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Legal Center

Document Center

Service-Provider Disclosure

The website must clearly identify:

  • Which legal entity provides each service.
  • Which legal entity collects each payment.
  • Which entity appears on the customer's billing statement.
  • Which services are provided by Momentum Network.
  • Which services are independently provided by MAC.
  • Which services are provided by Smart Credit / Smart Crédito.

Plan Table

The Legal Center must repeat the exact pricing:

Plan Initial Payment Monthly Recurring
Independent Momentum Partner $249 $149.99
Optima Individual $249.99 $99
Optima Family $299.99 $149

Terms & Conditions

The Terms must address, at minimum:

  • Acceptance, legal capacity, and eligibility.
  • Responsibility for account credentials and activity.
  • Acceptable use of the platforms.
  • Initial payment and automatic renewal.
  • Recurring-billing authorization.
  • Cancellation method.
  • Educational scope of the services.
  • Third-party services.
  • Limitations and absence of guarantees.
  • The applicable service-specific agreement controlling when it conflicts with general website terms.

Privacy Policy

The Privacy Policy must identify:

  • The responsible legal entity.
  • Categories of information collected.
  • Purposes for which information is used.
  • Providers with whom information is shared.
  • Information shared with MAC and Smart Credit / Smart Crédito.
  • Payment processors and technology providers.
  • Retention and security practices.
  • Access, correction, and deletion rights where applicable.
  • Cookies, analytics, and tracking technologies.
  • Effective date and last-updated date.
  • A working privacy contact channel.
Important: Do not collect Social Security numbers, credit documents, financial-account credentials, or credit reports directly through the public website. Sensitive information must only be submitted through the appropriate secure portal.

Cancellation & Refunds

The website must clearly explain:

  • How customers can cancel future renewals.
  • When a cancellation becomes effective.
  • What happens to charges already processed.
  • Where to find the official Refund Policy.
  • Any cancellation rights required by applicable law or contract.
Important: The 90-day guarantee must not appear anywhere on the website.

Income Disclosure and Rules & Conduct

These documents must be visible before anyone can complete enrollment as an Independent Momentum Partner.

Prohibited Representations

Do not present the opportunity as:

  • Employment.
  • A salary.
  • Guaranteed income.
  • Typical income without supporting evidence.
  • A way to replace employment.
  • A solution for paying debts.
  • A guaranteed path to financial freedom.

Payment Transparency

Before accepting payment, checkout must display:

  • The legal name of the entity collecting payment.
  • The descriptor that will appear on the customer's billing statement.
  • The selected plan.
  • The exact initial amount.
  • The exact recurring monthly amount.
  • Billing frequency.
  • Number of people covered.
  • Services included.
  • Third-party services or charges.
  • Cancellation policy.
  • Refund policy.
  • Express consent for recurring charges.
  • Links to all applicable agreements.
The recurring-payment authorization box must not be preselected. Evidence of consent must be retained, and the customer must receive a confirmation that matches the checkout terms.

Credit Optimization and CROA

Before activating any payment flow associated with MAC services, compliance counsel must determine whether the services and payment structure are subject to the federal Credit Repair Organizations Act and applicable state laws.

Important: Changing the commercial name to "Credit Optimization" does not, by itself, eliminate potential legal obligations.

CROA Requirements

If CROA applies, the flow must incorporate all applicable requirements, including:

  • Written consumer-rights disclosures before the contract.
  • A written, dated, and detailed contract.
  • A complete description of the services.
  • Pricing and payment terms.
  • A Notice of Cancellation.
  • The applicable three-business-day cancellation right.
  • The applicable restrictions concerning when payment may be collected.
Critical: Do not activate or configure advance payments for MAC services until the service structure, pricing allocation, contracts, and billing schedule have been approved in writing by compliance counsel and the payment processor.
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