RMAI Update July 2022

Gary Wood, RMAI Past President

RMAI wishes to honor and acknowledge Gary Wood, RMAI Past President, who passed on June 9, 2022. Gary served on the RMAI Board of Directors for seven years and held the position of President for two years, in 2006 and 2007. In 2016, Gary Wood was awarded the Bud Reitzel Award, the industry’s highest honor.

“Gary was a man that led by example,” said Mike Colby, RMAI Board Member and colleague of Gary’s for many years. “He was extremely knowledgeable and was willing to share with a huge smile and quick wit. He was one of the first to see the need for open communication with industry regulators. He made numerous trips to Capitol Hill on behalf of DBA/RMAI and set the tone for the relationships we have today on the Hill. He was a great mentor and friend.”

Before RMAI had a Federal Legislative Consultant, Gary helped organize many Capitol Hill visits, where he laid the ground work for having the association’s voice heard with Legislators. As the years progressed, Gary was an active consultant in the legislative arena. Gary’s background as a former staffer on Capitol Hill made him a natural mentor for RMAI’s advocacy program. He served as Chairman of the Legislative Task Force, and consultant to the State Legislative Committee.

Gary had a long and varied career, from serving in the U.S. Air Force to working for the CIA, to joining the faculties of the University of Texas at San Antonio and Baylor University. He served on the staff of Texas Senator John Tower in Washington, D.C., and was appointed the Chief Economist of the Republican Policy Committee for the United States Senate. Prior to retiring, Gary was President of Collins Financial Services.

Read more about Gary in his obituary.

Congress has turned its attention to the big pieces of legislation including the national defense authorization bill and trying to revive Build Back Better and others.  There is little to no chance of individual pieces of legislation making it through the process.  Therefore, while RMAI attentively monitors House Financial Services and Senate Banking activities, we don’t believe that legislation that does not have bi-partisan support has any chance of passage.  The general consensus remains that the House will flip in the mid-terms back to Republican control, and for the Senate, it depends on who you ask for a prediction!

So, our attention turns to the Federal Regulators – simply keeping up with the communications coming out of the CFPB has become time consuming. Interestingly, we have seen both the US Chamber of Commerce as well as a coalition of banking associations (Consumer Bankers Association, American Bankers Association, Independent Community Bankers Association, and the US Chamber) come out publicly against several of the CFPB proposals and expanded authority.  The Chamber paper is here, and the banking coalition whitepaper is here.

RMAI hopes you will join us for our regional event in Washington D.C., September 26th and 27th.  The event will feature a day of Federal advocacy focused education, with sessions including:

• Fireside Chat with CFPB Director Rohit Chopra (Invited)
• The Mid-term Elections: An “inside the beltway” view of the impact of the mid-term elections on the financial services community, with speaker Thomas Quaadman from the U.S. Chamber Center for Capital Markets Competitiveness.
• Federal Advocacy 101 Training & Grassroots Toolkit: Learn from RMAI about federal advocacy and how you can be an effective advocate on behalf of your business and your industry.
• Federal Regulatory Panel with representatives from the CFPB, FTC, OCC and FDIC (Invited)
• Direct from Capitol Hill: Key Staff from the House Financial Services Committee and Senate Banking Committee have been invited to share the issues being discussed by their respective committees.
• What You Need to Know to Collect Debt in D.C.: RMAI will share important information for protecting businesses collecting debt in the nation’s capital.

Registration is now open. Register early as there is limited space!

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 and regulators about the industry and the negative impacts or unintended consequences a bill would have on businesses and consumers. The State Legislative cycle is winding down with most states having adjourned for the year. However, a handful of states are still in session, including California and Massachusetts. RMAI is currently tracking 55 bills in states that are still in session (down from 352). Here are some recent developments – including a new Rhode Island bond requirement law already in effect – at the state level that might be of interest:

