RMAI Update April 2023

Congress has been on spring break for the first two weeks of April.  Prior to going on break, Congressman Barr, Chairman of the House Financial Services Subcommittee on Financial Institutions and Monetary Policy, reintroduced the Taking Account of Bureaucrats’ Spending (TABS) Act. The TABS Act would subject the CFPB to the traditional congressional appropriations process, like virtually every other federal agency.  Currently, the CFPB bypasses the appropriations process by receiving its funding directly from the Federal Reserve.   To complement the introduction of the TABS Act, on March 9 the HFS Subcommittee on Financial Institutions and Monetary Policy convened a hearing entitled Consumer Financial Protection Bureau: Ripe for Reform. The hearing largely followed party lines, with Republicans advocating for reforms that would make the CFPB subject to the annual congressional appropriations process and have a bipartisan five-member leadership structure. Conversely, Democratic Members largely applauded the work of the CFPB in improving the lives of American consumers, protecting consumers from fraud and abuse, and promoting competition and transparency in the economy.

On the regulatory front:

• On April 3, the CFPB issued a policy statement to provide guidance on abusive conduct in consumer financial markets. According to its press release, “In this policy statement, the CFPB sets forth how abusive conduct generally includes (1) obscuring important features of a product or service or (2) leveraging certain circumstances—including gaps in understanding, unequal bargaining power, or consumer reliance—to take unreasonable advantage. In particular, the statement describes how the use of dark patterns, set-up-to-fail business models like those observed before the mortgage crisis, profiteering off captive customers, and kickbacks and self-dealing can be abusive.” The full policy statement is available here. The RMAI Federal Legislative and Regulatory Committee is discussing whether or not RMAI should submit Comments regarding this policy statement.
• On March 23, the FTC issued a Notice of Proposed Rulemaking entitled Negative Option Rule, which would make it easier for consumers to “click to cancel” subscriptions. This Proposal would make several changes, including implementing a simple cancellation mechanism, new requirements before making additional offers, and new requirements regarding reminders and confirmations. More information is available in their press release here, the text of the NPRM here, and a fact sheet here. Comments are due 60 days after publication in the Federal Register.  Again, the RMAI Federal Committee is discussing whether or not RMAI should submit Comments.

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. If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel David Reid at (916) 779-2492 or [email protected]. The following bills of concern are a sample of the legislation that RMAI is currently engaging on behalf of the industry:

California AB 1414 – This bill would exclude consumer credit accounts from the definition of “book account” which would force all litigation through a contract theory for litigation. [RMAI and an industry coalition are in opposition to the bill.]

Colorado HB 1126 – This bill would prohibit consumer reporting agencies from including information related to a medical debt on a consumer report. The bill defines “medical debt” as “debt arising from health-care services . . . or health-care goods, including products, devices, durable medical equipment, and prescription medications.” [RMAI fought this expansive definition which would have included medical debt charged on a credit card, including a bottle of Tylenol purchased from a grocery store. Through the efforts of RMAI, our Colorado lobbyist, and other industry partners we were able to get an exemption for credit card debt unless the credit card was offered specifically for the payment of health-care services or health-care goods.]

Nevada AB 223 – This bill would require debt collectors to provide a payoff letter within 10-days of a consumer request. The bill also provides for a private right of action for failure to provide a payoff letter in the required time. [RMAI was able to obtain some modest amendments; however, we remain in opposition.]

Nevada SB 276 – This bill would modernize the Nevada Collection Agency Act to among other things: (1) require debt buyers to be licensed as collection agencies; (2) allow debt collectors to work remotely; (3) eliminate separate licenses for branch offices; (4) change “qualified managers” to “compliance managers” and require only a single compliance manager for the corporate entity rather than one for each location; (5) in certain circumstances, where the compliance manager is a chief compliance officer, eliminate the required test; (6) eliminate antiquated posting requirements of licenses; and (7) exempt debt buyers from trust account requirements. [RMAI sponsored the introduction of this bill and supports its passage.]

New York AB 1035 – This bill would prohibit debt collectors from communicating with consumers through the use of email, text messaging, or private communication tools offered by social media companies. [RMAI is strongly opposed to this bill and has the resources of RMAI’s New York lobbyist to help ensure that the bill is not considered.]

New York SB 4750 – This bill would expand the scope of the 2021 Consumer Credit Fairness Act (CCFA) by replacing the term “consumer credit transaction” with “consumer debt” and thereby bringing debt such as medical and utility under the scope of the CCFA’s litigation requirements. [This bill could potentially solve a problem contained in the proposed debt collection rule developed by the New York State Department of Financial Services (DFS). DFS is struggling with how to develop an appropriate consumer notice since the CCFA does not apply to all forms of consumer debt. However, the bill will need to be amended to exempt judgments from the bill’s scope.]

Oregon HB 2008 – This bill, among other things, would: (1) increase the auto exemption from $3,000 to $15,000; (2) increase various personal household property exemptions; (3) increase the homestead exemption from $40,000 to the median housing price for single-family dwellings in the county in which the homestead is located; and (4) protect approximately $52,000 in wages from garnishment. The bill would also authorize the award of punitive damages as part of a private right of action. [RMAI, while acknowledging some of the exemption thresholds could be increased, is strongly opposed to this bill as it is currently drafted. RMAI will be working with an industry coalition to seek amendments.]

