RMAI Update February 2021

The transition to the new administration continues in D.C. While Biden’s pick for CFPB Director, Rohit Chopra, has not yet been confirmed by the Senate, Dave Uejio has been named Acting Director. Through numerous press releases, Mr. Uejio has announced several directives he is pursuing while leading the CFPB. His overarching theme is to address consumer needs stemming from the pandemic and to assure racial equity in the financial services industry. Specific to the accounts receivables industry, Mr. Uejio has asked Research, Markets & Regulations to explore options for preserving the status quo with respect to QM and debt collection rules. This statement can be interpreted to mean that portions of the just finalized debt collection rule, scheduled to go into effect in November 2021, may be revised. We understand the difficult situation this puts our members in as your work to operationalize the final rule to become compliant. RMAI is in constant contact with the CFPB and will strive to bring clarity to you as it is determined.

On Capitol Hill, we are closely monitoring the latest stimulus package for inclusion of any of the FDCPA provisions proposed in the HEROES Act (that was not adopted). To date, Congress has not included any of those proposals which would dramatically restrict debt collection in the latest bill, and due to some rules regarding reconciliation bills may not be able to include non-monetary policy in the bill. Committee chairs and members are being appointed, and RMAI expects to engage with the committee members in the coming months when Congress completes the impeachment proceedings and moves forward with their agenda.

RMAI is actively monitoring over 100 bills that may impact the receivables industry in both positive and negative ways.  Here are a few noteworthy bills that are pending action:

Connecticut HB 5048 – This bill would increase the homestead exemption to $250,000. Today, the CT homestead exemption is $75,000, “or, in the case of a money judgment arising out of services provided at a hospital” then $125,000.

Hawaii SB 1373 – This bill would prohibit wage garnishments during any Governor-declared emergency and for 60-days after the emergency order has ended. [RMAI issued a memo in opposition highlighting that the Governor has the power to declare emergencies for relatively small events that have no consumer harms associated with them. RMAI suggested that an amendment that applied the bill to the COVID emergency and apply it to only those who have demonstrated a financial impact would be more appropriate.]

New Hampshire HB 109 – This bill would require an affirmative notification prior to referral to collections two weeks prior to referral of any bill to collection. The bill limits what can constitute a notification.

New Mexico HB 36 – This bill would establish an automatic $2,400 bank levy exemption.

New York SB 153 – This bill which is known as the “Consumer Credit Fairness Act” would: (1) reduce the statute of limitations from six to three years on consumer credit transactions; (2) prohibit the revival of a debt that is beyond the statute of limitations through the making of a payment; (3) require the mailing of a notice by the court clerk after filing proof of service of the summons and complaint; (4) require specific data to be included in the complaint; and (5) require the provision of form affidavits. [RMAI has been actively opposing this bill since it was first introduced in 2009. After years of industry offers to negotiate the bill being rejected, the sponsors finally expressed a desire to discuss our concerns. After 13 months of negotiations, the industry was successful at: (1) removing language which would have expunged all debt at the expiration of the statute of limitations; (2) removing pre-charge-off itemization requirements on revolving lines of credit; (3) changing the point of reference on data and documents from origination to charge-off; (4) clarifying a provision of existing law, that some judges were misinterpreting, to make clear that creditors are not required to inform consumers when their accounts are sold in order for the successor parties in interest to be able to collect on those accounts; and (5) extending the effective date by six months to provide the industry time to adjust operational controls as well as accelerate any legal actions under existing law.]

New York SB 1234 – This bill would create a private right of action for improper debt collection procedures and allow plaintiffs to recover punitive damages and reasonable attorney’s fees.

Washington HB 1447 – This bill would establish a temporary automatic $1,000 bank exemption on bank garnishments which would sunset in 2025.

Seventh Circuit Finds Evidentiary Hearing Required for Factual Disputes as to Standing

Bazile v. Fin. Sys. of Green Bay, Inc., 983 F.3d 274 (7th Cir. 2020)

The U.S. Court of Appeals for the Seventh Circuit recently vacated a trial court’s judgment of dismissal and remanded the case with instructions to hold an evidentiary hearing limited to the issue of whether the trial court had subject-matter jurisdiction over a plaintiff’s claim that a dunning letter violated the federal Fair Debt Collection Practices Act.

