What Are the Penalties for Companies That Break Credit Repair Laws?
Written by Mark Clayborne
Last updated on May 19, 2026
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Companies that break credit repair laws face consequences under three separate frameworks: civil liability under the Credit Repair Organizations Act (CROA, 15 U.S.C. 1679 et seq.), enforcement actions by the Federal Trade Commission under the FTC Act and Telemarketing Sales Rule, and federal criminal prosecution for fraud.
Under CROA Section 1679g, any consumer harmed by a violation can sue in federal court and recover actual damages, punitive damages, and attorney’s fees.
The FTC can impose civil penalties up to $51,744 per TSR violation, seek permanent injunctions, and ban companies and their principals from the credit repair industry entirely.
State attorneys general hold independent enforcement authority under CROA Section 1679h. The penalties for breaking credit repair laws are not administrative inconveniences.
They are seven-figure restitution orders, lifetime industry bans, asset forfeitures that reach personal real estate and vehicles, and federal prison sentences.
The credit repair entrepreneurs who avoid these consequences are almost always those who understood the regulatory framework before they took on their first client, not those who tried to learn compliance after a problem had already materialized.
This guide covers every penalty category the law creates, the specific violations that trigger each one, and the operational decisions that separate a compliant credit repair business from one that draws regulatory attention.
What Laws Govern Credit Repair Companies in the United States?
Five federal laws govern credit repair companies operating in the United States. The Credit Repair Organizations Act (CROA, 15 U.S.C. 1679 et seq.) is the primary statute. The FTC Act (15 U.S.C. 45) prohibits unfair and deceptive practices.
The Telemarketing Sales Rule (TSR, 16 C.F.R. 310.4(a)(2)) bars advance fees for telemarketed credit repair services. The Fair Credit Reporting Act (FCRA, 15 U.S.C. 1681 et seq.) governs the dispute procedure. State Credit Services Organization (CSO) laws add requirements on top of the federal framework in most states.
Every credit repair company in the United States must comply with all applicable federal laws simultaneously. They do not operate independently.
A single violation, such as collecting a fee before services are performed, can trigger liability under both CROA and the TSR, creating two separate enforcement risks from one decision. Understanding how those frameworks overlap is the foundation of compliant credit repair operations.
| Law | Citation | What It Governs | Enforced By |
|---|---|---|---|
| Credit Repair Organizations Act (CROA) | 15 U.S.C. 1679 et seq. | Disclosures, written contracts, advance fee prohibition, civil liability for violations | FTC |
| FTC Act | 15 U.S.C. 45 | Unfair or deceptive acts and practices; false advertising; unverifiable outcome claims | FTC |
| Telemarketing Sales Rule (TSR) | 16 C.F.R. 310.4(a)(2) | Advance fee prohibition for telemarketed credit repair; civil penalties up to $51,744 per violation | FTC |
| Fair Credit Reporting Act (FCRA) | 15 U.S.C. 1681 et seq. | Dispute procedures, bureau investigation timelines, furnisher obligations, consumer rights to accurate reporting | FTC + CFPB |
| State CSO Laws | Varies by state | Surety bond requirements, state registration, state-specific contract language beyond CROA in TX, GA, FL, CA, and others | State AG |
CROA was enacted in 1996 because Congress found that credit repair companies were routinely charging large upfront fees, making false promises about removing accurate negative information, and leaving consumers financially worse off than they started.
The law applies to any person or business that uses interstate commerce to sell services claiming to improve a consumer’s credit record for payment, regardless of how those services are marketed. Courts have interpreted that definition broadly, capturing mortgage brokers, auto dealers, and law firms that bundle credit repair into other service offerings.
What Are the Penalties for Violating the Credit Repair Organizations Act?
CROA Section 1679g establishes three categories of civil penalties for violations. A consumer can recover actual damages, which the statute defines as the greater of real harm sustained or the full amount paid to the credit repair company.
Punitive damages are available in amounts the court determines for individual actions, with class action aggregate amounts reaching the full extent of consumer harm across all class members. Prevailing consumers automatically recover attorney’s fees and court costs.
There is a five-year statute of limitations from the date of each violation under CROA Section 1679f. The structure of CROA’s civil liability provision under 15 U.S.C. 1679g is one of the most consumer-favorable frameworks in federal law.
