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a “credit repair” program. The Ultimate Comeback offered three
“phases” for the marketing and sale of the Credit Maze.
The Ultimate Comeback’s orientation guide states that in
order to be a member in phase I an interested party paid $1,250
plus a $50 administrative fee for a copy of the Credit Maze
product. The broker2 for the phase I member received 90 percent
of the $1,250 payment.
The Ultimate Comeback’s orientation guide states that in
order to be a member in phase II, an interested party paid $6,250
plus a $75 administrative fee for a seminar related to the Credit
Maze. The broker3 for the phase II member received 90 percent of
the $6,250 payment.
The Ultimate Comeback’s orientation guide states that in
order to be a member in phase III, an interested party paid
$31,250 for a financial education seminar in Hawaii. The broker4
for the phase III member received 90 percent of the $31,250
payment.
Not all new phase I, II, and III members paid the amounts
listed in the orientation guide. Everyone who transferred from
2 In order to be a phase I broker, a member had to recruit
six additional phase I members.
3 In order to be a phase II broker, a member had to recruit
six additional phase II members.
4 In order to be a phase III broker, a member had to
recruit two additional phase III members.
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Last modified: May 25, 2011