A debt collector sent a consumer a collection letter that stated the date and the total balance of the debt but didn’t indicate whether the amount may increase due to accruing interest.  On that basis, the consumer sued and the  debt collector moved to dismiss the complaint, arguing that the plaintiff lacked standing to sue and failed to state a claim upon which relief can be granted under Fed. R. Civ. P. 12(b)(6).

The trial court held that the consumer had sufficiently alleged standing because “the violation she alleged amounted to a concrete injury by itself.”  Nevertheless, the trial court agreed with the debt collector on the merits and dismissed the complaint. The consumer appealed.

On appeal, the Seventh Circuit explained that it was “presented with one question about subject‐matter jurisdiction (whether [the consumer] has Article III standing to sue), and one question about the merits of the parties’ dispute (whether [the consumer’s] complaint states a claim upon which relief can be granted).”  The Court, however, never reached the merits  “because jurisdiction is a threshold matter that needs to be further assessed on remand.”

In the words of the Court, “[b]ecause standing is an essential ingredient of subject-matter jurisdiction, it must be secured at each stage of the litigation. At the pleading stage, ‘general factual allegations of injury resulting from the defendant’s conduct may suffice.’”

The Court explained that the defense of lack of subject-matter jurisdiction under Rule 12(b)(1) may be either a facial or a factual attack. “A facial attack tests whether the allegations, taken as true, support an inference that the elements of standing exist. In this way, a facial attack does not challenge the alleged facts themselves. But a factual attack does, testing the existence of jurisdictional facts underlying the allegations.  Accordingly, a plaintiff undergoing only a facial attack enjoys treatment of her allegations as true, but that benefit does not carry into the context of a factual challenge.  In that context, the court may consider and weigh evidence outside the pleadings to determine whether it has power to adjudicate the action.”

The Court pointed out that although the debt collector did not make clear “whether it was launching a facial or factual attack on [the plaintiff’s] allegations,” the debt collector did make “a factual assertion that conflicts with an inference one could reasonably draw from [the consumer’s] complaint: while [the consumer’s] allegations support an inference that interest was accruing on the debt, the collector asserted that interest was not accruing.”

The Court noted that an FDCPA plaintiff must allege and establish “that the statutory violation harmed him” or that it “presented an appreciable risk of harm to the underlying concrete interest that Congress sought to protect.”  Accordingly, the Seventh Circuit turned to address “the key question” of whether the consumer suffered or faced the risk of suffering “a concrete injury from the collection letter’s lack of information about whether the debt amount was increasing from the accrual of interest?”

The Court reasoned that “[t]he nonreceipt of information to which a plaintiff is entitled under a statute may amount to a concrete injury, but only if it impairs the plaintiff’s ability to use [that information] for a substantive purpose that the statute envisioned. In other words, a  bare procedural violation, divorced from any concrete harm, does not satisfy the injury-in-fact requirement of Article III.”

The Seventh Circuit determined that the consumer’s “allegations may support an inference that she suffered a concrete injury” because she alleged that the letter did not contain information to which she was entitled, “which resulted in a misleading or inaccurate statement of the debt’s amount.”  For example, the court noted, had she known whether interest was accruing it may have affected how she prioritized which debts to pay.

Accordingly, the Seventh Circuit vacated the judgment and remanded the case for an evidentiary hearing on whether the consumer had standing to sue.

Seventh Circuit Holds Confusion and Hiring an Attorney is Inadequate for Art. III Standing

Brunett v. Convergent Outsourcing, Inc., 982 F.3d 1067 (7th Cir. 2020)

The U.S. Court of Appeals for the Seventh Circuit recently held that dismissal for lack of subject matter jurisdiction was appropriate where a collection letter did not include a false statement and the consumer conceded that the letter had not injured her, causing only some “confusion” that led her to retain counsel.

The consumer received a letter from a debt collector demanding repayment of outstanding debt.  In the letter, the debt collector offered to accept 50% of the balance in satisfaction of the debt and offered the consumer the opportunity to discuss other available options. The letter also informed the consumer that if more than $600 of the debt was forgiven, the collector would be required to report the forgiven amounts to the Internal Revenue Service as taxable income on a Schedule 1099-C in accordance with federal law.  The amount of the debt was $1,012.