The actual damages provision does not require the consumer to prove harm beyond the money they paid. A client who paid $1,500 in illegal advance fees and received nothing can recover $1,500 automatically as actual damages, regardless of whether they can document additional injury. Punitive damages and attorney’s fees are layered on top of that baseline.
| Penalty Type | Statutory Basis | What It Means For Credit Repair Companies |
|---|---|---|
| Actual Damages | 15 U.S.C. 1679g(a)(1) | The greater of real harm sustained or the full amount paid to the company. Consumers recover the entire fee paid even without proving additional injury beyond the payment itself. |
| Punitive Damages (Individual) | 15 U.S.C. 1679g(a)(2)(A) | Court-determined additional amount based on frequency of noncompliance, intentional nature of the violation, and number of consumers affected. |
| Punitive Damages (Class Action) | 15 U.S.C. 1679g(a)(2)(B) | Aggregate amount across all named plaintiffs plus all class members. Class actions against companies with systematic violation patterns regularly reach seven figures. |
| Attorney's Fees | 15 U.S.C. 1679g(a)(3) | Prevailing consumers automatically recover court costs and reasonable attorney's fees. This provision makes individual lawsuits financially viable even when actual damages are modest. |
| Statute Of Limitations | 15 U.S.C. 1679f | Five years from the date the specific violation occurred. The clock starts on the act, not on the date the consumer discovered the problem. |
Courts have confirmed that CROA’s damages framework reaches well beyond simple fee restitution. In Taylor v. United Credit Management Corp., a court awarded punitive damages against a company with a documented pattern of advance fee violations, finding that repeated intentional misconduct warranted additional financial consequences above actual damages. In Hill v.
Homeward Residential, Inc., a court acknowledged that emotional harm and reputational damage qualify as actual damages under consumer protection law. Credit repair companies facing CROA lawsuits are not dealing with a theoretical penalty framework. They are dealing with one that courts apply broadly.
Can Consumers Sue a Credit Repair Company for CROA Violations?
Yes. CROA Section 1679g grants any consumer harmed by a credit repair law violation the right to sue in federal court without waiting for the FTC or a state attorney general to act first. A successful lawsuit entitles the consumer to actual damages, punitive damages, and mandatory attorney’s fees.
The private right of action under CROA is independent of government enforcement, which means a consumer can file suit whether or not regulators have taken any action against the company.
The private right of action under CROA is structured specifically to make individual lawsuits financially viable. Because attorney’s fees are mandatory for prevailing consumers under Section 1679g(a)(3), a consumer who paid $800 in illegal advance fees can file suit knowing that if the case succeeds, the company will cover their legal costs.
That fee-shifting provision is why consumer protection attorneys take CROA cases on contingency, and why individual claims with modest damage amounts still create substantial legal risk for non-compliant credit repair companies.
Class action lawsuits become available when the same violation pattern harmed a group of consumers through the same company’s conduct. A credit repair company that collected illegal advance fees from 200 clients over two years has created a potential class of 200 plaintiffs.
The aggregate actual damages across that class, before punitive damages and attorney’s fees are added, could exceed $300,000 on a $1,500 average fee alone. That is the financial exposure created by a single systematic compliance failure.
The steps that produce the strongest outcome for a consumer filing a CROA lawsuit are: document every interaction, including the contract or evidence that no contract was provided, all payment receipts, all communications, and any marketing materials that made specific promises.
File with the FTC at reportfraud.ftc.gov and with the state attorney general to create a regulatory record. Consult a consumer protection attorney. File in federal district court within five years of the violation date.
What Happens When a Credit Repair Company Charges Upfront Fees Illegally?
When a credit repair company charges upfront fees illegally, it violates two separate federal laws at the same time: CROA Section 1679b(b) and the Telemarketing Sales Rule Section 310.4(a)(2). The consumer can recover the full amount paid as actual damages under CROA Section 1679g regardless of whether other harm occurred.
The FTC can impose civil penalties up to $51,744 per TSR violation, with each individual advance fee charged counted as a separate violation. Companies with a pattern of advance fee violations face both consumer class actions and FTC enforcement simultaneously.
The advance fee prohibition is the most commonly violated provision in credit repair law, and it is also the most clearly stated. CROA Section 1679b(b) says explicitly that no credit repair organization may charge or receive any money before fully performing the services the company agreed to provide.
