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Terms of Service

Last Updated: Sep 11, 2026

Welcome to Path to Keyes, LLC. Please read these Terms of Service (“Agreement” or “Terms”) carefully before accessing or using the website, client portals, educational resources, or credit counseling services provided by Path to Keyes, LLC (“the Company,” “we,” “us,” or “our”).

By accessing or using any part of our website, enrolling in our 60–90 day mortgage readiness program, or interacting with our automated systems, you (“Client,” “user,” “you,” or “your”) agree to be bound by these Terms. If you do not agree to all of the terms and conditions of this Agreement, you are not authorized to access our website or use any of our services.

These Terms govern your legal relationship with Path to Keyes, LLC, a registered Credit Services Organization (CSO) operating under the Credit Repair Organizations Act (CROA) (15 U.S.C. §§ 1679–1679j), the Federal Trade Commission’s (FTC) Telemarketing Sales Rule (TSR) (16 C.F.R. Part 310), and applicable state credit services regulations.

1. Corporate Identity And Global Transparency

All services, platforms, and legal obligations are owned and operated by:

  • Verified Legal Business Name: Path to Keyes, LLC
  • Physical Contact Address: 211 E 43rd St, Ste 6th Fl. NY, 10017
  • Support Email Contact: info@pathtokeyes.com

This corporate information matches the Company’s official Employer Identification Number (EIN) and state business registries. Consistent with mobile carrier vetting standards (A2P 10DLC Vetting Code 30919), this business identity is conspicuously displayed across all footers, intake forms, and disclosure portals.

2. Scope Of Services & The Mortgage Readiness Program

Path to Keyes, LLC provides a structured, 60–90 day mortgage readiness credit counseling program designed to prepare first-time homebuyers, particularly low-to-moderate-income (LMI) individuals, for home purchase eligibility.

Our core services include:

  1. Credit Score Simulation Analyses: Utilizing decisioning algorithms to model how prospective financial actions impact lending profiles.
  2. Educational Curriculum & Gated Library: Access to a custom 6-step mortgage readiness framework and a 15-eBook library containing comprehensive financial education resources.
  3. Credit Analysis & Audit Services: Auditing consumer credit reports, identifying reporting errors, inaccuracies, and outdated entries, and preparing administrative documents to correct consumer files in accordance with the Fair Credit Reporting Act (FCRA).
  4. B2B Referral Milestone Tracking: Providing a secure portal for authorized real estate and mortgage professionals to monitor client progress milestones without financial compensation.

Non-Guarantee Disclosure

PATH TO KEYES, LLC DOES NOT GUARANTEE CREDIT SCORE INCREASES, FICO IMPROVEMENTS, OR THE REMOVAL OF ACCURATE, TIMELY, OR NON-OBSOLETE NEGATIVE INFORMATION FROM ANY CREDIT REPORT. CREDIT PROFILES VARY SIGNIFICANTLY BY CLIENT, AND HISTORICAL RESULTS ARE NOT A GUARANTEE OF FUTURE OUTCOMES. WE DO NOT PROMISE “FAST RESULTS,” “QUICK FIXES,” OR AUTOMATIC SCORE DELETIONS. ACTUAL RESULTS DEPEND ENTIRELY ON INDIVIDUAL DEBT PROFILES, TIMELY PAYMENTS, AND CREDITOR COMPLIANCE WITH FEDERAL LAW.

Mobile Carrier Keyword Safeguards

To maintain strict compliance with mobile telecommunications regulations and A2P 10DLC vetting protocols, the Company strictly prohibits the use of high-risk financial marketing keywords on its platforms. Our documentation, public text, and mobile transactional alerts are strictly classified under “Financial Education” and “Transactional Customer Support”.

3. Consumer Disclosures & Success Rates

Pursuant to the Credit Repair Organizations Act (CROA) and state Credit Services Organization (CSO) statutes, and to prevent the deceptive billing omissions criticized in Harris v. My Credit Guy, L.L.C., the Company provides the following historical performance disclosures:.