The consumer filed a putative class action complaint against the debt collector on behalf of herself and all other recipients of similar letters, alleging that the statement about IRS reporting violated 15 U.S.C. §1692e(5) and (10) for threatening action that could not be legally taken and making a false representation.

At summary judgment, the trial court considered that the consumer had offered to pay the debt collector $5 a month.  Because that amount was less than the interest accruing on the debt, the court equated it to a request to forgive the entire debt which could have triggered the IRS reporting.  Accordingly, the trial court granted summary judgment in the debt collector’s favor and the consumer appealed.

The Seventh Circuit began by discussing the consumers’ Article III standing, citing several decisions holding that a plaintiff who lacks a concrete injury cannot sue under the FDCPA simply because a statement in a letter is incorrect or misleading.

Here, the consumer testified at her deposition that while the letter had confused her, it did not injure her.  It was undisputed that she did not pay any amounts not owed, and the “statement about the possibility of a report to the IRS did not affect her credit rating or discourage anyone from doing business with her.”

Addressing these facts, the court explained that “[a] debtor confused by a dunning letter may be injured if she acts, to her detriment, on that confusion—if, for example, the confusion leads her to pay something she does not owe, or to pay a debt with interest running at a low rate when the money could have been used to pay a debt with interest running at a higher rate. But the state of confusion is not itself an injury. If it were, then everyone would have standing to litigate about everything.”

Additionally, the fact that the consumer’s confusion led her to retain counsel did not change the Court’s evaluation because “A desire to obtain legal advice is not a reason for universal standing.”

For these reasons, the Seventh Court concluded that the consumer lacked Article III standing and vacated the trial court’s judgment with instructions to dismiss for lack of subject-matter jurisdiction.

Seventh Circuit Explains Article III Standing Requires More than Annoyance

Gunn v. Thrasher, Buschmann & Voelkel, P.C., 982 F.3d 1069 (7th Cir. 2020)

The U.S. Court of Appeals for the Seventh Circuit recently held that a debt collection letter that references a legal remedy that could be pursued but is ultimately not pursued is not itself a sufficient basis to confer Article III standing.

A husband and wife (“consumers”) stopped paying their homeowners’ association dues.  The association hired a law firm, which sent a collection letter that stated “[i]f the Creditor has recorded a mechanic’s lien, covenants, mortgage or security agreement, it may seek to foreclose such mechanic’s lien, covenants, mortgage, or security agreement.” The collection law firm later filed a lawsuit against the consumers to collect the debt, but the only claim asserted in the collection lawsuit was a breach of contract and not to foreclose.

The consumers sued the law firm, alleging the letter was false and misleading and violated subsections 1692e(2), (4), (5) and (10) of the FDCPA because “the law firm would have found it too costly to pursue foreclosure to collect a $2,000 debt.”

The trial court dismissed the complaint, “ruling that a true statement about the availability of legal options cannot be condemned under the [FDCPA] just because the costs of collection may persuade a law firm to seek one remedy (damages) rather than another (foreclosure).”

On appeal, the Seventh Circuit did not reach the merits, instead directing “the parties to file supplemental briefs addressing the question whether plaintiffs have standing to sue” under Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016), and Casillas v. Madison Avenue Associates, Inc., 926 F.3d 329 (7th Cir. 2019).

The consumers argued that “they were annoyed or intimidated by the letter, which as a matter of law satisfies the constitutional injury requirement,” citing Gadelhak v. AT&T Services, Inc., 950 F. 3d 458 (7th Cir. 2020).

The Seventh Circuit disagreed and distinguished Gadelhak because it involved “uninvited and unintelligible text messages, which intruded on the plaintiffs’ seclusion,” but here the consumers did not allege that “the law firm’s letter was a forbidden invasion of privacy.” Instead, the consumers’ “claim is that legally sound language in an otherwise proper letter violated the Act.  Nothing in Gadelhak implies that this has ever been deemed a concrete injury.”

