ICS's recorded message uses various names to identify the speaker. "Jim Collins", "Eric Williams", etc. are used to tell consumers, "You may recall receiving an approval letter stating that you have been approved to consolidate your credit cards down to as low as 1.5 percent." The voice also states that he is "surprised" he has not heard from the called party because "you've already been approved by a non-profit agency."

ICS claims to be exempt from the TCPA because it is a for-profit firm, calling on behalf of a non-profit organization. 

ICS is a subsidiary of Flagship Capital Services Corp., a for-profit organization, working in tandem with a non-profit credit-counseling agency called Lighthouse Credit Foundation, Inc. (8550 Ulmerton Rd. Largo, FL 33771).  The three organizations all have the same Largo, Fla., address.

States ( New York Missouri Oregon ) have levied fines against ICS for tens of thousands of dollars.