No Waiver Of Consumer Rights (15 U.S.C. § 1679g)

YOU HAVE A STATUTORY RIGHT TO SUE ANY CREDIT REPAIR ORGANIZATION THAT VIOLATES THE CREDIT REPAIR ORGANIZATIONS ACT. YOU CANNOT WAIVE THESE RIGHTS, AND NOTHING IN THIS AGREEMENT SHALL BE CONSTRUED TO WAIVE, LIMIT, OR RESTRICT YOUR NON-WAIVABLE STATUTORY RIGHTS UNDER FEDERAL OR STATE LAW.

We explicitly reject and omit any arbitration, choice-of-law, or forum-selection clauses that operate as a waiver of consumer protection rights or force clients to litigate outside of their residential state jurisdictions.

4. Automated Digital-Only Onboarding & Telemarketing Safe Harbor

To comply with the Federal Trade Commission’s (FTC) Telemarketing Sales Rule (TSR) (16 C.F.R. Part 310) and insulate the Company from telemarketing liability, Path to Keyes, LLC operates under a Telemarketing Safe Harbor.

  • Self-Service Execution Required: All clients must enroll, review disclosures, execute their written contract, and authorize their payment billing details in a completely automated, self-directed, digital-only environment.
  • No Pre-Contract Consultations: The Company, its employees, and virtual assistants are strictly prohibited from conducting pre-sale consultative phone calls, pre-sale inbound discovery calls, or pre-sale live video consultations prior to the client’s execution of the written service agreement.
  • Zero Verbal Inducement: You acknowledge that your enrollment was initiated and executed entirely by you via our digital web intake forms, without any interactive verbal or telephonic sales coaching. This structural boundary separates the Company’s digital workflow from telemarketing regulations, enabling the lawful operation of our standard monthly billing-in-arrears structure.

5. Billing Sequence & Arrears Formula

The Company charges no upfront fees for setup, credit audit preparation, or intake administration. Our billing sequence is powered by ECRYPT and is governed by strict chronological compliance constraints.

The Chronological Arrears Formula

  1. $0 Initial Fee: You are charged exactly $0.00 at the moment of onboarding.
  2. Service Performed Prior to Charge: Your baseline credit file analysis is fully performed, generated, and delivered to you before any subscription fee trial is started.
  3. 30-Day Billing Deferral: Your card on file is not charged the recurring monthly service fee of $99.00 until exactly thirty (30) days after the baseline audit has been transmitted.

Independence Of Onboarding Triggers

Your monthly subscription billing cycle is strictly handled by ECRYPT under the arrears rule and is legally independent of the educational access trigger. Access to the gated eBook library is unlocked when you complete your onboarding.

6. Specialized Fintech Integrations & Third-Party Disclosures

Path to Keyes, LLC integrates specialized financial technology APIs, specifically IdentityIQ®, to construct and optimize your comprehensive mortgage readiness profile. Within this integrated ecosystem, IdentityIQ® serves as the primary native tri-bureau data feed, providing continuous credit monitoring, detailed credit factor breakdowns, debt analysis (including Debt-to-Income/DTI ratio calculations), and credit score simulations. By agreeing to our terms, you acknowledge and authorize these integrated workflows.

A. IdentityIQ® Native Monitoring & Analytics

Continuous analysis of your credit file requires an active, external, and uninterrupted credit monitoring connection.

  • Monitoring Mandate: You are required to maintain an active subscription to IdentityIQ®, our natively integrated tri-bureau monitoring partner. This connection allows our team to retrieve credit reports, score updates, and detailed debt profiles via secure API integration without requiring your external portal passwords.
  • Pricing & Terms: IdentityIQ® is billed independently at $29.86/month following a $1.00 7-day trial.
  • Prohibition of Native Dispute Tools & Limitation of Liability: Clients are strictly advised against using IdentityIQ’s native “Dispute Assistance” tool or any third-party self-service dispute features inside their retail dashboard. Submitting disputes directly through IdentityIQ creates duplicate bureau filings that can interfere with, delay, or compromise active dispute strategies. Path to Keyes, LLC is not liable or responsible for any credit score degradation, report file errors, dispute delays, or credit damage resulting from the client’s use of third-party or “do-it-yourself” (DIY) dispute services.