Annoyance, indignation, infuriation, disgust or aggravation are not enough. The Seventh Circuit explained the issue as follows:

Consider the upshot of an equation between annoyance and injury. Many people are annoyed to learn that governmental action may put endangered species at risk or cut down an old-growth forest. Yet the Supreme Court has held that, to litigate over such acts in federal court, the plaintiff must show a concrete and particularized loss, not infuriation or disgust. . . Indeed, it is hard to imagine that anyone would file any lawsuit without being annoyed (or worse). Litigation is costly for both the pocketbook and peace of mind. Few people litigate for fun. Yet the Supreme Court has never thought that having one’s nose out of joint and one’s dander up creates a case or controversy. No one can doubt that the plaintiff in Spokeo was sore annoyed. If that were enough, however, then the very fact that a suit had been filed would show the existence of standing, and the need to have a concrete injury that could be cured by a favorable judicial decision would be abolished.

Because the plaintiffs did not allege that the “contested sentence in the defendant’s letter caused them any concrete harm,” the trial court’s judgment was vacated, and the case was remanded with instruction to dismiss for want of subject-matter jurisdiction.

Seventh Circuit: No Harm or Appreciable Risk of Harm, No Standing

Larkin v. Fin. Sys. of Green Bay, 982 F.3d 1060 (7th Cir. 2020)

The U.S. Court of Appeals for the Seventh Circuit recently concluded that bare procedural violations alleged by collection letter recipients failed to satisfy the “injury-in-fact” requirement to confer standing under Article III as the consumers’ complaint did not allege that the purported FDCPA violations injured them in any concrete way, tangible or intangible.

In March 2017, a debt collector sent a dunning letter to a consumer regarding debt related to medical services.  The letter stated: “You want to be worthy of the faith put in you by your creditor. . . We are interested in you preserving a good credit rating with the above creditor.”

In August and September 2017, another consumer received three similar dunning letters from the debt collector, which, respectively, included the following statements: (1) “Your creditor is interested in you preserving a good credit rating with them”; (2) “You do not want to lose our confidence. You want to be worthy of the faith put in you by your creditor”; and (3) “Your creditor has placed your bill for collection. To avoid errors and to clear your credit record with the above creditor, send or bring your payment to our office, or pay online.”

The consumers, both represented by the same law firm, filed nearly identical class-action lawsuits against the debt collector alleging that the collection letters violated the FDCPA, 15 U.S.C. § 1692, et seq., by containing false, deceptive or misleading statements in violation of § 1692e, and that the statements amount to an unfair or unconscionable means of collecting a debt in violation of § 1692f.

The debt collector moved to dismiss the consumers’ complaints, arguing that the complaint was untimely and failed to state a claim, challenging the consumers’ standing.  The trial court judge concluded that the consumers had standing and timely filed suit but dismissed the complaints for failing to state a claim, holding as a matter of law that the statements within the collection letters did not violate §§ 1692e or 1692f.

The consumers appealed, and the Seventh Circuit consolidated the cases because they presented identical questions of law.

On appeal, the Seventh Circuit initially discussed the consumers’ Article III standing to bring their claims in federal court.  To establish standing, a plaintiff has the burden to establish that she or he has “(1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial ruling.”

Regarding “injury in fact,” the Court explained that “a plaintiff must show that he or she suffered an invasion of a legally protected interest’ that is concrete and particularized and actual or imminent, not conjectural or hypothetical. The key question here is whether [the consumers] have alleged an injury that is both concrete and particularized.”

Here, the Seventh Circuit found that the consumers only generally alleged that certain statements in the collection letters were violative, but neither complaint alleged any resulting harm or “appreciable risk of harm.”

Because the consumers failed to allege that the debt collector’s FDCPA violation injured them in any concrete way, as required under Article III, the Seventh Circuit concluded that their suits should have been dismissed for lack of standing.

Accordingly, the Court modified the judgments to reflect a jurisdictional dismissal and affirmed the trial court’s judgment as modified.

Seventh Circuit: Evidence of “Specific Facts” Required for Article III Standing

Spuhler v. State Collection Serv., 983 F.3d 282 (7th Cir. 2020)

The U.S. Court of Appeals for the Seventh Circuit recently vacated judgment in favor of consumers and certification of a proposed class for claims that a debt collector violated sections 1692e and 1692f of the federal Fair Debt Collection Practices Act (FDCPA) by excluding a statement that interest would accrue on the debts in their collection letters.

