC; Guidestone Client Services, LLC; Harbor Client Services, LLC; Heartland Client Services, LLC; Monarch Client Services, LLC; Newport Client Services, LLC; Northstar Client Services, LLC; Option 1 Client Services, LLC; Pioneer Client Servicing, LLC; Rockwell Client Services, LLC; Royal Client Services, LLC; Stonepoint Client Services, LLC; Summit Client Services, LLC; Whitestone Client Services, LLC; Twist Financial, LLC; Duke Enterprises, LLC; and Blaise Investments, LLC (collectively, SFS); and as individuals: SFS Chief Executive Officer Ryan Sasson, Jason Blust, Daniel Blumkin, and Albert Ian Behar. The complaint also named the following relief defendants: Strategic ESOP; Strategic ESOT; The Blust Family Irrevocable Trust through Donald J. Holmgren, Trustee; Jaclyn Blust; Lit Def Strategies, LLC; and Relialit, LLC. SFS is a debt-relief company with offices in Buffalo and Manhattan, New York. In the First Amended Complaint filed on March 27, 2024, the Bureau alleges that since at least January 2016, SFS and the individual defendants have operated a debt-relief scheme that collects exorbitant, illegal advance fees from vulnerable consumers suffering financial difficulties through a web of interrelated companies they have created, including law firms, that serve as a facade for SFS’s debt-relief operation. The Telemarketing Sales Rule (TSR) prohibits charging and collecting fees before renegotiating the terms of at least one debt and before a payment is made under the renegotiated terms, as well as charging fee amounts that are not tied to the percentage of the enrolled debt settled or reduced or the amount saved. The TSR also prohibits making a false or misleading statement to induce any person to pay for goods or services as well as misrepresenting any material aspects of debt relief services. The Bureau alleges that the defendants violated, and substantially assisted violations of, these prohibitions. Specifically, under SFS’s direction, the web of companies induce consumers to sign up for debt-relief services using a bait and switch scheme that draws consumers in by offering a debt consolidation loan. Once consumers call SFS to inquire about the loan, SFS representatives push them towards purchasing debt relief services, which they misleadingly describe as the “0% interest” option. After making the sale, SFS begins debiting fees for the debt-relief services from consumers’ escrow accounts long before any of the consumers’ debts have been settled, and the fee amounts the companies collect are pre-determined and do not depend on any results the companies might obtain. As alleged in the complaint, since January 2016, defendants have collected at least $100,000,000 from consumers before any of the consumers’ debts were settled, and in some instances when no such settlements ever took place. The complaint seeks permanent and preliminary injunctive relief, redress for consumers, and a civil money penalty. On January 11, 2024 and March 4, 2024, the court granted the Bureau’s request for a temporary restraining order and preliminary injunction, respectively.


First Amended Complaint

Press release

CFPB and Seven State Attorneys General Sue Debt-Relief Enterprise, Strategic Financial Solutions, for Illegally Swindling More Than $100 Million from Financially Struggling Families