RMAI Update August 2021

Register for Advocacy, Baseball and/or Golf! Whether you hit a single, a double or a triple, this three-component networking event is a home run for receivables management professionals. Tee off for golf on Monday, and join us for an opening reception in the evening. Then on Tuesday, get an in-depth look at RMAI’s advocacy program and a grassroots tool kit, and top it all off by enjoying an Atlanta Braves baseball game from The Back Porch.

Space is limited so REGISTER NOW for one, two or all three components of this event. Check out the discounted package rate for both the advocacy program and the baseball game.

To the industry’s surprise, the CFPB withdrew the proposed extension of the implementation date for the debt collection rules. This means we are back to an implementation date of November 30, 2021. While RMAI requested a delayed enforcement date of 60 days (instead of extending the effective date) to allow additional time for members to ensure compliance with the debt collection rules, the CFPB did not publicly indicate there would be any delay in enforcement.

As of now, CFPB Director nominee, Rohit Chopra, has not been confirmed by the US Senate. The House and the Senate are now out for summer recess through August. We anticipate the Senate will narrowly confirm Director Chopra when they return in September.

RMAI continues to monitor actions on Capitol Hill. RMAI fully supports recently introduced legislation by Congressman Blaine Luetkemeyer (R-MO) to change the CFPB leadership from a single director to a bipartisan commission of five, similar to other federal commissions such as the FTC and the FCC.  A commission structure would provide much needed regulatory stabilization to the financials services industry instead of the instability created with each change in the executive branch. RMAI does not believe this bill has the potential of passing as it does not have bipartisan support. On the Senate side, we are in close contact with Senate Banking ranking staff on potential data and documentation legislation. We have been asked to share industry best practices as well as state requirements.

Congress continues to be spending their time on infrastructure and budget issues, leaving little time for other issues. Our K&L Gates team is closely monitoring negotiations to ensure that FDCPA amendments, which would harm the industry, are not slipped into these mega omnibus bills as they make their way through the legislative process.

RMAI monitors, tracks, and responds to legislative and regulatory activity in all 50 states as the need arises.  Backed by RMAI’s State Legislative Committee and a team of state lobbyists, RMAI educates legislators about the industry and the negative impacts or unintended consequences a bill would have on businesses and consumers. In 2021, RMAI continued with its impressive track record of success. The following are some recent developments at the state legislative level that might be of interest:

California AB 1020 – This bill would among other things prohibit the sale of hospital debt to debt buyers. [RMAI has been working collaboratively with the bill’s author on amendments that would remove the ban on sales to debt buyers and is cautiously optimistic it will be amended in the next week. RMAI strongly opposes the provision of any bill which prohibits the sale of an entire asset class of debt. We view this as a dangerous precedent which could be used in the future to prohibit the sale of other asset classes.]

California SB 531 – This bill would require collection agencies to provide certain data and documents to a consumer upon request. The data and documents are identical to the requirements for debt buyers contained in the California Fair Debt Buying Practices Act which was adopted in 2013. [The author amended the bill to address several concerns raised by RMAI.]

District of Columbia B 348 with 8/3/21 amendments – This temporary legislation will be in effect for 225 days to provide the DC City Council the opportunity to adopt permanent legislation. This bill would adopt a significant overhaul to DC’s debt collection laws related to collection activity and litigation. Among other things, the bill: (i) expands the prohibitions on deceptive behavior; (ii) prohibits debt collectors from making more than three phone calls to a consumer in seven days; (iii) requires debt collectors to have complete documentation related to the consumer debt being collected; (iv) requires debt collectors to provide extensive data and documents to the consumer within 15 days of a written request; (v) requires lengthy consumer notices informing consumers of their rights; (vi) requires debt collectors who enter into a payment schedule or settlement to provide a written copy of the schedule or agreement; (vii) adds specific requirements for a debt collector when initiating a cause of action against a consumer for consumer debt; and (viii) increases damages that can be awarded to a consumer for violation of the act. [RMAI retained a DC lobbyist to advocate on behalf of the industry. RMAI and an industry coalition were successful in: (a) adding exemptions to the call cap limitation, (b) eliminating pre-charge-off itemization of credit card debt; (c) eliminating the requirement for 24 months of statements; (d) eliminating unsolicited mailing requirements foisted upon debt collectors involving sensitive consumer data; (e) eliminating a requirement that the “original account number” be in the bill of sale; (f) eliminating mandatory punitive damages; and (g) eliminating a “per violation” penalty. More work needs to be done on the “permanent” bill which will be adopted sometime this Fall.]