California SB 975 – This bill would prohibit a debt collector from collecting or attempting to collect a consumer debt if the consumer provides documentation to the debt collector that the debt, or any portion of the debt, is the result of economic abuse. The bill defines economic abuse to be when a person causes another person “to have impaired financial stability by maintaining control over the individual’s financial resources . . .” Sufficient documentation to determine the occurrence of economic abuse would include a copy of a protective order; a police report indicating the individual was a victim of domestic violence or elder abuse; a  Federal Trade Commission identity theft report; or documentation from a licensed medical professional, domestic violence counselor, a sexual assault counselor, licensed health care provider, attorney, social worker, or counselor stating that the debt was incurred as a result of economic abuse. [RMAI opposes this bill, as drafted, given the unqualified background of some of the individuals who can determine the existence of economic abuse. There are similar bills that were introduced in Florida and Illinois that RMAI supports given appropriate protections contained in those bills. RMAI and an industry coalition is in active negotiations with the author of the bill and amendments are expected.]

California SB 1200 – This bill would reduce the post-judgment interest rate from 10% to the federal prime rate not to exceed 5% if the judgment is on a claim related to personal debt or personal credit. The bill would also prohibit the renewal of a 10-year judgment for another 10 years, except in instances where a lien was created. [RMAI is working with our California lobbyist and an industry coalition to amend this bill. We are hoping proposed industry amendments will be accepted which would establish a flat 5 percent interest rate and allow for a five-year renewal.]

California SB 1477 – This bill would increase the disposable earnings that are exempt from wage garnishment by increasing the minimum wage multiplier to approximately 80x (California uses a convoluted formula). This would effectively exempt incomes under $70,000 from wage garnishment. This bill would also set the maximum amount of disposable earnings of a judgment debtor that is subject to levy at 10% of the amount by which the individual’s disposable earnings for a given week exceed 80 times the state minimum hourly wage. [RMAI is working with our California lobbyist and an industry coalition to fight this bill. Higher wage multipliers are becoming a priority issue for consumer advocates. RMAI has met with the bill’s author to float a framework for a compromise which is being considered.]

District of Columbia B 357 – The bill passed the City Council and has been signed by the Mayor. The bill now heads to Congress who as a formality has the ability to reject the bill (this will not happen). The new law will take effect on January 1, 2023. The law will change a number of provisions related to D.C.’s debt collection laws, including: (1) expanding the prohibitions on deceptive behavior; (2) prohibiting debt collectors from making more than four phone calls to a consumer in seven days; (3) limiting debt collectors to one email, text, or direct messaging communication in a seven day period until the consumer opts into e-communications; once opting in they can make five communications; (4) requiring debt collectors to have complete documentation related to the consumer debt being collected; (5) requiring debt collectors to provide extensive data and documents to the consumer within 15 days of a written request; (6) requiring lengthy consumer notices informing consumers of their rights; (7) requiring debt collectors who enter into a payment schedule or settlement to provide a written copy of the schedule or agreement; (8) adding specific requirements for a debt collector when initiating a cause of action against a consumer for consumer debt; (9) requiring account level-affidavits similar to New York; and (10) increasing damages that can be awarded to a consumer for violation of the act. [After 10 months of negotiations and amendments, the D.C. Council adopted the final bill on June 7^th and will become effective on January 1, 2023. RMAI and an industry coalition were successful in amending the emergency and temporary bills by: (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.]

Massachusetts SB 2858 – This bill among other things: (1) increases the garnishment exemption from 50x state minimum wage to 65x state minimum wage; (2) once the consumer exceeds the exemption threshold, the bill limits garnishment to 10% of the income above the threshold; (3) reduces the statute of limitations in an action for the collection of a consumer debt from six to four years; (4) prohibits the revival of a debt that is beyond the statute of limitations through the making of a payment; and (5) reduces the time allowed to take action to enforce a judgment from 20 to 10 years but allows renewing the judgment for an additional 10 years. If passed, the bill would take effect on September 1, 2023. [RMAI has been opposing this bill since 2014 when it was first introduced. After eight years of negotiations and countless amendments, we appear to be close to a final compromise between the advocates and industry that will result in final adoption. More to come.]

Rhode Island SB 2794/HB 7781 – This law was signed by Governor McKee on June 29^th and took effect upon its signing. The law requires a $50,000 bond for licensed debt collectors in Rhode Island. The bond amount for debt collectors is similar to bond amounts for other businesses in Rhode Island. [On July 8, 2022, RMAI issued Member Alert: New Rhode Island Law Requires Bond for Debt Collectors.]

