While this case was poorly defended and
involved egregious facts of alleged wrongdoing that bear no resemblance to the operations of present - day legitimate
credit counseling agencies, including those of Cambridge itself, the court took a broad view of the definition of a
credit repair organization and, as a result, the scope of CROA.
(b) Such books, records, and accounts shall be maintained separate and apart from any other business in which the
organization is
involved and shall be kept at the location in the state at which the
credit repair services activity occurred or at the
organization's principal office unless otherwise permitted in writing by the commissioner.