The TSR reinforces this for any credit repair services marketed through telephone or online contact. A company that charges at enrollment, before any dispute round has been completed, has violated both laws with that single transaction.
The consumer’s recovery under this violation is straightforward. CROA Section 1679g(a)(1)(B) sets the recovery floor at the full amount paid, regardless of what services were eventually delivered. A company cannot reduce a consumer’s actual damages by arguing partial performance.
If the fee was collected before the contracted services were fully performed, the consumer is entitled to recover it in full. Client Dispute Manager Software addresses the advance fee prohibition through billing architecture rather than through operator memory.
The platform generates invoices when a dispute round closes, not when a client enrolls. That billing trigger is tied to service completion by the platform’s workflow design, which means the TSR and CROA requirement is enforced by the sequence of the system rather than by requiring the operator to manually time each payment.
Credit repair business owners who use Client Dispute Manager Software cannot inadvertently collect an advance fee because the invoice does not exist until the work is done.
What Are the FTC Penalties for Credit Repair Violations?
The FTC enforces credit repair laws through three statutes that create escalating consequences. Under the FTC Act Section 53(b), the agency can seek preliminary and permanent injunctions in federal court. Under TSR Section 310.4(a)(2) and 16 C.F.R. 1.98(d), it can impose civil penalties up to $51,744 per violation.
Under CROA Section 1679h, the FTC is designated as the primary federal enforcement agency for credit repair law violations, with authority to pursue legal actions against companies and their individual principals.
FTC enforcement against credit repair companies operates through a three-tier system that most operators do not fully understand until they are already inside it.
The operators who navigate regulatory contact without permanent consequences are almost always those who responded correctly at the first tier rather than waiting to see what happened.
| Enforcement Tier | Ftc Action | What Happens And What It Means |
|---|---|---|
| Tier 1 | Warning Letter | FTC contacts the company in writing, identifies the specific violations, and requests corrective action. Most companies comply immediately. The letter is a public record and signals an active investigation file has been opened. |
| Tier 2 | Federal Court Action | FTC files a complaint in federal district court seeking injunctive relief and consumer restitution. Court orders require cessation of violations, payment of restitution funds to harmed consumers, and disgorgement of revenues. Judgments in the millions of dollars are common at this tier. |
| Tier 3 | Permanent Industry Ban | Court permanently enjoins the company and its named individual principals from operating in credit repair. Asset forfeiture includes cash, vehicles, real estate, and other personal property. Bans extend to individuals and survive corporate dissolution. |
The Financial Education Services enforcement action completed in 2024 is the clearest recent illustration of Tier 3 outcomes. The FTC secured more than $12 million in combined monetary penalties and permanent bans across the defendant entities.
VR-Tech Mgt LLC and Statewide Commercial Lending LLC were permanently banned from credit repair services. Principals were required to forfeit cash, vehicles, a boat, and multiple real estate properties.
The FTC brought its complaint under CROA, the FTC Act, and the Telemarketing and Consumer Fraud and Abuse Prevention Act simultaneously, stacking all three enforcement frameworks.
In FTC v.
BoostMyScore.net, the agency secured a $6.6 million judgment and a permanent injunction against a company promoting credit piggybacking schemes. In the Grand Teton Professionals enforcement action, the FTC alleged violations of six separate laws, resulting in $6.2 million in identified consumer harm.
The common thread across those enforcement actions is not the scale of the operation but the presence of systematic, intentional violations that continued after regulatory contact.
Can a Credit Repair Company Be Permanently Banned from Operating?
Yes. Federal courts can issue permanent injunctions banning a credit repair company and its individual principals from operating in the credit repair industry under FTC Act Section 53(b). These bans name the individuals, not just the corporate entity, which means a principal who dissolves one company and opens another under a different name with the same principals remains in violation of the original order and can face contempt proceedings.
The personal nature of permanent bans is the element most credit repair business owners underestimate. When the FTC obtains a permanent injunction against a credit repair operation, the order names the individual owners and officers as defendants alongside the business entity.
Dissolving the company does not satisfy the injunction. Forming a new LLC with a different name in a different state with the same individuals at the helm puts those individuals in contempt of the original court order from the day the new business takes on its first client.
