Corporate Misconduct Accountability Project
Prosperity Training Technology LLC (d/b/a The Credit Game) · FTC Enforcement Action
The Credit Game Scam: How a Florida Credit Repair Ring Stole Millions
Federal regulators allege Michael and Valerie Rando operated a web of companies that promised fast credit fixes, charged illegal upfront fees, filed fake identity theft reports, and exploited COVID relief funds to fleece consumers nationwide.
CRITICAL SEVERITY
TL;DR
Michael and Valerie Rando ran multiple Florida LLCs promising consumers they could boost credit scores from the 500s to over 780 in as little as 45 days. The FTC alleges they charged thousands in illegal upfront fees, added fake authorized user tradelines to credit reports, coached consumers to file false identity theft claims, and refused refunds. The operation generated over $15 million while systematically violating federal credit repair, telemarketing, and business opportunity laws. Many victims were encouraged to spend COVID-19 stimulus checks on the worthless services.
This case shows how lightly regulated credit repair markets let predators exploit the desperate.
$15M+
Total revenue from deceptive credit repair and business opportunity sales
475K
YouTube subscribers used to market the scam
524
Credit accounts in cardholder database purchased from prior FTC defendant
$152,500
Amount paid to acquire tradeline database from company under FTC investigation
The Allegations: A Breakdown
Core Allegations
What they did · 8 points
| 01 | Defendants falsely promised consumers they could increase credit scores from as low as the 500s to over 780 in as little as 45 days by removing negative items and adding third-party credit histories. | high |
| 02 | The company charged consumers hundreds or thousands of dollars upfront before performing any credit repair services, violating federal law that prohibits advance fees. | high |
| 03 | Defendants filed or caused to be filed fake identity theft reports on the FTC’s identitytheft.gov website, falsely claiming negative credit information resulted from identity theft when it did not. | high |
| 04 | The operation sold authorized user tradelines that added strangers’ credit histories to consumers’ reports without giving consumers actual access to the accounts, misrepresenting creditworthiness to lenders. | high |
| 05 | Defendants coached consumers to dispute accurate credit report information by falsely claiming addresses, phone numbers, and employment history were incorrect in order to suppress negative accounts. | high |
| 06 | The company advertised a money-back guarantee and 365-day refund policy but routinely denied refunds to consumers who did not receive promised results. | high |
| 07 | Defendants sold business opportunities claiming consumers could legally and profitably resell the same deceptive credit repair services, without disclosing the illegality of the underlying practices. | high |
| 08 | The operation urged consumers to spend December 2020 and March 2021 COVID-19 stimulus payments and child tax credits on credit repair packages instead of essential needs. | high |
Regulatory Failures
How they got away with it · 6 points
| 01 | Defendants purchased a cardholder database from BoostMyScore LLC in December 2019 while that company was under active FTC investigation for selling tradelines, yet faced no immediate consequences. | high |
| 02 | The Letter of Intent for the database purchase included disclaimers acknowledging regulators could investigate and shut down the tradeline business, showing Defendants knew the practices were legally dubious. | high |
| 03 | Defendants operated through a web of at least seven interrelated Florida LLCs with common ownership, offices, and commingled funds, making it harder to trace money and accountability. | medium |
| 04 | The enterprise operated from at least 2019 through 2022 with hundreds of thousands of YouTube subscribers and millions in revenue before the FTC filed suit, demonstrating slow enforcement response. | medium |
| 05 | Defendants failed to provide required Credit Repair Organizations Act disclosures, contracts with mandated terms, or cancellation forms, yet continued signing up customers for years. | medium |
| 06 | The operation rebranded from Wholesale Tradelines to The Credit Game in February 2020, continuing the same practices under a new name to evade scrutiny. | medium |
Profit Over People
Targeting the vulnerable · 7 points
| 01 | Defendants specifically targeted consumers with poor credit in the 500s, people already facing financial strain and desperate for solutions, charging them thousands in upfront fees. | high |
| 02 | The operation generated over $15 million in revenue by exploiting the desperation of consumers who saw credit scores as their last hope for economic stability. | high |
| 03 | Defendants marketed aggressively during the COVID-19 pandemic, urging consumers to invest stimulus checks intended for food, housing, and medical bills into credit repair services instead. | high |
| 04 | YouTube videos used titles like ‘How I went from 505 to 814 credit score SO FAST!’ to lure vulnerable consumers, with the channel amassing 475,000 subscribers. | high |
| 05 | Defendants sold business opportunity packages for thousands of dollars by falsely promising consumers could make five-, six-, seven-, or even eight-figure incomes reselling credit repair services. | high |