Ninth Circuit Holds (Again) That Text Messages  Can Constitute “Prior Express Consent”
Moskowitz v. Am. Sav. Bank, F.S.B., No. 20-15024, 2022 U.S. App. LEXIS 16016 (9th Cir. June 10, 2022)

A bank that offered mobile text banking services to its clients had a procedure for responding to texts from non-clients, who could be sending texts to the short code number to inquire about services, or accidentally or mischievously.  The text response from the bank instructed the non-client consumers to reply “STOP” to opt out, and how to otherwise contact the bank.  If the bank received a “STOP” text, it replied by informing the consumer they were unsubscribed and provided instructions to re-subscribe.

In this case, a consumer sent ten text messages to the bank with content unrelated to banking services, and one final text message with the word “STOP.”  The bank replied as per its procedure.

The consumer, a serial filer, naturally filed a lawsuit against the bank in federal court alleging it had violated the Telephone Consumer Protection Act (“TCPA”) “which prohibits calling [including texting] a mobile phone by use of automatic call generating capabilities absent the call recipient’s prior express consent.”

The trial court granted the bank’s motion for summary judgment, “concluding that each text message from [the consumer’s] mobile phone constituted prior express consent for each of ASB’s reply texts to his mobile phone.”  The consumer appealed.

The U.S. Court of Appeals for the Ninth Circuit used little ink in affirming the ruling of the trial court on this issue, explaining “[w]e have already determined that the type of message [the consumer] sent [the bank] provided the express consent required for each of [the bank’s] responsive text messages,” citing Van Patten v. Vertical Fitness Grp., Ltd. Liab. Co., 847 F.3d 1037 (9th Cir. 2017).

In Van Patten, the Court adopted the FCC’s interpretation of “prior express consent,” which is not defined in the TCPA: “a person who knowingly releases his number consents to be called at that number, and that consent is ‘effective’ where the responsive messages relate to the same subject or type of transaction as the messages that led to the response.”

Sixth Circuit Holds “Objectively Baseless” Collection Actions Can Violate FDCPA
Snyder v. Finley & Co., L.P.A., No. 21-3997, 2022 U.S. App. LEXIS 16512 (6th Cir. June 15, 2022)

A debt collector filed suit against a wife for attorney’s fees owed by her husband, asserting it as a “spousal obligation to support” claim pursuant to Ohio’s Necessaries Statute which permits the collection of certain debts from one spouse that were incurred by the other.

The wife then filed a lawsuit against the debt collector alleging violations of the Fair Debt Collection Practices Act (“FDCPA”), arguing that the lawsuit against her for legal fees incurred by her husband was “objectively baseless.”  The parties filed cross-motions for summary judgment and the trial court ruled in favor of the debt collector.  The wife appealed.

The U.S. Court of Appeals for the Sixth Circuit noted that “merely advancing an ultimately unsuccessful claim for relief does not, in and of itself, rise to an FDCPA violation.” However, a litigation filing containing a material misstatement of state law that is “false, deceptive, or misleading” at the time it is made can constitute an FDCPA violation.

Ohio’s Necessaries Statute provides that a “married person must support the person’s self and spouse,” and if one is “unable to do so, the spouse of the married person must assist in the support so far as the spouse is able.” The Ohio Supreme Court previously clarified that  “a nondebtor spouse becomes liable only if the debtor spouse does not have the assets to pay for his or her necessaries.”

Based on the Ohio Supreme Court’s decision, the Court found “that defendant’s debt-collection lawsuit against plaintiff was objectively baseless,” and that the debt collector was required “to first seek satisfaction of its claim from [the husband] and [was] prohibited [] from filing a joint-liability suit against [the husband and wife] without clearly stating that its claim against [the wife] was contingent.”

Thus, the Sixth Circuit reversed the trial court’s judgment, and remanded with instructions to enter judgment in favor of the wife.