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. [This bill has passed both houses of the State Legislature and the Governor is expected to sign the bill into law. RMAI had 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.]

Multiple Hunstein Cases Dismissed for Lack of Standing in Eastern District of New York

In re FDCPA Mailing Vendor Cases, Civil Action No. 21-2312, 2021 U.S. Dist. LEXIS 139848 (E.D.N.Y. July 23, 2021)

On July 23, U.S. District Court Judge Gary R. Brown issued an opinion in a consolidated matter dismissing multiple complaints alleging debt collectors violated the FDCPA by transmitting consumer information to letter vendors engaged to print or send dunning letters, and scolded plaintiff’s attorneys who “manipulate” the FDCPA for their own personal gain.

The dismissed claims were premised upon the recent decision from the U.S. Court of Appeals for the Eleventh Circuit in Hunstein v. Preferred Collection & Mgmt. Servs., No. 19-14434, 2021 U.S. App. LEXIS 11648 (11th Cir. Apr. 21, 2021).

In In re FDCPA Mailing Vendor Cases, Judge Brown cites the actual purpose of the Fair Debt Collection Practices Act, which is to “eliminate abusive debt collection practices by debt collectors,” and highlighted a few early cases where such abusive practices occurred such as calling a consumer suffering from mental instabilities 9,500 times over 11 months and making threats of false arrests.

However, he observed that “legions of FDCPA cases that have little to do with the purpose of the statute” have inundated the Eastern District of New York, and noted other judges who complained of the “’cottage industry of plaintiffs’ lawyers filing suits over fantasy harms the statute was never intended to prevent.”  Judge Brown explained that many judges have had to adopt FDCPA-specific procedures to deal with the tremendous influx of cases.

Analyzing the Supreme Court’s recent decision in TransUnion LLC v. Ramirez, No. 20-297, 2021 U.S. LEXIS 3401 (June 25, 2021), in connection with the Hunstein letter vendor cases, the Court concluded that none of the plaintiffs had standing because none of them sufficiently alleged a concrete and particularized injury-of-fact sufficient to satisfy Article III standing.

It must also be noted that the Court was skeptical that Hunstein complaints were valid in the Second Circuit to begin with, noting that Hunstein was not even binding on the courts. In any event, after TransUnion there could be no doubt.

First, the Court noted that TransUnion itself likely disposes of Hunstein cases with its reasoning that “many American courts did not traditionally recognize intra-company disclosures as actionable publications for purposes of the tort of defamation” and rejection of the argument that TransUnion had “published” the class members’ information internally to employees.

Next, given TransUnion’s holding that “future risk of harm, standing alone, cannot qualify as a concrete harm,” the speculative nature of the Hunstein claims could not support Article III standing.

Finally, the Court reasoned that the complaints as pleaded could not plausibly demonstrate injury-in-fact under traditional defamation or intentional infliction of emotional distress theories because “simply mailing a collection letter, even if erroneous, is a far cry from ‘extreme and outrageous conduct.’”

After disposing of the Hunstein claims, the Court went on to address another popular theory that “the debts in question were not, in fact owed, and therefore constitute actionable deceptive practices.” But since neither of those plaintiffs alleged any actual injury from receiving the purportedly false notice, the Court held that “informational violations of the statute, without alleging any harm” do not confer standing.

The dismissals were without prejudice, giving the plaintiffs 14 days file amended complaints properly alleging some actual injury-in-fact or to file in New York State court.

FCRA Claims Claiming Insufficient Investigation Rejected by Seventh Circuit

Chuluunbat v. Experian Info. Sols., Inc., Nos. 20-2373, 20-2392, 20-2775, 20-2776, 20-3000, 20-3351, 20-3368, 2021 U.S. App. LEXIS 20973 (7th Cir. July 15, 2021)

Seven unrelated consumers incurred credit card debts that were subsequently “sold and assigned” to other creditors.  The change in ownership was reported to the three prominent credit reporting agencies, and the new creditors attempted to collect the debts.