Husband and wife consumers incurred medical debts that a debt collector sought to collect on behalf of the medical care provider.  The debt collector mailed letters to the consumers providing the debts’ sums but omitting a statement that interest would accrue on the debts.

The consumers filed a putative class action complaint against the debt collector on behalf of themselves and a proposed class of all recipients of the collection letters alleging that the letters’ omissions of a statement that interest would accrue on the debts violated the FDCPA, 15 U.S.C. § 1692, et seq., by containing false, deceptive, or misleading statements in violation of § 1692e, and that the statements amounted to an unfair or unconscionable means of collecting a debt in violation of § 1692f.

The trial court entered summary judgment in the consumers’ favor and certified a class.  This appeal followed.

On appeal, the debt collector argued: “(1) the consumers lack standing to sue based on the letters’ lack of a statement about interest; (2) the consumers are otherwise not entitled to judgment as a matter of law because no statement about interest was required under the FDCPA; and (3) class certification was improper.”

As a threshold issue, the Seventh Circuit explained that to establish standing, a plaintiff must establish: “(1) the plaintiff suffered a concrete and particularized injury in fact; (2) the injury is fairly traceable to the challenged conduct; and (3) the injury is likely to be redressed by a favorable judicial decision.”

The debt collector argued that the consumers lacked standing for failing to allege a concrete injury in fact.  However, the Seventh Circuit found this argument “misplaced because it relies on the standard for demonstrating standing at the pleading stage: whether the plaintiffs clearly alleged facts that plausibly suggest they have standing.”  Instead, the applicable standard at the summary judgment phase “is whether the plaintiffs have supplied evidence of ‘specific facts’ that, taken as true, show each element of standing.”

The consumers argued the collection letters’ failure to include a statement that the debts would accrue interest was misleading in violation of sections 1692e(2)(A) and 1692f of the FDCPA and was enough, by itself, to establish a concrete injury necessary for standing.  However, for a concrete injury to result from the purported FDCPA violation, the Court reasoned that the collection letters’ exclusion of a statement about accruing interest must have detrimentally affected the debtors’ handling of their debts.

Here, the consumers failed to present any record evidence that the absence of the statement affected how they responded to the collection letters or managed their debts, or even took any action to seek information whether the debts were accruing interest.

For these reasons, the Seventh Circuit concluded that the consumers’ claims were non-justiciable, as they failed to set forth evidence of specific facts demonstrating they suffered a concrete injury necessary for standing.

Accordingly, the trial court judgment in favor of the consumers and certifying a class was vacated and remanded for proceedings consistent with this opinion.

RMAI actively monitors and responds to state and federal measures affecting how our members do business. Your contributions to the Legislative Fund extend the reach of RMAI’s advocacy across the country where and when needed. Read more about the Legislative Fund here. If you are not currently contributing to the Legislative Fund, please make a contribution of any amount. You can donate online or send your fill out our contribution form and send via email or by check.

Our proactive advocacy efforts are especially important during this time of transition to a new administration and COVID-19 pandemic as legislators and regulators rush to take action. RMAI is grateful for members’ generous support of the Legislative Fund.

2021 Virtual Silent Auction a Resounding Success

RMAI’s 2021 Virtual Silent Auction to support the Legislative Fund ended on February 10^th by raising a total of $18,340.01. Thank you to our silent auction organizers for presenting the fundraiser, to all of our silent auction donors for donating a compelling mix of auction catalog items and to all of our silent auction winners for contributing to the Legislative Fund and winning awesome items in the process!

The next fundraising event to support the Legislative Fund is the Experience Auction at the 2021 Annual Conference at the Aria Resort & Casino in Las Vegas.

