A Lamborghini, a Maserati, and a Golf Cart: What Regulators Seized From 'The Credit Game'

One advertisement for a credit repair operation called The Credit Game used the headline “Free Credit Repair From The Government.” According to a federal complaint, that was one of a series of lies the scheme's operators, Michael and Valerie Rando, told consumers to sell services that a federal court would later find rarely worked and sometimes made customers' credit worse.DOCUMENTED

The Randos, based in Florida, had operated credit repair schemes since at least 2019, first under the name Wholesale Tradelines before rebranding as The Credit Game in 2020.DOCUMENTED According to the FTC's complaint, they claimed to have brought in more than $15 million in business through the operation before regulators shut it down.DOCUMENTED

What the complaint alleges

According to the FTC's complaint, the Randos lied to consumers about the legality and effectiveness of their credit repair products, misrepresented whether customers would receive refunds when they requested them, and provided false information to credit reporting agencies regarding consumers' credit reports.DOCUMENTED The complaint further alleges the Randos pitched their own customers a supposed business opportunity that amounted to starting their own bogus credit repair scheme — turning dissatisfied customers into potential recruiters for the very operation that had failed them.DOCUMENTED Samuel Levine, then Director of the FTC's Bureau of Consumer Protection, said the defendants “falsely promised consumers improved credit based on tactics that were both illegal and ineffective.”DOCUMENTED

A database bought with open eyes

One detail from the FTC's investigation stands out for what it suggests about the Randos' awareness of the legal risk they were taking. According to the agency, the defendants purchased a tradeline database from William Airy and BMS, Inc. — individuals the FTC had already sued in 2020 for operating a separate bogus credit repair scheme.DOCUMENTED The FTC's investigation found that the Randos were aware of the agency's investigation into Airy and BMS at the time they purchased the database.DOCUMENTED Knowingly acquiring the customer infrastructure of an operation already under federal investigation for the same type of conduct is the kind of fact that tends to weigh against an argument that any violations were inadvertent or the product of poor legal advice.REVIEWED

Exploiting a pandemic-era benefit

The FTC's original 2022 action against the Randos also included an unusual allegation: that the defendants attempted to redirect COVID-19 tax benefits intended for consumers into their own accounts.DOCUMENTED Samuel Levine said at the time that “credit repair schemes cheat those already in financial trouble, and these defendants even tried to redirect COVID-19 tax benefits into their own pockets.”DOCUMENTED The Commission's vote authorizing the initial complaint and request for a temporary restraining order was 4-0, and the case was filed in the U.S. District Court for the Middle District of Florida.DOCUMENTED

What the final order requires

Under the proposed orders resolving the case, the Randos and their companies are permanently banned from operating or assisting any credit repair service of any kind.DOCUMENTED The orders also prohibit the defendants from making claims about the benefits, performance, or efficacy of any good or service without sufficient supporting evidence — a restriction that extends well beyond credit repair specifically.DOCUMENTED To satisfy the judgment, the Randos are required to turn over a wide array of property, including their interest in numerous real estate investments, a Lamborghini, a Maserati, a Land Rover, and a golf cart, along with the contents of numerous bank, investment, and life insurance accounts.DOCUMENTED A court-appointed receiver is tasked with liquidating those assets, with proceeds used to refund harmed consumers; the FTC has since sent more than $3.5 million in refunds tied to the case.DOCUMENTED

The Randos allegedly bought a customer database from operators the FTC had already sued for the same kind of credit repair fraud — while aware of that investigation.

Why the case matters

The Credit Game case illustrates a recurring feature of credit repair enforcement: operators who lose access to one customer base or database, whether through bankruptcy, a lawsuit, or a shutdown, do not always disappear from the industry. Sometimes their customer lists and tradeline databases simply change hands, occasionally to buyers who, as alleged here, understood exactly what legal cloud surrounded the asset they were purchasing.

How credit repair schemes typically fail consumers

Legitimate credit repair is narrowly limited by law: a company can dispute genuinely inaccurate items on a credit report, but it cannot legally remove accurate negative information simply because a consumer wants it gone, and federal law prohibits charging upfront fees for credit repair services before those services are actually rendered.REVIEWED The complaint's allegation that the Randos provided false information to credit reporting agencies suggests a scheme built around disputing accurate items using fabricated grounds — a tactic that can temporarily remove an item from a report while the dispute is investigated, but that typically results in the item being restored once the credit bureau verifies it, leaving consumers who paid for the service with a report that reverts to its original state, sometimes after they have already relied on the temporarily improved score to take on new credit obligations.

Turning customers into recruiters

The complaint's allegation that the Randos pitched their own dissatisfied customers on a business opportunity to start their own credit repair operation reflects a self-reinforcing structure common to schemes that combine a service offering with a recruitment pitch: a customer who is unhappy with the results they received becomes, through the recruitment pitch, financially incentivized to bring in new customers rather than to file a complaint or seek a refund, since doing so would undercut the business opportunity they had just been sold into.REVIEWED That structure can slow the emergence of the kind of consumer complaints that typically alert regulators to a scheme's existence in the first place.

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