A debt collector filed suit against three of the consumers to collect payment, but voluntarily withdrew the suits after the consumers claimed that the new creditor did not own their debts, demanded proof of ownership, and requested arbitration.  The other four consumers were not sued but sent letters to their respective debt collectors similarly challenging their purported ownership of the debts.

The consumers then contacted the CRAs requesting an investigation into the accuracy of their reports to determine if the new creditors, in fact, owned the debts.  The new creditors responded to the CRAs’ inquiries by confirming ownership but did not produce the original sale or assignment agreements.  Relying upon these representations, the CRAs informed the consumers that the ownership was confirmed, and their investigation was complete.

Each consumer separately filed suit against the CRAs claiming that their inclusion of allegedly false debt ownership information on their credit reports and failure to fully investigate their claims violated sections § 1681e(b) and § 1681i of the FCRA.

In each case, the trial court entered judgment on the pleadings or dismissed each suit in the CRA’s favor for various reasons, but all concluding that the consumers did not plead the type of inaccuracies in their credit reports that the CRAs had a duty to reinvestigate under the FCRA.  The instant consolidated appeal followed.

The FCRA primarily tasks furnishers (creditors, debt collectors, and the like) with providing accurate information to the CRAs, but also requires that CRAs “follow reasonable procedures to assure maximum possible accuracy of” information in credit reports (15 U.S.C. § 1681e(b)) and “conduct a reasonable reinvestigation” to determine whether information disputed by a consumer is inaccurate (15 U.S.C. § 1681i(a)(1)(A)).  A threshold requirement for claims under both sections is that there must be an inaccuracy in the consumer’s credit report.

The Seventh Circuit initially noted that it recently held in Denan v. Trans Union LLC, 959 F.3d 290 (7th Cir. 2020), that “inaccurate information under 1681 . . mean[s] factually inaccurate information,” rather than “’legal inaccuracies’ which are outside the competency of the consumer reporting agencies.”

Here, the consumers argued that whether the creditors were assigned and now owned their respective debts was a factual question, thus triggering the CRAs’ obligations under sections 1681e(b) and 1681i(a)(1)(A), relying upon the Court’s holding in Chemetall GMBH v. ZR Energy, Inc., 320 F.3d 714, 720–21 (7th Cir. 2003), that a party’s intention to assign something is a question of fact for a jury.  The consumers reasoned that upon receipt of a dispute, a straightforward factual inquiry by the CRAs to request the relevant purchase and sale agreement would determine whether the creditor or debt collector owned the debt.

The Seventh Circuit noted that although no clear line has been drawn between legal and factual inaccuracies in the FCRA context, review of its own decisions and those of its sister circuit courts showed that the central question is whether the alleged inaccuracy turns on applying law to facts or simply examining the facts alone.  Consumer reporting agencies are competent to make factual determinations, but they are not charged with reaching legal conclusions or resolving alleged inaccuracies under the FCRA.

Unlike a challenge to the existence or amount of the debt, the Seventh Circuit concluded that the question of whether the disputed debts were assigned was a question that required a legal determination.

In each case here, the CRA reached out to the debt collectors and asked them to confirm ownership of the debts, which they did.  Any further investigation into whether the debts were actually assigned to the debt collectors involved more than just determining if an assignment agreement exists, but also interpreting the legal validity of any assignment – a legal judgment outside the scope of a CRA’s competency.

The Seventh Circuit further noted that the consumers did have alternate recourse in that they could confront the creditors, who are in the best position to respond to assertions that they do not own the plaintiffs’ debts, or make notations of their disputes on their credit reports pursuant to 15 U.S.C. § 1681i(c), to notify future employers or creditors that they dispute the ownership of these debts.

Because the alleged inaccuracies involved interpreting legal rights to a debt and making legal judgments, the Seventh Circuit agreed with the trial court’s holding that the CRAs bore no burden under the FCRA to determine whether the consumer’s debts were validly assigned to the debt collectors, and affirmed each judgment entered in the debt collectors’ favor.

8th Circuit Holds FDCPA Inapplicable to Certain Loss Mitigation and Foreclosure Communications

Heinz v. Carrington Mortg. Servs., LLC, No. 19-3717, 2021 U.S. App. LEXIS 20338 (8th Cir. July 9, 2021)

The U.S. Court of Appeals for the Eighth Circuit recently affirmed entry of summary judgment in favor of a mortgage servicer against a borrower’s claims that it violated the federal Fair Debt Collection Practices Act (FDCPA).