| 06 | The company claimed to have ‘proprietary software’ for credit repair that achieved ’80 to 95 percent removal rates’ when in fact results were rarely achieved and methods were not substantiated. | medium |
| 07 | Sales representatives told undercover investigators Defendants wanted ‘everybody making millions’ and that ‘tens of thousands monthly’ was the income goal, luring people into a pyramid-style scheme. | medium |
Economic Fallout
The ripple effects · 6 points
| 01 | Consumers who paid thousands in upfront fees found themselves poorer and no closer to improving their credit, draining disposable income from already struggling households. | high |
| 02 | Some consumers who followed Defendants’ advice to file false identity theft reports now face potential legal liability for making fraudulent statements to government agencies. | high |
| 03 | By diverting COVID-19 relief funds into worthless credit repair services, Defendants drained public resources meant to provide a safety net for housing, food, and medical expenses. | high |
| 04 | Consumers with artificially inflated credit scores from fake tradelines may have obtained credit they could not afford, setting them up for defaults, collections, and deeper financial harm. | medium |
| 05 | Local economies lost spending power as thousands of dollars per consumer flowed to Defendants instead of local businesses, rent, or essential goods. | medium |
| 06 | The promised credit fixes that never materialized kept families locked out of home ownership and stable community growth, reinforcing cycles of intergenerational poverty. | medium |
Corporate Accountability Failures
Shell games and disclaimers · 6 points
| 01 | Defendants operated through at least seven Florida LLCs, including Prosperity Training Technology, Elite Customer Services, Digital Business Scaling, First Coast Matchmakers Inc and LLC, Financial Consulting Management Group, and Resource Management Investments, obscuring liability. | high |
| 02 | The Randos structured the purchase of the tradeline database so Michael Rando’s name could be removed from the contract while his email remained as point of contact, attempting to distance himself from accountability. | high |
| 03 | Defendants claimed credit repair services were provided by a separate ‘vendor’ called Elite Deletions to avoid refund requests, but Elite Deletions had no corporate form and was wholly controlled by the Randos. | high |
| 04 | When consumers requested refunds, Defendants told them they had only purchased ‘digital educational materials’ with a no-refund policy, contradicting promises of money-back guarantees for credit repair. | high |
| 05 | The Better Business Bureau received so many complaints that Ms. Rando blamed poor communication during the rebrand from Wholesale Tradelines to The Credit Game, deflecting from systemic fraud. | medium |
| 06 | Multiple shell companies transferred money, digital assets, and property among themselves, making it difficult to pinpoint personal liability and track consumer funds for refunds. | medium |
The PR Machine
Marketing deception as empowerment · 6 points
| 01 | Defendants ran a YouTube channel with 475,000 subscribers posting near-daily videos with titles like ‘Credit Repair Hack That Should Be ILLEGAL But’s It’s NOT!’ to normalize illegal practices. | high |
| 02 | In a February 2020 video, Mr. Rando assured viewers ‘I can assure I won’t be one of those’ scams and promised to fulfill every order, just before rebranding to evade scrutiny. | high |
| 03 | Marketing materials claimed tradelines were the ‘smartest, fastest way to BOOST your credit score’ and emphasized ‘legal loopholes’ to make illegal practices sound legitimate. | high |
| 04 | Defendants positioned themselves as financial educators and mentors, comparing Mr. Rando to ‘Mike Tyson,’ ‘Tiger Woods,’ and ‘Michael Jordan’ to build trust and authority. | medium |
| 05 | Sales pitches emphasized ‘free money’ from stimulus checks, framing COVID relief as an investment opportunity rather than emergency assistance for basic needs. | medium |
| 06 | The operation used glossy websites, DocuSign contracts, and professional branding to create an appearance of legitimacy while violating multiple federal consumer protection laws. | medium |
Wealth Disparity
Extracting from the bottom · 6 points
| 01 | Defendants targeted consumers with credit scores in the 500s, people at the lowest rungs of the economic ladder who paid disproportionately high prices for empty promises. | high |
| 02 | While consumers lost thousands in upfront fees and faced deeper financial hardship, the Randos pocketed over $15 million in revenue from the scheme. | high |
| 03 | The business model externalized all risk onto consumers through non-refundable fees and fake guarantees, while owners faced only eventual regulatory action. | high |
| 04 | Exploiting COVID-19 relief payments meant public funds intended to prevent eviction, hunger, and medical crisis flowed instead into private corporate coffers. | high |
| 05 | Consumers who needed credit repair most, those with negative marks from medical debt or job loss, were precisely the ones charged thousands for services that worsened their situations. | medium |