B. Self-Managed Subscription & Third-Party Terms

  • Affiliate Compensation Notice: Path to Keyes, LLC participates in an affiliate marketing program with IdentityIQ®. When clients enroll in IdentityIQ® through our platform or onboarding links, Path to Keyes, LLC receives a $5.82 monthly recurring commission per active subscription. This commercial commission helps support our educational platform operations.
  • Independent Relationship: IdentityIQ® subscription billing and account management are handled independently between the client and the monitoring provider. Path to Keyes, LLC does not directly collect credit monitoring fees.

C. Rental Kharma and Rent Reporting Operational Independence

Path to Keyes LLC provides educational curricula, budgeting analyses, and mortgage-readiness coaching. The rent reporting services referenced across this platform are provided, operated, and maintained exclusively by an independent third party, Rental Kharma (a division of Credit Bureau Connection or its successors). Path to Keyes LLC does not maintain operational control, technical direction, or managerial oversight over Rental Kharma’s landlord verification systems, reporting schedules, or tradeline transmissions. By accessing the third-party affiliate links on this site, you enter into a direct contractual relationship with Rental Kharma, governed by its independent Terms of Service and Privacy Policy. Path to Keyes LLC is not liable for any acts, omissions, delays, processing errors, or data transmission failures caused by Rental Kharma.

C.1 Platform Independence and Operational Scope

Path to Keyes, LLC provides educational curricula, budgeting analyses, and mortgage-readiness coaching. Rent reporting services referenced across this platform are provided, operated, and maintained exclusively by an independent third party, Rental Kharma (a division of Credit Bureau Connection). Path to Keyes, LLC does not maintain operational control, technical direction, or managerial oversight over Rental Kharma’s landlord verification systems, reporting schedules, or trade line transmissions. Entering into services via third-party affiliate links creates a direct contractual relationship with Rental Kharma, governed by its independent Terms of Service and Privacy Policy.

C.2. Commercial Affiliate Compensation Disclosure

Path to Keyes, LLC maintains a commercial affiliate marketing partnership with Rental Kharma. When users access affiliate links on our platform and register for Rental Kharma services, Path to Keyes, LLC receives financial compensation, referral fees, or commissions from Rental Kharma. Users are under no obligation to enroll in Rental Kharma, and selecting an alternative provider or declining rent reporting does not impact your access to Path to Keyes, LLC’s core educational services.

C.3 Credit Bureau Coverage & Experian Omission

  • Repository Reporting Limits: Rental Kharma reports verified rental payment history solely to TransUnion and Equifax. Rental Kharma does not report to Experian.
  • Mortgage Underwriting Impact: Conforming residential mortgage originators evaluate tri-merge credit reports and utilize the representative middle credit score among all three nationwide repositories. Because Rental Kharma excludes Experian, your Experian credit file and score will remain unaffected by reported rental tradelines.
  • Scoring Algorithm Compatibility: Rental tradelines are recognized primarily in newer scoring models (such as VantageScore 3.0/4.0 and FICO 9/10). Legacy tri-merge scoring algorithms utilized for conventional and government-backed (FHA, VA, USDA) loans—specifically Equifax Beacon 5.0, Experian/Fair Isaac v2, and TransUnion Classic 04—do not automatically factor rental payment data into algorithmic score outputs. Lenders may, however, consider rental payment records during manual underwriting evaluations.

7. B2B Referral Portal & RESPA Section 8 Safeguards

To support collaborative mortgage planning, the Company operates a secure B2B partner portal (secureclientaccess.com) for licensed Real Estate Agents, Mortgage Loan Officers (LOs), and community housing counselors. This portal is governed by the Real Estate Settlement Procedures Act (RESPA) Section 8.

RESPA Compliance & Prohibition Of Referral Fees

UNDER RESPA SECTION 8(a), IT IS A FEDERAL CRIME TO GIVE OR ACCEPT ANY FEE, KICKBACK, OR THING OF VALUE IN EXCHANGE FOR REFERRALS OF SETTLEMENT SERVICES IN CONNECTION WITH A FEDERALLY RELATED MORTGAGE LOAN. PATH TO KEYES, LLC PAYS NO REFERRAL FEES, OFFERS NO COMMISSION SPLITS, AND PROVIDES NO FINANCIAL PAYOUTS, CREDITS, OR REWARDS TO LENDING OR REAL ESTATE PROFESSIONALS. THE B2B PORTAL IS STRICTLY A NON-COMPENSATED TRACKING INTERFACE.