Eleventh Circuit Holds “Dual Purpose” Mortgage Statements Can Be Subject to FDCPA
Lamirand v. Fay Servicing, LLC, No. 20-14286, 2022 U.S. App. LEXIS 18290 (11th Cir. July 1, 2022)

Following on the heels of its decision in Daniels v. Select Portfolio Servicing, Inc., 34 F.4th 1260 (U.S. 11th Cir. 2022) (summarized in last month’s RMAI Update), the U.S. Court of Appeals for the Eleventh Circuit again found that periodic statements sent pursuant to the Truth in Lending Act (“TILA”) can result in liability under the Fair Debt Collection Practices Act (“FDCPA”) if the representations are “’in connection with’ or a ‘means’ of debt collection.”

Here, the borrowers were in default and the servicer brought a foreclosure action and took over the loan. The borrowers then filed suit against the servicer, and the parties settled with an agreement that the borrowers would pay a specific sum within one year.

Just months later, however, the servicer sent the borrowers a statement “notifying them that their loan had been accelerated because they were late on their monthly payments.”  That statement, and the monthly statements that followed, warned that the borrowers could lose their home and provided multiple ways to make a payment.

The borrowers filed suit against the servicer alleging violations of the FDPCA which prohibits false statements “made in connection with the collection of any debt.” § 1692e. Similar claims were made under the Florida Consumer Collection Practices Act.  The trial court dismissed the suit, determining that “the periodic statements were unrelated to debt collection . . . because [the servicer] was required to send monthly updates under the Truth in Lending Act.”  The borrowers appealed.

The U.S. Court of Appeals for the Eleventh Circuit began by noting “[a] communication has the necessary nexus to debt collection under the FDCPA if it conveys information about a debt and its aim is at least in part to induce the debtor to pay.”

Taking a “comprehensive view” of the monthly statements, the Court determined that they had a dual purpose, with some TILA provisions being purely informational, but other provisions plausibly intended to collect a debt.  For example, the statements warned the borrowers that they “must pay this amount to bring loan current,” and “that a failure to pay . . . could result in additional fees or expenses, and in certain instances, the loss of their home to a foreclosure sale.”

Reversing the trial court’s dismissal of the borrowers’ suit, the Court concluded: “The Truth in Lending Act encourages lenders to give consumers information about their loan—information that is useful only if it is accurate and fair, as the FDCPA requires. When servicers use periodic statements to collect a debt, then, they can be held liable for any misleading or unconscionable representations they make in those statements.”

Ninth Circuit Finds Retroactive Consent Violates California Law
Javier v. Assurance IQ, LLC, No. 21-16351, 2022 U.S. App. LEXIS 14951 (9th Cir. May 31, 2022)

A consumer visited an insurance platform that provides life insurance quotes. He provided answers to a variety of questions not knowing that the platform was capturing “in real time every second of his interaction with [the website] and created a video recording of that interaction.”  It was not until the questionnaire was complete that he was asked to click, and did click, a button that ostensibly constituted his agreement to the recording.

The consumer filed a class action lawsuit against the platform provider and the service provider that provided the recording function, alleging violation of the California Invasion of Privacy Act (“CIPA”).  That Act, in part, “makes liable anyone who ‘reads, or attempts to read, or to learn the contents’ of a communication ‘without the consent of all parties to the communication.’” Citing Cal. Penal Code § 631(a).

The trial court granted the defendants’ motion to dismiss, holding that the consumer’s “claims were defeated because he had retroactively consented to the conduct at issue by agreeing to Assurance’s privacy policy, and that retroactive consent is valid under Section 631(a).”  The consumer appealed.

On appeal, the U.S. Court of Appeals for the Ninth Circuit noted that the California Supreme Court, in analyzing another section of CIPA, wrote that section (§ 632) “prohibits . . . a party . . . from recording [a] conversation without first informing all parties to the conversation that the conversation is being recorded.”  Additionally, the California Supreme Court held with regard to § 631, that “the Privacy Act has been read to require the assent of all parties to a communication before another may listen.”

Based on those interpretations, and that “all CIPA provisions are to be interpreted in light of the broad privacy-protecting statutory purposes of CIPA,” the Court held the consumer “sufficiently alleged that he did not provide express prior consent,” and reversed the trial court’s dismissal.