| 06 | The structure of late-stage capitalism rewarded the Randos for maximizing short-term extraction from vulnerable populations, treating consumer harm as an acceptable cost of profit. | medium |
The Bottom Line
What this reveals · 6 points
| 01 | This case demonstrates how deregulated markets and underfunded enforcement let predatory businesses operate for years, extracting millions before any intervention. | high |
| 02 | The web of shell companies, disclaimers, and rebrands shows corporate structures can be weaponized to evade accountability even when practices are blatantly illegal. | high |
| 03 | Targeting consumers during a pandemic to divert relief funds represents a moral low point where profit motive completely overrides any concept of corporate social responsibility. | high |
| 04 | The pattern of purchasing assets from a company already under FTC investigation, with explicit disclaimers about regulatory risk, proves Defendants knew they were operating illegally. | high |
| 05 | Without systemic reforms including stricter advance-fee prohibitions, centralized registries of bad actors, and enhanced enforcement funding, similar scams will continue to emerge and rebrand. | medium |
| 06 | Credit scoring has become such a pivot point for economic inclusion that scams in this space do not just harm individuals but destabilize entire communities and reinforce intergenerational poverty. | medium |
Timeline of Events
December 2019
Randos purchase cardholder database with 524 tradeline accounts for $152,500 from BoostMyScore LLC, which is under FTC investigation
January 2020
HHS Secretary declares COVID-19 public health emergency under Section 319 of Public Health Service Act
February 2020
Defendants announce closure of Wholesale Tradelines and rebrand as The Credit Game in YouTube video, promising to fulfill all existing orders
March 2020
FTC files complaint against BoostMyScore LLC for selling tradelines; court enters stipulated order in April 2020
December 2020
COVID Related Tax Relief Act passes; Defendants post YouTube video urging consumers to spend stimulus checks on credit repair
March 2021
American Rescue Plan Act passes with $1,400 stimulus payments; Defendants post multiple videos urging consumers to invest stimulus money
July 2021
Child tax credit payments begin; Defendants urge consumers to spend increased credits on credit repair packages
May 2022
FTC files complaint in U.S. District Court Middle District of Florida seeking permanent injunction and monetary relief
Direct Quotes from the Legal Record
QUOTE 1
Knowing purchase of illegal assets
allegations
“First Coast Matchmakers [Inc.] is aware of BMS’ situation with the FTC and understands the risks of operating a tradeline business. Particularly that at any time, a regulator can investigate the operations of any business and force it to cease operations, rendering the assets of this sale unusable.”
💡 This shows Defendants knowingly purchased a business model already under federal investigation and acknowledged it could be shut down.
QUOTE 2
Fraudulent claims to consumers
allegations
“I can remove anything from your credit report.”
💡 Mr. Rando made this blanket promise in an August 2021 YouTube video despite having no ability to legally deliver such results.
QUOTE 3
Exploiting COVID relief
profit
“There is no, absolutely, no risk. No risk. You’re investing free money into a program that has helped so many people change their life and absolutely no risk to you. No risk, zero. You didn’t work for the money [the] government gave it to you.”
💡 This March 2021 pitch encouraged consumers to divert emergency assistance into a scam by framing stimulus checks as free money.
QUOTE 4
Coaching credit report manipulation
allegations
“remove every address and every phone number that is attached to any of the negative accounts… I don’t want this address on my credit report. It’s not mine, I want it off.”
💡 Defendants explicitly coached consumers to lie to credit bureaus about accurate information to suppress negative accounts.
QUOTE 5
False business opportunity claims
profit
“[T]his is a not a five-figure job. Not a six-figure job. This is a seven-figure income job. In my case, it was an eight-figure.”
💡 Mr. Rando made this earnings claim in a February 2021 video without providing required substantiation or disclosures.
QUOTE 6
Deceptive tradeline marketing
allegations
“Broad regulations and legal loopholes allow for you to benefit from being an authorized user on another person’s tradeline (also known as ‘credit piggybacking’)… the history of that account appears on ‘your’ credit report and will be treated as if it was ‘your’ credit history.”
💡 This website claim framed illegal misrepresentation of creditworthiness as a legal loophole.
QUOTE 7
Proof of fake identity theft scheme
allegations
“Additionally, in numerous instances, unbeknownst to the consumers, Defendants have filed, or caused to be filed on the FTC’s identitytheft.gov website, identity theft reports asserting that negative information on consumers’ credit reports resulted from identity theft. In fact, in numerous instances, consumers on whose behalf Defendants filed, or caused to be filed, identity theft reports were not victims of identity theft nor was the negative information in question the result of identity theft.”
💡 Defendants filed false government reports to fraudulently remove accurate negative credit information.
