Those who follow the Mark Silverthorn Blog might recall that on June 22, 2015 I wrote a post titled “Complete Debt Solutions Operating in Canada Illegally?” In that post I raised the question whether or not a firm based in Toronto, Ontario, carrying on business under the name Complete Debt Solutions was operating in one or more Canadian jurisdictions illegally as a debt settlement firm.
I became aware of the existence of Complete Debt Solutions after receiving a tip, from one of my hundreds of contacts, about the firm’s website, www.completedebtsolutions.ca. A portion of the CONTACT page from this website is reproduced below.
Complete Debt Solutions is an Ontario-based debt settlement firm offering debt settlement services to Ontario residents
On its website Complete Debt Solutions lists its business address at 1075 Bay Street, Suite 149, Toronto, Ontario. I recently came into possession of 13 pages of material which Milton Kaseke, the principal of Complete Debt Solutions, e-mailed on or about June 22, 2015, to an Ontario resident making inquiries about the organization’s services. A redacted copy of the first page of these 13 pages is reproduced below (yellow highlights have been added for clarity).
On this page Milton Kaseke, who describes himself as a Senior Account Executive, confirms that “Complete Debt Solutions (C.D.S.) is a Debt Relief/Debt Settlement/Debt Negotiation and Credit Repair company located in Toronto Ontario Canada.”
Debt settlement providers require a collection agency licene
Subject to the following two exceptions, a firm must possess a license–typically a collection agency license (or a debt repayment agency license in Alberta)–in order to legally provide debt settlement services.
- a few Canadian provinces might not require a debt settlement provider to be licensed
- in some Canadian provinces and territories a law firm might be exempt from the requirement of obtaining a collection agency license
Complete Debt Solutions is not licensed in any province or territory as a collection agency
After I wrote my initial post on June 22, 2015, concerning the activities of Complete Debt Solutions I began making inquiries concerning the status of Complete Debt Solutions across the country. I contacted, some, but not all, of the regulators in various provinces responsible for supervising the conduct of debt settlement service providers. I was unable to identify a single province or territory where Complete Debt Solutions possessed a collection agency license.
You can imagine my surprise when on Friday, July 17, 2015, I received a phone call from Milton Kaseke, the principal of Complete Debt Solutions. After advising me that he was not a fan of my June 22nd posts on both LinkedIn and the Mark Silverthorn Blog he confirmed that Complete Debt Solutions does not possess a collection agency license in a single province or territory in Canada.
E-mail from Milton Kaseke in which he states Complete Debt Solutions does not charge consumers for its services
On June 23, 2015 I received an e-mail from Milton Kaseke, the principal of Complete Debt Solutions. In this e-mail Mr. Kaske states that “I haven’t taken any penny from anybody which means that I am not breaking the law (Collection and Debt Settlement Services Act of Ontario).” This e-mail is reproduced below.
Mr. Kaseke is correct when he says that a firm offering debt settlement services to Ontario residents does not need to possess a valid Ontario collection agency license if the firm is not receiving any compensation for its services.
The question that remains to be answered is whether or not Complete Debt Solutions and Milton Kaseke are offering debt settlement services to Ontario residents in circumstances where potential clients must pay a fee to Complete Debt Solutions.
Complete Debt Solutions would appear to be offering debt settlement services in return for financial compensation
As noted earlier, I recently came into possession of 13 pages of material that Milton Kaseke of Complete Debt Solutions e-mailed on or about June 22, 2015 to an Ontario resident inquiring about debt settlement services offered by the firm. This material contains a 2-page contract for debt settlement services titled “Complete Debt Solutions Service Agreement”. The first page of this document is reproduced below (yellow highlight has been added to some of the most pertinent portions of text).
According to the first page of this debt settlement agreement Complete Debt Solutions charges its clients an Administration Fee. In the middle of the first page of this 2-page debt settlement agreement a potential client is advised that he is responsible for paying to Complete Debt Solutions an “Administration Fee equal to 13% (thirteen percent) of the Client’s total enrolled debt.”
Official complaint made to the Ontario Government on or about June 24th
About a month ago, after spending a signficant amount of time reviewing the content on Complete Debt Solutions’s website I thought it would be appropriate to ask the Ontario Government to make inquiries and determine whether or not Complete Debt Solutions was operating as an illegal debt settlement service provider in contravention of the Ontario Collection and Debt Settlement Services Act. Accordingly, I wrote a letter dated June 22, 2015, to Doug Kariam, Ontario’s Acting Registrar of Collection Agencies, requesting that his office investigate the matter. The following day I completed and submitted the appropriate online Complaint Form used by the Ontario Ministry of Government and Consumer Services.
The Ontario Ministry of Government and Consumer Services refuses to process a complaint against a business unless a consumer first writes a letter of complaint directly to the business in question. Some people might think that this requirement is not only bad policy but also a direliction of the Ontario Registrar of Collection Agencies’ statutory duty to enforce the Ontario Collection and Debt Settlement Services Act. In order to satisfy this “written notice requirement” I sent an e-mail to Milton Kaseke of Complete Debt Solutions on June 23, 2015, a copy of which is reproduced below.
Furthermore, I forwarded copies of my letter to Doug Kariam to several of his counterparts in a number of provinces across the country. I asked them to make inquiries to determine whether or not the activities of Complete Debt Solutions warranted an investigation in their province to determine if the law regulating debt settlement firms was being contravened.
On Friday, July 17, 2015, I sent an e-mail to Doug Kariam, Ontario’s Acting Registrar of Collection Agencies. In that e-mail I provided a copy of the 13 pages of material that Milton Kaseke e-mailed to an Ontario resident on or about June 22, 2015, which I refer to in this post. You can read a redacted copy–with the name of the consumer removed–of this material, in its entirety, at the end of this post.
I am not privy to what action the office of the Ontario Registrar of Collection Agencies has taken to date in response to my official complaint regarding the activities of both Complete Debt Solutions and its principal, Mr. Milton Kaseke. Nor am I privy to the actions which might be currently underway in other provinces as a result of my communications with Doug Kariam’s counterparts in other provinces. I would hope that my complaint receives the attention that is warranted under the circumstances.
Contact Mark Silverthorn if you have recevied a debt settlement agreement from Complete Debt Solutions
If you have received a debt settlement agreement from Complete Debt Solutions I would invite you to contact me. I would also invite anyone who has received a debt settlement agreement from any other debt settlement service provider to contact me. I can be reached at (866) 996-9941 or (519) 827-5513. Alternatively, you can contact me via e-mail at email@example.com
Redacted copy of 13 pages of material sent from Complete Debt Solutions to an Ontario resident on or about June 22, 2015