8. External Advertisements & Manual Referrals

The Company may feature manual outbound links and promotional sections for external professional services on its website.

  • McCarthy Law PLC: Advertised as an optional legal escalation add-on service. This is a purely manual, client-initiated referral with no automated backend API, database brokering, or revenue sharing.
  • Tradeline & Credit Profile Enhancement Partner: Advertised as an optional credit profile strengthening add-on. This is a manual, client-initiated transaction. Path to Keyes, LLC does not broker, resell, or guarantee any credit outcomes from these external programs, and is not a party to any agreement you enter with such partners.
  • Compliance Constraint: All descriptive text for external partner services adheres to CROA-safe guidelines and contains no guarantees of specific credit score outcomes or permanent file removals.

9. Transactional SMS Notification Program Terms and Conditions

A. Program Identification and Overview

Path to Keyes, LLC (“Company,” “we,” “us”) provides an automated, transactional Short Message Service (SMS) notification program (“Program”) designed to deliver administrative alerts, educational updates, and scheduling notifications to enrolled clients and registered affiliates of our mortgage-readiness counseling platform. Enrollment in the Program is strictly voluntary.

B. Unbundled and Optional Consent

Agreeing to these Terms of Service is legally unbundled from mobile SMS opt-in consent. SMS opt-in is completely optional, is not pre-selected by default, and is not a prerequisite for purchasing services, creating an account, or accessing the gated eBook library

C. Transactional Message Scope

Program communications are non-marketing and purely transactional in nature. SMS messaging is restricted strictly to transactional, customer support, and system security notifications (such as reminders, portal registration links, and document upload confirmations). All marketing, promotional outreach, and client file adjustment discussions are restricted exclusively to secure email channels.

D. Expected Message Frequency

The Program operates on an event-triggered, non-recurring model. Message frequency varies based upon active engagement level and counseling milestones. Enrolled clients can anticipate receiving approximately two (2) to six (6) transactional messages per calendar month during active participation.

E. Mobile Carrier Rates and Fees

Message and data rates may apply to each SMS transmitted or received under this Program, in accordance with your individual wireless carrier plan. Path to Keyes, LLC assesses no independent fee for sending SMS messages.

F. Opt-Out and Revocation Instructions

You may opt out of the Program at any time. To revoke consent, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any text message received from Path to Keyes, LLC. You will receive a single, final automated SMS confirming that your mobile number has been removed.

G. Customer Support and HELP Inquiries

For assistance or support regarding text notifications, reply HELP to any message received, email us at info@pathtokeyes.com, or call our support line at (518) 268-0589.

H. Carrier Liability Disclaimer

Mobile network operators (including AT&T, T-Mobile, Verizon, and regional wireless carriers) and Path to Keyes, LLC are not liable for delayed or undelivered messages. Uninterrupted transmission remains subject to local cellular transmission conditions and device availability.

I. Privacy Alignment and Mobile Data Protection

All mobile information captured via the Program is governed by our Privacy Policy. Consumer mobile phone numbers, opt-in data, and consent details will never be shared, sold, rented, leased, or transferred to third parties or affiliates for marketing or promotional purposes. For full details, review our complete Privacy Policy.

10. General Legal Terms & Liability Provisions

  • Entire Agreement: These Terms, together with your executed written Credit Services Organization (CSO) agreement, represent the entire agreement between you and Path to Keyes, LLC.
  • Severability: If any provision of these Terms is found to be invalid or unenforceable under federal or state law, the remaining provisions shall continue in full force and effect.
  • Amendment: The Company reserves the right to modify these Terms at any time to reflect changing regulatory requirements or platform updates. Continued use of our platforms following any changes constitutes acceptance of those updates.

11. Contact And Compliance Verification

If you have any questions regarding these Terms of Service, your consumer rights, or our regulatory bonds, please contact us at:

Path to Keyes, LLC 211 E 43rd St, Ste 6th Fl. NY, 10017 Email: info@pathtokeyes.com