UPCOMING WEBINARS

LIVE MONTHLY WEBINARS (Free to Members) *

Hot Topics in Agency Enforcement/Handling AG Inquiries, Wednesday, February 24, 2021 at 9:00am PT/12:00pm ET

ANNUAL CONFERENCE ‘LIVE’ WEBINARS (MARCH AND APRIL)  – REGISTER HERE

Licensed to Thrive – Managing Collection Agency Licensing Issues, Wednesday, March 17^th at 9:00am PT/12:00pm ET

Regaining Contactability and Trust in Consumer Communications, Wednesday, March 24^th at 9:00am PT/12:00pm ET

Preparing for, Managing, and Cleaning Up/Remediating Federal and State Investigations, March 31^st at 9:00am PT/12:00pm ET

Diversity & Inclusion: Having the Difficult Conversations with your Staff, Wednesday, April 7^th at 9:00am PT/12:00pm ET

RECORDED WEBINARS

CHIEF COMPLIANCE OFFICER WEBINAR SERIES

Reaching Consumers/Persons by Telephone Under the CFPB’s New FDCPA Rule, held on December 3, 2020

Email and Safe Harbor – How to Navigate New Regulation F’s Bona Fide Error Defense, held on December 10, 2020

Text Messaging & Safe Harbor – How to Navigate New Regulation F’s Bona Fide Error Defense, held on December 17, 2020

Time, Place, and Manner – Oh My! Breaking Down Reg. F’s Requirements and Strategies for Compliance, January 7, 2021 at 9:00am PT/12:00pm ET, held on January 7, 2021

Letters – Regulation F’s Do’s and Don’ts, held on January 14, 2021

Get certified in 2021 through RMAI Receivables Management Certification Program. Check out these helpful resources to learn how to earn the CRCP, CRB and CRV designations:

• 7 Steps for Individual Certification
• 7 Steps for Business Certification
• 7 Steps for Vendor Certification

Did you know that if your Certified Business has one or more affiliated business entities (debt buying company, law firm, collection agency, creditor), you can certify them as a Family of Companies for ONLY $150 each?

Your affiliated business entities must meet the following criteria to qualify for a Family of Companies under the same Certification:

• Have the same Chief Compliance Officer
• Have the same executive management team that exerts control over business operations
• Maintain a uniform network of compliance on all accounts serviced between the business entities
• Be governed by the same corporate policies and procedures
• Agree to be audited in a single unified audit
• Agree deficiency and remediation against one business entity will apply to all of the business entities

Learn how to add a Family of Companies by clicking here.

CONGRATULATIONS TO OUR NEW & RENEWAL CERTIFIED BUSINESS, INDIVIDUALS, AND NEW FAMILY OF COMPANIES!

CRCP – New
Jason Clark – Superlative RM 
Javier Palmero – Hilco Receivables, LLC
Rachel Portnoy- — Portnoy Schneck L.L.C.
Elizabeth Stockbridge – The Axiom Group

CRCP – Renew
Todd Gurstel – T&I Enterprises, LLC Gurstel Law Firm PC
Tyler Peska – Credit Management Corporation

CRB – Renew
The Bureaus, Inc.

Family of Companies New –
Orion Portfolio Purchasing LLC

View all certified businesses and vendors.

View all certified individuals.

For questions about certification, contact Brianna Halsey at (916) 482-2462 or [email protected].

RMAI’s leadership cultivates relationships within the receivables management industry to expand business opportunities for members.

Please be aware, we have heard recent reports of scammers offering to sell our Annual Conference attendee list, posing as representatives of RMAI and potentially even using our logo. RMAI does not sell its exhibitor or attendee lists, and no third-party is authorized to distribute or sell any lists related to our events.  Any claims of this sort are fraudulent. If you receive a message making this kind of claim, do not engage and delete the message.

Thank you to our February 2020 – February 12, 2021 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Financial Recovery Services, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Titanium $15,000

Velocity Portfolio Group, Inc.

Platinum $10,000

CKS Financial

Crown Asset Management, LLC

Encore Capital Group, Inc.

Unifund CCR LLC

Gold $7,500

First Financial Portfolio Service, LLC

C&E Acquisition Group, LLC/Diverse Funding Associates, LLC/DNF Associates

Silver $5,000

Collins Asset Group LLC

Oliphant United, LLC

The Bureaus, Inc.

U.S. Equities Corp.

Bronze $2,500

Investment Retrievers, Inc.

National Loan Exchange, Inc.