Support the Executive Summit Silent Auction Fundraiser for the Legislative Fund
The Executive Summit 2022 Silent Auction opens live on July 18th! Register now, browse the online auction catalog and “Buy it Now” if you find something you can’t live without! “Buy it Now” ends July 30^th before the Executive Summit begins. The auction will then go live on-site for Summit attendees.

Donate an Item
To donate a silent auction item and add your company logo to the auction catalog and donor list, please fill out this donation form. (Not sure what to donate? Browse our Amazon wishlist for ideas.)

Where Do Your Donations Go?
RMAI utilizes the Legislative Fund donations from our members to fund state and federal advocacy efforts. Check out our updated infographic which shows where the donations go and contribute to the Legislative Fund by donating here. Click here to see a list of current contributors.

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.

Chief Compliance Officer Webinar Series (CCO Series)
Register for RMAI’s six-part webinar series which begins May 26th and ends on November 1st and focuses on recent updates and changes in the compliance world since the implementation of Regulation F. Topics include Credit Reporting, Letters, Communication Restrictions, Vendor Oversight, Text Message/SMS, and Payments. While this series is designed for chief compliance officers, the content is beneficial for anyone working in or wanting to learn more about these topic areas.

Registration Options

Entire CCO Webinar Series: $299 for members – REGISTER (Recordings provided for webinars that have already occurred.)

Individual Webinars: $64 per webinar for members

• Credit Reporting – May 26th REGISTER for the Recording
• Letters – June 23rd REGISTER for the Recording
• Communication Restrictions – July 26th REGISTER
• Vendor Oversight – September 15th REGISTER
• Text Message/SMS – October 13th REGISTER
• Payments – November 1st REGISTER

Click here for more information on individual webinars.

Monthly Webinars – Free for Members

Register now for our August 9th webinar, The Building Blocks of Reputation Management. Learn from our panelists how to begin the process of reputation management and helpful steps you can take for building the reputation of your business.

Register now for our August 30th webinar, Trending in 2022: Bankruptcy Litigation. Our panel, which will include a United States Bankruptcy Court Judge, a Chapter 13 Trustee, and other members of the industry, will provide an update on the latest bankruptcy filing statistics and projections.

If you missed our June 17th webinar, you can still watch the recording: What’s New with New York Form Affidavits.

Contact Shannon Parod at [email protected] or (916) 482-2590 with any questions.

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

CRCP – Renewals
Buddy Beaman – Hilco Receivables, LLC
Terri Haley – Second Round, LP
Jonathan Koop – Bankrupt Debt Services
Kelli Moes – Financial Recovery Services, Inc.
Robert Obringer – Invenio Financial, a Phillips & Cohen Associates, Ltd. Company

CRB – New
640 Financial Group, LLC
Pressler, Felt & Warshaw, LLP

CRB – Renewals
B-Lo, LLC

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

For questions about certification, contact Shannon Parod direct at 916-482-2590 or email [email protected].

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

RMAI 2022 Executive Summit | August 2-4, 2022

RMAI 2022 Washington D.C. Regional Event | September 26-27, 2022

Applications due for the RMAI Diversity Equity Inclusion (DEI) 2023 Annual Conference Scholarship | October 14, 2022

Thank you to our July 2021 – July 11,  2022 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

First Financial Portfolio Services, LLC (FFAM360)

Midland Credit Management

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Titanium $15,000

National Credit Adjusters, LLC

Velocity Portfolio Group, Inc.

Platinum $10,000

Blitt and Gaines, P.C.

Cascade Capital, LLC

InvestiNet, LLC

Second Round, LP

Unifund CCR LLC

Gold $7,500

EverChain

Miller and Steeno, P.C.

Pressler, Felt and Warshaw, LLP

Rausch Sturm, LLP

Superlative RM

Silver $5,000

AscensionPoint Recovery Services, LLC

CKS Financial

Digital Recognition Network

FMA Alliance, Ltd

Klima, Peters, & Daly, P.A.

T&I Enterprises, LLC

Tromberg, Morris & Poulin, PLLC

Velo Law Office

Bronze $2,500

Absolute Resolutions Corp.

