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p0252 REVIEW DENIED California's Credit Services Act, which requires that all contract modifications be signed, does not single out arbitration clauses and so is not pre-empted by the Federal Arbitration Act; a credit repair association can not unilaterally modify membership contracts to require arbitration by notifying its members by mail and treating their continued membership as an acceptance of the new term..CitationMITCHELL v AMERICAN FAIR CREDIT ASS'N (Credit Repair) 99 CA4 1345 [See: CivC 1789.10 etseq; 9 USC 1 etseq]
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