The CROA defines an 'upfront fee' as any payment requested before the company has fully performed the services they promised in your contract. This includes:
- Setup fees
- Initial consultation charges
- Monthly payments billed before any dispute work is completed
Example: If a company charges you to 'open your file' before sending any disputes or providing any documentation, that is considered an illegal upfront fee.
Table: Legal vs. Illegal Credit Repair Fees
| Fee Type | Legal? | When Can It Be Charged? |
| Setup/Enrollment Fee | No | Never before services are done |
| Monthly Service Fee | Yes* | Only after that month’s work |
| Pay-Per-Deletion Fee | Yes | Only after item is removed |
| Consultation Fee | No | Never before services are done |
*Monthly fees must be billed after the company completes that month’s work—not before.