Bans obtained through federal court proceedings routinely include asset forfeiture provisions that require defendants to surrender personal property as compensation for consumer harm. In the FES enforcement action, defendants surrendered vehicles, a boat, and multiple properties.
These forfeitures are separate from the consumer restitution fund and represent a direct financial penalty against the principals personally, beyond any consequence the business entity faces. The credit repair business owners who face bans are not losing only their company. They are losing assets they accumulated over the entire period of the violation.
The standard for obtaining a permanent ban requires a showing of persistent and intentional noncompliance with credit repair laws. Courts consider whether the company received prior warning, whether it took corrective action after regulatory contact, and how many consumers were harmed.
A company that received an FTC warning letter at Tier 1 and continued the same conduct is substantially more likely to face a permanent ban than one that corrected the violation immediately.
What Criminal Charges Can Credit Repair Companies Face?
Credit repair companies face federal criminal prosecution under three statutes when violations cross into fraud territory. Identity fraud under 18 U.S.C. 1028 applies to companies that create or promote synthetic credit identity schemes, including CPN programs, with penalties up to 15 years imprisonment per count.
Wire fraud under 18 U.S.C. 1343 applies to advance fee schemes conducted electronically, with penalties up to 20 years per count. Bank fraud under 18 U.S.C. 1014 applies when false credit applications are submitted to financial institutions, with penalties up to 30 years per count.
Criminal exposure in credit repair arises from three specific practices, each of which also constitutes a CROA violation. Understanding the link between the civil prohibition and the criminal statute is what makes this exposure real rather than theoretical.
| Practice | Criminal Statute | Maximum Sentence | Croa Predicate Violation |
|---|---|---|---|
| Cpn And File Segregation Schemes | 18 U.S.C. 1028 | Up to 15 years per count | CROA 1679b(a)(1) and (a)(2) |
| Electronic Advance Fee Fraud | 18 U.S.C. 1343 | Up to 20 years per count | CROA 1679b(b) |
| False Credit Applications To Financial Institutions | 18 U.S.C. 1014 | Up to 30 years per count | CROA 1679b(a)(1) |
The Credit Privacy Number scheme is where criminal exposure is most concentrated. A company that advises clients to apply for credit using a synthetic nine-digit number formatted like a Social Security number is advising those clients to commit identity fraud under 18 U.S.C. 1028 and bank fraud under 18 U.S.C. 1014 with each application.
The predicate CROA violation is Section 1679b(a)(1), which prohibits advising a consumer to make any false or misleading statement to a credit bureau or creditor. The civil prohibition and the criminal statute are triggered by the same act.
Wire fraud charges apply when advance fee schemes use electronic payment systems, email, or telephone to collect money from consumers.
Because virtually all credit repair payments are processed electronically, any advance fee collected through an online payment portal, ACH transfer, or credit card creates wire fraud exposure alongside the CROA and TSR civil liability.
Each individual electronic transaction is a potential separate count. A company that collected illegal advance fees from 50 clients over 18 months has created 50 potential wire fraud counts in addition to its civil exposure.
What Are the State-Level Penalties for Credit Repair Law Violations?
State attorneys general can bring enforcement actions against credit repair companies in federal court on behalf of state residents under CROA Section 1679h, independent of any FTC action.
Most states also have their own Credit Services Organization (CSO) acts that impose requirements beyond federal law: surety bond requirements, state registration before offering services, and state-specific disclosure language.
A credit repair company operating in multiple states can face simultaneous federal enforcement under CROA and state enforcement under each applicable CSO act. State-level penalties for credit repair law violations operate through two channels that work independently of each other.
The first is the state attorney general’s authority under CROA Section 1679h to bring a federal civil action on behalf of state residents. The second is the state’s own Credit Services Organization statute, which creates state-law liability entirely separate from CROA.