In September 2016, the assignee to a twice-modified mortgage loan initiated foreclosure proceedings and advised the homeowner-borrower that a foreclosure sale was scheduled for August 1, 2017.  The borrower again applied for loss mitigation assistance but was notified in March and May 2017 that his application was incomplete for failure to provide required documentation and was no longer under review.

On July 11, 2017, the borrower’s mortgage loan was transferred to a new servicer.  After being provided notice of the transfer, the borrower spoke with a representative of the servicer who confirmed that the August 1, 2017, foreclosure sale would proceed, but invited the borrower to submit a loss mitigation package if he wished to prevent the sale.

The borrower contacted the Minnesota Attorney General’s Office for assistance, who agreed to represent the borrower and whom the borrower asserts he relied upon to relay communications and information regarding his loan from the servicer.

The foreclosure sale was subsequently postponed to September 9, 2017, and later to November 14, 2017. Between August and November 2017, the borrower submitted requests and documentation for mortgage assistance, and the Minnesota AG’s Office notified the borrower that, on November 7, 2017, the servicer confirmed to the AG’s office that the borrower’s application was complete and would force postponement of the foreclosure sale while awaiting a final determination.

Nevertheless, the scheduled sale proceeded and the mortgagee purchased the property.  The borrower subsequently received a letter from the servicer dated two days after the sale, which advised him that his loss mitigation application had been canceled and would not be considered.

During the six-month redemption period, the AG’s Office requested that the servicer rescind the sale on the borrower’s behalf, and the servicer refused.  The letter explaining the decision stated that the borrower failed to provide all requisite documentation to complete the loss mitigation application and that the home had been sold to a third-party bidder at the foreclosure sale, although it had in fact been sold to the mortgagee.

The borrower filed suit against the servicer in Minnesota state court, alleging that the servicer violated the FDCPA by making false representations about the borrower’s loss mitigation application and the foreclosure sale by ignoring his application and delaying communications so that the borrower could not take advantage of his legal remedies, along with various state law claims and requests for injunctive relief seeking rescission of the foreclosure sale and preventing eviction.  The servicer removed the action to federal court, and by the summary judgment stage, the borrower’s FDCPA claim was the lone remaining cause of action.

The trial court granted summary judgment in the servicer’s favor, concluding that its communications and conduct with the borrower were not in connection with an attempt to collect a debt and that any post-sale communications were immaterial as they had no impact on the borrower’s legal rights.  The borrower timely appealed.

On appeal, the lone issue before the Eighth Circuit was whether certain challenged communications and conduct were made in connection with the collection of a debt.

These included the servicer’s: (1) pre-sale letter cancelling his loss mitigation application for purported failure to provide requested documents; (2) response to the AG’s complaint; (3) representations by phone to the AG’s office that the borrower’s application was sent to underwriting and awaiting a decision, and; (4) post-sale letter stating that the servicer did not receive all necessary information to complete the application before the deadline (along with prior representations it was complete), and that the property was sold to a third party (when, in fact, it was sold to the mortgagee).

The borrower argued that the trial court erred in granting summary judgment because the evidence presented was sufficient to allow a jury to conclude that the servicer used false, deceptive, and misleading representations and unfair and unconscionable means to collect on the underlying mortgage debt and erroneously narrowed the “animating purpose” test.

The Eighth Circuit employs the “animating purpose test” to consider whether certain statements for conduct are in connection with the collection of a debt for the purposes of section 1692e of the FDCPA, which prohibits the use of any false, deceptive, or misleading representation or means in connection with the collection of a debt.

Under this test, for a communication to be in connection with the collection of a debt, an animating purpose of the communication must be to induce payment by the debtor.  An explicit demand for payment is not required for a communication to satisfy the animating purpose test; implicit demands for payment may satisfy the test based upon the specific content of the communications.  Though the “animating purpose” of the communication is a question of fact that generally is committed to the discretion of the jurors, not the court, where a reasonable jury could not find that an animating purpose of the statements was to induce payment, summary judgment is appropriate.

The borrower argued that the Supreme Court of the United States, in Obduskey v. McCarthy & Holthus LLP, 139 S. Ct. 1029, 1036 (2019), indicated that nonjudicial foreclosure is a debt collection activity, even if the FDCPA exempts nonjudicial foreclosing parties from the definition of “debt collector.”  Therefore, each of the identified communications were in connection with the attempt to collect a debt.