RAzOR Capital, LLC

SAM, Inc. – Solutions for Account Management

Security Credit Services, LLC

Tobin & Marohn

Brass $1,000

Andreu, Palma, Lavin & Solis, PLLC

Balbec Capital, LP

Ballard Spahr LLP

Butler & Associates, P.A.

Capio

C & E Acquisition Group

Central Portfolio Control, Inc.

Digital Recognition Network

Equifax, Inc.

Gaskell & Giovannini, LLC

Halsted Financial Services, LLC

Investinet, LLC

Investment Retrievers, Inc.

Jefferson Capital Systems, LLC

Jormandy, LLC

Kino Financial Co., LLCF

Plaza Services, LLC

Pressler, Felt and Warshaw, LLP

Resurgence Capital

Stenger & Stenger P.C.

Stephen L. Bruce & Associates

The Cadle Company

The Law Offices of Ronald S. Canter, LLC

TrueAccord

United Holding Group

Verifacts, Inc.

Vertican Technologies, Inc

Other

Accelerated Data Systems

Acctorp International, Inc.

Action Collection Agencies, Inc.

Aldridge Pite Haan, LLP

Alliance Credit Services, Inc.

Alpha Recovery Corp.

Andreu, Palma, Lavin & Solis, PLLC

Applied Innovation, Inc.

Arko Consulting LLC

ARM Compliance Business Solutions, LLC

ATKB Portfolio Management

Attunely Inc.

Ballard Spahr, LLP

Bloom & Associates, P.A.

Capital Collection Management, LLC

Cascade Capital, LLC

Central Research, Inc.

CMS Services

Collins Asset Group

Commercial Credit Group Inc.

Complete Credit Solutions

Comtronic Systems, LLC

Convergence Acquisitions, LLC

Converging Capital, LLC

Convoke, Inc.

Credit Control, LLC

Credit Management Corporation

CSS Impact!

D & A Services, LLC

D. Scott Carruthers, APLC

David Reid

DebtTrader

Delev & Associates, LLC

Delta Outsource Group, Inc.

DNF Associates LLC

Dynamic Recovery Solutions

Faloni Law Group, LLC

FLOCK Specialty Finance

FMS, Inc.

FocusOne, Inc.

Full Circle Financial Services, LLC

J. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Glass Mountain Capital, LLC

Harvest Strategy Group, Inc.

Hunt & Henriques

Indiana Receivables, Inc.

Invenio Financial, a Phillips & Cohen Associates Company

Jan Stieger

Keith D. Weiner & Associates Co., LPA

Kelly Knepper- Stephens

Kino Financial Co., LLC

Kirschenbaum & Phillips, P.C.

Law Office of James R. Vaughan, P.C.

Law Offices of Daniel C. Consuegra, P.L.

Law Offices of Steven Cohen, LLC

Lippman Recupero

Lockhart, Morris & Montgomery, Inc.

Logicoll, LLC

London & London

LTD Financial Services

Malone Frost Martin PLLC

Maurice Wutscher LLP

Mercantile Adjustment Bureau, LLC

Metronome Financial LLC

Monarch Recovery Management, Inc.

MRS BPO, LLC

Mullooly, Jeffrey, Rooney & Flynn, LP

National Check Resolution, Inc.

National Enterprise Systems, Inc.

National Recovery Associates

NCB Management Services, Inc.

NDS, LLC

Nelson & Kennard

Neustar, Inc.

Nuvei

Ontario Systems, LLC

Orion Capital Solutions, LLC

Palinode, LLC

PCI Group, Inc.

PerSolve, LLC

Pharus Funding, LLC

Phin Solutions, Inc.

Portfolio Recovery Associates, LLC

Portnoy Schneck, L.L.C.

Poser Investments, Inc.

Premier Forty Financial, LLC

ProVest

Quantum3 Group, LLC

Resource Management Services, Inc

RevSpring

RIP Medical Debt

Robinson Hoover & Fudge, PLLC

SCORE Statistical Consulting

Simmonds & Narita LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Troy Capital, LLC

United Holding Group

Universal Fidelity LP

US Mortgage Resolution, LLC

USI Solutions, Inc.

VanDerHeyden Law Office PA

Vargo & Janson, P.C.

Venable LLP

Venandi Systems, LLC

Viking Client Services, Inc.

VoApps

Wipfli LLP