A company can satisfy CROA requirements and still violate a state’s CSO act if it failed to register, post the required surety bond, or use the state’s required contract language.
| State | Governing Law | Key Requirement Beyond Croa | Enforcement Authority |
|---|---|---|---|
| Texas | TX Finance Code Ch. 393 | Registration with TX Secretary of State plus surety bond before offering services to any Texas resident | TX AG + TX SOS |
| Georgia | O.C.G.A. 16-9-59 | Criminal penalties for CSO violations in addition to civil liability, making Georgia one of the highest-consequence states for non-compliance | GA AG |
| Florida | F.S. 817.7001 | State-specific written contract language requirements and a $1,000 bond cap per client | FL AG + FDACS |
| California | Civ. Code 1789.10 et seq. | Registration with the CA DOJ, surety bond requirement, and consumer right to cancel at any time for any reason | CA AG + CA DOJ |
| North Carolina | N.C.G.S. 66-220 et seq. | $10,000 surety bond required. Operating without a valid bond in place is unlawful regardless of federal compliance status. | NC AG |
State surety bond requirements create a penalty mechanism that does not exist at the federal level. A credit repair company operating without the required bond faces immediate legal ineligibility to collect fees in that state, and regulators can order restitution of all fees collected during the period of non-compliance.
Bond forfeiture gives harmed consumers a direct financial recovery source that operates entirely outside the CROA and FTC enforcement channels.
How Do Consumers Report a Credit Repair Company That Broke the Law?
Consumers report credit repair violations to three separate authorities: the FTC at reportfraud.ftc.gov, the CFPB at consumerfinance.gov/complaint, and their state attorney general’s office. Filing with regulatory agencies creates a public record that supports enforcement actions and documents the violation timeline for a private lawsuit.
A CROA private lawsuit under Section 1679g is available independently of any agency action. The five-year statute of limitations under Section 1679f begins on the date of the violation, not the date it was discovered. The most important step before filing any complaint is documentation.
Gather every piece of evidence available: the original contract if one was provided, or a written record of the fact that no contract was given (which is itself a CROA violation under Section 1679d), all payment receipts and bank records showing the amount and timing of fee collection, every written communication including texts and emails, and any marketing material that made specific promises about results.
This documentation is the evidentiary foundation for both a regulatory complaint and a private lawsuit under CROA.
The reporting sequence that produces the strongest enforcement and legal outcome follows this order.
File first with the FTC at reportfraud.ftc.gov because the FTC uses complaint data to identify companies with violation patterns that warrant enforcement action. File next with the CFPB at consumerfinance.gov/complaint, which maintains a public consumer complaint database that other prospective clients can see when researching the company.
File with the state attorney general, whose enforcement authority under CROA Section 1679h is independent of what the FTC does. Consult a consumer protection attorney about a private lawsuit, noting the five-year filing window from the date of each specific violation.
How Do Compliant Credit Repair Companies Avoid These Penalties?
Compliant credit repair companies avoid penalties by building the legal requirements into their operational workflow rather than relying on operators to remember each obligation in sequence.
The five non-negotiable compliance steps under federal law are: delivering the CROA disclosure before any contract is signed, executing a written contract meeting Section 1679d requirements, honoring the three-day cancellation window before work begins, collecting payment only after services are fully performed, and generating dispute letters that contain only truthful and accurate information.
The distinction between compliant and non-compliant credit repair operations is almost always an architectural problem rather than an ethical one. Operators who violate CROA do not typically intend to violate it.
They set up their business using a workflow that was not designed around the legal requirements, and compliance failures emerge from the gaps in that design.
The credit repair business owners who maintain long-term regulatory compliance are almost always those who built their operations around the compliance requirements from day one rather than trying to retrofit legal requirements into a workflow that was already running.
| Croa Requirement | Code Section | How Client Dispute Manager Software Enforces It |
|---|---|---|
| Deliver Disclosure Before Contract | 15 U.S.C. 1679c | The disclosure acknowledgment step must be completed before any contract can be generated. The platform will not advance past it. |
| Written Contract With Required Elements | 15 U.S.C. 1679d | Contracts include all required fields: total cost, services description, estimated completion date, and company name and address. CROA-compliant templates are included in the platform. |
| Honor The Three-Day Cancellation Window | 15 U.S.C. 1679e | Dispute work cannot begin until the three-business-day cancellation period closes. The platform enforces this timeline in the workflow sequence. |
| Collect Payment After Services Are Performed | 15 U.S.C. 1679b(b) + TSR 310.4(a)(2) | Invoices are generated when a dispute round closes, not when a client enrolls. The billing trigger is tied to service completion by design. |
| Accurate And Truthful Dispute Documentation | 15 U.S.C. 1679b(a)(1) | Every dispute letter and client interaction is timestamped and stored in an audit-ready record within the client file. |
Client Dispute Manager Software enforces each of these compliance requirements through the platform’s workflow sequence rather than through a checklist the operator manages manually.