However, the Eighth Circuit noted that because the Supreme Court statement in Obduskey was rendered in consideration of whether a party qualified as a “debt collector” for the purposes of the FDCPA, and not in consideration of specific communications regarding foreclosure proceedings, the communications at issue still required individual consideration.

Reviewing the content of each of the communications, the appellate court agreed that none were made in connection with the collection of a debt.

Specifically, neither the pre-sale letters to the borrower and AG’s office, nor the phone call between the servicer and the AG’s office evidenced any mention of the loan apart from identifying information and did not provide amounts due or demands for payment.

To the contrary, the Court found that these communications “arguably served to thwart” the servicer’s attempts to arrange for payment of the mortgage indebtedness.  Similarly, the post-sale letter contained only basic identifying information of the loan and was not an attempt to collect a debt because the property had already been sold, and thus, any purported misrepresentations were also immaterial.

Moreover, despite the inclusion of a “mini-Miranda” statement including language that the communications were “for the purpose of collecting a debt,” the boilerplate language did not automatically trigger the protections of the FDCPA.

Because the servicer’s conduct was not made or carried out in connection with an attempt to collect a debt, the Eighth Circuit also rejected the borrower’s arguments that the servicer ignored the borrower’s loss mitigation application and delayed communications to run out the statute of limitations on a potential claim of a violation of the Minnesota dual-tracking statute in violation of § 1692f.

Accordingly, the trial court’s entry of summary judgment in the servicer’s favor was affirmed.

Executive Summit Silent Auction & Live Experience Auction Raise Record Funds on August 3!

It’s safe to say that RMAI members are the best! The Executive Summit virtual silent auction was a great success and as always, the proceeds from the auction go directly to RMAI’s Legislative Fund. Bidders vied for 28 items to support RMAI’s future advocacy efforts. In addition to the silent auction, Executive Summit attendees participated in RMAI’s first-ever Live Experience Auction, with the proceeds also going directly to RMAI’s Legislative Fund. Attendees upped the ante by bidding on six exclusive experiences! All total, both auctions raised more than $50,000.

About the Legislative Fund

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.

WATCH WEBINARS

Register for RMAI’s next monthly webinar on August 25^th, The Future of Technology Driven Collections, focusing on how your company can leverage technology for the future. View our Live Webinar page on the RMAI website for future webinars.

View our Online Education selection and register for previously recorded webinars including the most recent webinar hosted on July 20^th, DC Emergency Legislation All recorded monthly webinars are FREE to RMAI members. (Special series and select required courses for certification are offered at a discounted member rate.)

SPONSOR WEBINARS

Get your business name and logo in front of a captive audience of your colleagues and RMAI members when you sponsor a webinar! View our Webinar Sponsorship Flyer for details and benefits of a sponsorship.

Contact Shannon Parod at [email protected] or 916.482.2590 with any questions.

Congratulations to our new and renewed Certified Receivables Compliance Professionals (CRCP) and new and renewed Certified Receivable Businesses (CRB)!

CRCP – New
Debra Jolynn Cook, Director of Compliance – Oliver Adjustment Company, Inc.
Chad Hollins, Vice President of Sales – CBK, Inc.
Samantha Inman, Compliance Specialist – Stenger and Stenger PC
Michael Kane, Chief Compliance Officer – Unifund
Kerstin McFarlane, Chief Operating Officer – River Heights Capital
Ginny Rodriguez, Chief Compliance Officer – Plaza Services LLC

CRCP – Renewals
Steven Cohen, Attorney – Law Office of Steven Cohen, LLC
Svetlana Denekamp, Managing Attorney, Compliance Officer – Resurgence Capital LLC
Michael Lagana, VP Client Services – Klima, Peters & Daly P.A.
Bill Sorgatz, Director of Outsourcing & Litigation – The Bureaus, Inc.
Rance Willey, CEO/CCO – Troy Capital, LLC
Christopher Asbrock, COO – Debt Management Partners, LLC

CRB – New
Accelerated Portfolio, Inc.
Coastal Settlement Recovery, Inc.
SMS Financial LLC

CRB – Renewals
Consuegra & Duffy, P.L.L.C. (Formally known as Law Offices of Daniel Consuegra)
Credit Corp Solutions, Inc and family of companies
Hilco Receivables, LLC
Poser Investments, Inc
Crown Asset Management, LLC

DID YOU EARN EDUCATION CREDITS AT THE EXECUTIVE SUMMIT?