Couch Lambert

DebtNext Software, LLC

Investment Retrievers, Inc.

Ragan & Ragan

RAzOR Capital, LLC

Resurgence Capital, LLC

SAM, Inc. – Solutions for Account Management

Security Credit Services, LLC

Weltman, Weinberg & Reis Co., L.P.A.

Brass $1,000

Andreu, Palma, Lavin & Solis, PLLC

Bayview Solutions, LLC

Complete Credit Solutions, Inc.

FLOCK Specialty Finance

Gordon, Aylworth & Tami, P.C.

Halsted Financial Services, LLC

Hunt & Henriques

Kino Financial Co., LLC

Levy & Associates, LLC

Maxwell & Graves Solutions, LLC

Quantum3 Group, LLC

Simmonds & Narita, LLC

Slovin & Associates

Synergetic Communication, Inc.

The Cadle Company

Tobin & Marohn

VeriFacts, Inc.

Vertican Technologies, Inc.

Other

Accelerated Data Systems

Acctorp International, Inc.

Action Collection Agencies, Inc.

Advancial Federal Credit Union

Aldridge Pite Haan, LLP

Alliance Data

Alliant Capital Management LLC

Arko Consulting LLC

ARM Compliance Business Solutions

Atlas Acquisitions

Attunely Inc.

Autovest, LLC

Ballard Spahr, LLP

Beam Software

Business and Professional Collection Service, Inc.

Butler & Associates, P.A.

C&E Acquisition Group, LLC/ Diverse Funding Associates

Capio

Capital Collection Management, LLC

Capital Link Management, LLC

Client Services Incorporated

CMS Services

Commercial Credit Group Inc.

Complete Credit Solutions, Inc.

Comtronic Systems, LLC

Conficio Capital, Inc.

Converging Capital, LLC

Convoke, Inc.

Cornerstone Support, Inc.

Credit Control, LLC

Credit Management Corporation

Credit Corp Solutions, Inc.

CSS Impact!

Debt Recovery Solutions, LLC

Delev & Associates, LLC

Dyck-O’Neal, Inc.

Dynamic Recovery Solutions

Equabli

Experian

Finvi

First American Acceptance Co., LLC

First Solutions Debt Management, LLC

FMS, Inc.

G. Reynolds Sims & Associates, P.C.

Gaskell & Giovannini, LLC

Genesis Recovery Services

Guglielmo & Associates, PLLC

Harvest Strategy Group, Inc.

Indiana Receivables, Inc.

Interim Capital Group, Inc.

International Debt Buying Consultants, LLC

Invenio Financial, a Phillips & Cohen Associates Company

Jefferson Capital Systems, LLC

Jormandy

Keith D. Weiner & Associates Co., LPA

Kelly Knepper -Stephens

Kirschenbaum & Phillips, P.C.

Law Offices of Steven Cohen, LLC

Lockhart, Morris & Montgomery, Inc.

Malone Frost Martin PLLC

MauriceWutscher LLP

Metronome Financial LLC

Monarch Recovery Management, Inc.

National Debt Holdings, LLC

National Loan Exchange NLEX

National Recovery Associates, Inc.

National Recovery Solutions, LLC

Nationwide Recovery Systems

NCB Management Services, Inc.

Nelson & Kennard

NRA Group, LLC

PCI Group Inc.

Phin Solutions, LLC

Portnoy Schneck, L.L.C.

Poser Investments, Inc.

Premier Forty Financial, LLC

Premium Asset Recovery Corp (PARC)

Pro Forma Inc

Provana, LLC

ProVest LLC

Quall Cardot, LLP

RAS LaVrar LLC

Repay

Resource Management Services, Inc.

RevSpring

Robinson, Hoover & Fudge, PLLC

Scott & Associates, PC

Sentry Credit, Inc.

SMS Financial, LLC

State Collection Services, Inc.

Stone, Higgs & Drexler

Suttell & Hammer

Synchrony Financial

Tag Process Service, Inc.

Tate & Kirlin

Techno Brain BPO ITES Limited

TransUnion

Troy Capital, LLC

USASF Servicing

Vargo & Janson, P.C.

Venable LLP

VoApps

Zenarate, Inc