QUOTE 8
Illegal advance fee collection
allegations
“Defendants require consumers to make an upfront payment, often thousands of dollars, before any of their credit repair services have been performed.”
💡 This directly violates the Credit Repair Organizations Act prohibition on charging fees before services are fully performed.
QUOTE 9
Deceptive refund promises
allegations
“Our policy lasts 365 days. If 365 days have gone by since your purchase, unfortunately, we can’t offer you a refund or exchange.”
💡 The website prominently advertised a refund policy that was routinely ignored when consumers requested their money back.
QUOTE 10
Creating false sense of legitimacy
pr_machine
“I’m your Mike Tyson. I’m your, I’m your Tiger Woods. I’m your Michael Jordan, right. I’m your Arnold Schwarzenegger in the gym. I’m that guy that’s going to be able to help you get to the next level fast because I know exactly where the shortcuts are and how to pivot around them.”
💡 Mr. Rando positioned himself as an expert mentor to build trust while running an illegal operation.
QUOTE 11
Admitting proprietary software claims are false
allegations
“Defendants’ claim they have ‘software’ or other proprietary ‘electronic’ methods to challenge and remove information from a consumer’s credit report are false.”
💡 The FTC directly alleges the core technical claims used to market the services were fabricated.
QUOTE 12
Targeting desperate consumers
pr_machine
“[Y]ou might have dealt with people before that were scams, but I can assure I won’t be one of those. Any previous order before February 10th will be handled. I’m not running off with money.”
💡 In the February 2020 rebrand video, Mr. Rando explicitly addressed consumer fears about scams while perpetuating one.
QUOTE 13
Revenue scale
economic
“Defendants claim to have generated more than $15,000,000 in revenue from their unlawful credit repair and education, and business or investment opportunity practices.”
💡 This figure shows the massive scale of consumer harm and profit extracted through illegal practices.
Frequently Asked Questions
What did The Credit Game promise consumers?
The Credit Game promised consumers they could raise their credit scores from as low as the 500s to over 780 in as little as 45 days by removing negative items and adding authorized user tradelines. They also advertised money-back guarantees and claimed to use proprietary software for rapid credit repair.
How did Defendants break the law?
They charged illegal upfront fees before providing credit repair services, filed fake identity theft reports, sold tradelines that misrepresented creditworthiness, coached consumers to lie to credit bureaus about accurate information, failed to provide required disclosures, and made false earnings claims about business opportunities.
What is credit piggybacking and why is it problematic?
Credit piggybacking means adding someone as an authorized user to another person’s credit card so the positive payment history appears on the user’s credit report. When the user is an unrelated stranger who pays a fee but never gets access to the card, it misrepresents creditworthiness to lenders and can violate consumer protection laws.
Did Defendants know what they were doing was illegal?
Yes. They purchased a tradeline database from a company under FTC investigation and signed a Letter of Intent acknowledging regulators could shut down the business. They also rebranded from Wholesale Tradelines to The Credit Game when scrutiny increased.
How did they exploit COVID-19 relief?
Defendants posted YouTube videos urging consumers to spend December 2020 and March 2021 stimulus checks and July 2021 child tax credits on credit repair packages, calling the relief payments ‘free money’ and framing them as investment opportunities instead of emergency assistance.
Were refunds actually provided?
No. Despite advertising a 365-day money-back guarantee, Defendants routinely denied refund requests, claiming consumers only purchased non-refundable educational materials or blaming a separate vendor they actually controlled.
How many companies were involved?
At least seven Florida entities operated as a common enterprise: Prosperity Training Technology LLC, Elite Customer Services LLC, Digital Business Scaling LLC, First Coast Matchmakers Inc and LLC, Financial Consulting Management Group LLC, and Resource Management Investments LLC.
What business opportunity did they sell?
Defendants sold packages claiming consumers could make five-, six-, seven-, or even eight-figure incomes by reselling The Credit Game’s credit repair services and tradelines, without disclosing the underlying practices were illegal.
How much money did they make?
Defendants claim to have generated over $15 million in revenue from credit repair services, educational materials, and business opportunity sales between at least 2019 and 2022.
What can I do if I was a victim?
Contact the FTC through their website or complaint assistant. Monitor your credit reports for fraudulent activity. If you filed an identity theft report at Defendants’ direction that was not accurate, consult a consumer protection attorney. Report the matter to your state attorney general and consider filing complaints with the Consumer Financial Protection Bureau.
The FTC has a press release about this act of misleading marketing and corporate misconduct: https://www.ftc.gov/news-events/news/press-releases/2022/05/ftc-acts-shut-down-credit-game-running-bogus-credit-repair-scheme-fleeced-consumers
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