The disclosure gate, the cancellation window, and the post-service billing trigger are all built into the order in which the platform allows the operator to proceed.
The result is an audit-ready record of every client interaction from disclosure delivery through invoice generation, which is the documentation that matters when a consumer lawsuit or an FTC inquiry requires demonstrating that the business operated within the law.
Frequently Asked Questions
What Is the Statute of Limitations for a CROA Lawsuit?
The statute of limitations for a lawsuit under the Credit Repair Organizations Act is five years from the date the specific violation occurred, under CROA Section 1679f. The clock starts on the date of the act, not the date the consumer discovered it.
A consumer who paid an illegal advance fee three years ago has two years remaining to file a lawsuit. Missing the five-year window eliminates the right to recover under CROA regardless of how clear or well-documented the violation is.
Is It Illegal for a Credit Repair Company to Charge Upfront?
Yes. CROA Section 1679b(b) expressly prohibits credit repair organizations from charging or receiving any money before services are fully performed.
The Telemarketing Sales Rule Section 310.4(a)(2) adds a separate prohibition for credit repair services sold through telephone or online marketing, with civil penalties up to $51,744 per violation. Collecting payment at enrollment before any dispute round has been completed violates both laws simultaneously, and the consumer is entitled to recover the full amount paid as actual damages under CROA Section 1679g(a)(1)(B).
What Is the Civil Penalty per TSR Violation for Credit Repair Companies?
The FTC can impose civil penalties up to $51,744 per violation of the Telemarketing Sales Rule under 16 C.F.R. 1.98(d). Each individual transaction counts as a separate violation.
A credit repair company that collected illegal advance fees from 100 clients over two years faces up to $5.1 million in TSR civil penalties before CROA civil liability and any criminal exposure are added to the total.
The FTC can also seek restitution and disgorgement of all revenues received during the violation period on top of the per-violation penalty amount.
Can a Credit Repair Company Operate Without a Written Contract?
No. CROA Section 1679d requires every credit repair organization to provide a written contract before performing any services. The contract must include the total cost of services, a description of the services to be performed, the estimated completion date, and the company’s name and principal business address.
Operating without a written contract is a CROA violation that exposes the company to consumer lawsuits under Section 1679g and FTC enforcement action. A non-existent contract is also evidence of the violation in itself, since Section 1679d makes the written contract a prerequisite for any legal service relationship.
Do State Credit Repair Laws Apply in Addition to Federal Law?
Yes. CROA Section 1679j allows states to enact laws that add requirements beyond CROA as long as they do not conflict with federal law. Most states with significant credit repair activity have their own Credit Services Organization (CSO) acts. Texas requires registration with the Secretary of State and a surety bond.
California requires registration with the state Department of Justice and allows consumers to cancel at any time. Georgia’s CSO statute adds criminal penalties for violations. Credit repair companies operating across multiple states must satisfy each state’s specific requirements alongside all federal law obligations.
Conclusion
The penalties for companies that break credit repair laws are not abstract regulatory risks. The FTC has permanently banned operators, seized personal assets, and collaborated with the Department of Justice on criminal prosecutions resulting in federal prison sentences.
Consumers have won seven-figure class action judgments under CROA’s private right of action. State attorneys general have brought independent enforcement actions that added state-level consequences on top of federal ones.
Every penalty category, from a CROA civil lawsuit to a TSR fine to wire fraud charges, traces back to a small set of operational decisions that compliant credit repair business owners make correctly from the start.
Client Dispute Manager Software is built around the premise that credit repair compliance is a workflow architecture problem, not a memory problem.
The platform enforces the CROA disclosure sequence, the written contract requirement, the three-day cancellation window, and the post-service billing rule through the order of operations in the platform itself rather than requiring operators to manually track each obligation.
Credit repair professionals who want to see what a compliant operational workflow looks like in practice can try Client Dispute Manager Software free for 30 days at clientdisputemanagersoftware.com. No credit card is required.

Mark Clayborne
Mark Clayborne specializes in credit repair, starting and running credit repair businesses. He's passionate about helping businesses gain freedom from their 9-5 and live the life they really want. You can follow him on YouTube.
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