If you attended the 2021 RMAI Executive Summit in Stowe, Vermont, and any of the education sessions, you’ve earned credits which qualify towards the Certified Receivables Compliance Professional (CRCP) designation. The CRCP certification is intended for receivables management industry professionals. Individuals who earn the CRCP designation take continuing education every two years to renew the CRCP designation.

To put credits you earned at the Executive Summit toward initial or renewal certification, send your credit form to [email protected]. If you do not have the credit form, you can get the credit form here.

View all certified businesses and vendors.
View all certified individuals.
View educational requirements for certified individuals.

For questions about certification, contact RMAI at 916-482-2462 or email [email protected].

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

RMAI 2021 Atlanta Regional Event | September 27-28, 2021

NACARA 28th Annual Meeting | October 4-6, 2021

RMAI 2022 Annual Conference | February 7-10, 2022

Note the RMAI office will be closed September 6, 2021 in observance of Labor Day.

Thank you to our August 2020 – August 10, 2021 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Titanium $15,000

Velocity Portfolio Group, Inc.

Platinum $10,000

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

CKS Financial

Crown Asset Management, LLC

Encore Capital Group, Inc.

Unifund CCR LLC

Gold $7,500

DebtTrader

First Financial Portfolio Service, LLC

Silver $5,000

Collins Asset Group LLC

NCB Management Services, Inc.

Oliphant United, LLC

Pharus Funding, LLC

Superlative RM

The Bureaus, Inc.

U.S. Equities Corp.

Bronze $2,500

Absolute Resolutions Corp.

Central Portfolio Control, Inc.

Investment Retrievers, Inc.

National Loan Exchange, Inc.

RAzOR Capital, LLC

SAM, Inc. – Solutions for Account Management

Security Credit Services, LLC

Spire Recovery Solutions, LLC

Synergetic Communication, inc.

Brass $1,000

Andreu, Palma, Lavin & Solis, PLLC

Balbec Capital, LP

Ballard Spahr LLP

Bayview Solutions, LLC

Equifax, Inc.

Halsted Financial Services, LLC

Investinet, LLC

Jefferson Capital Systems, LLC

Jormandy, LLC

Kino Financial Co., LLC

Plaza Services, LLC

Pressler, Felt and Warshaw, LLP

Resurgence Capital, LLC

Stenger & Stenger P.C.

Stephen L. Bruce & Associates

The Cadle Company

The Law Offices of Ronald S. Canter, LLC

TrueAccord

United Holding Group

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.

Applied Innovation, Inc.

Arko Consulting LLC

ARM Compliance Business Solutions, LLC

ATKB Portfolio Management

Attunely Inc.

Ballard Spahr, LLP

Bloom & Associates, P.A.

Butler & Associates, P.A.

Capio

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.

Dynamic Recovery Solutions

Faloni Law Group, LLC

FLOCK Specialty Finance

FMS, Inc.

FocusOne, Inc.

Full Circle Financial Services, LLC

G. Reynolds Sims & Associates, P.C.

Gaskell & Giovannini, LLC

Genesis Recovery Services

Glass Mountain Capital, LLC

Hunt & Henriques

Indiana Receivables, Inc.

International Debt Buying Consultants, LLC

Invenio Financial, a Phillips & Cohen Associates Company

Jan Stieger

Keith D. Weiner & Associates Co., LPA

Kelly Knepper- Stephens

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

National Recovery Solutions

NDS, LLC

Nelson & Kennard

Neustar, Inc.

NRA Group, LLC

Ontario Systems, LLC

Orion Capital Solutions, LLC

Palinode, LLC

PCI Group, Inc.

PerSolve, LLC

Phin Solutions, Inc.

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

Slovin & Associates

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Tobin & Marohn

Troy Capital, LLC

Universal Fidelity LP

US Mortgage Resolution, LLC

USI Solutions, Inc.

VanDerHeyden Law Office PA

Vargo & Janson, P.C.

Venable LLP

Venandi Systems, LLC

Verifacts, Inc.

Viking Client Services, Inc.

VoApps

Wipfli LLP