Washington SB 5173 – This bill would update the state property exemption provisions. The most notable changes include: (1) increasing the auto exemption from $6,500 to $15,000; (2) increasing the tools of the trade exemption from $10,000 to $15,000; and (3) doubling of the exemption amount for married couples when a marital status is declared. [RMAI worked with an industry coalition to fight this legislation and was able to achieve amendments that would eliminate an automatic doubling of the exemption for married individuals and an automatic cost of living adjustment.]

Sixth Circuit Finds Standing for Unwanted Collection Call, But Defendant Was Not a Debt Collector
Ward v. NPAS, Inc., No. 21-6189, 2023 U.S. App. LEXIS 7100 (6th Cir. Mar. 24, 2023)

A consumer received bills for medical treatment that were “due upon receipt,” but did not pay.  The medical provider sent the bills to a third-party servicer that proceeded to send the consumer statements and left three voicemails.  On the voicemails, the servicer left its name but omitted the word “incorporated.”

Through a law firm, the consumer erroneously sent a cease-and-desist letter to a company with a name similar to that of the servicer.  The servicer, not having received the letter, left another voicemail and the consumer filed suit alleging violations of the Fair Debt Collection Practices Act (“FDCPA”).  Specifically, the consumer alleged the servicer: 1) did not meaningfully disclose its identity as a debt collector, in violation of § 1692d(6); 2) used a name other than its “true name,” in violation of § 1692e(14); and 3) called him after he attempted to send a cease-and-desist letter, in violation of § 1692c(a)(2) and (c).

The trial court granted the servicer’s motion for summary judgment, finding it “did not qualify as a ‘debt collector’ under the FDCPA.”  The consumer appealed and on appeal the servicer “questioned whether [the consumer] had suffered an injury in fact sufficient to confer Article III standing.”  The U.S. Court of Appeals for the Sixth Circuit remanded the matter to the trial court on the issue of whether the third voicemail, left after the attempted cease-and-desist demand, could constitute an Article III injury.

In an amended complaint, the consumer alleged that that “[t]he intrusion upon [his] phone services, time, and home life greatly irritated [him] because he believed that he had successfully invoked his right to be free from intrusive voice messages months earlier, and the voicemail therefore came as a nasty shock and an unwanted intrusion upon seclusion.”

The trial court denied the servicer’s motion for summary judgment on the issue of standing, but
“granted the motion as to substantive liability.”  The consumer again appealed.

On this appeal, the Court explained that the consumer “must show either that the procedural harm itself is a concrete injury of the sort traditionally recognized or that the procedural violations caused an independent concrete injury.”  Here, the consumer relied on intrusion upon seclusion which requires “that a defendant intentionally intruded, physically or otherwise, upon the solitude or seclusion of another or his privacy affairs or concerns.”

The Court noted that generally, “the single unwanted phone call [the consumer] offers would not likely show the ‘substantial’ and ‘strongly objectionable’  intrusion upon his privacy that would make NPAS liable to him under the common law.”  However, relying on Spokeo, Inc. v. Robins, 578 U.S. 330, 136 S. Ct. 1540 (2016), the Court stated it must “look for a harm with a close relationship ‘in kind, not degree’ to common law harms,” and concluded:

Because the intrusion caused by unwanted phone calls bears a close relationship to the kind of harm that the common law sought to protect, it does not matter that the volume of such calls may be too minor an annoyance to be actionable at common law.

While the Court found in favor of the consumer on the issue of Article III standing, it found in favor of the servicer on the question of whether it was a “debt collector” under the FDCPA.

Importantly, the contract between the medical provider and the servicer stated that “during  the time that the medical account is being serviced by the [servicer], the account shall not be considered delinquent, past due or in default, and shall not be reported to a credit bureau or subject to collection legal proceedings.”

The Court stated that “a ‘debt collector’ is one who ‘either acquired a debt in default or has treated the debt as if it were in default at the time of acquisition,’” and that “[h]ere, no one—neither the [medical provider], nor [the servicer]—treated [the consumer’s] debt as if it were in default at that time.”

Based on this, the Court found the servicer was not a debt collector under the FDCPA and affirmed the trial court’s grant of summary judgment.

Second Circuit Holds CFPB Funding Structure Constitutionally Sound
Consumer Fin. Prot. Bureau v. Law Offices of Crystal Moroney, P.C., No. 20-3471, 2023 U.S. App. LEXIS 6978 (2d Cir. Mar. 23, 2023)

A three-judge panel of the U.S. Court of Appeals for the Second Circuit handed down a decision on March 23, 2023, holding that the funding mechanism for the federal Consumer Financial Protection Bureau (“CFPB”) is constitutionally sound. In doing so, it “respectfully decline[d] to follow the Fifth Circuit’s decision” in Cmty. Fin. Servs. Ass’n of Am. v. Consumer Fin. Prot. Bureau, 51 F.4th 616 (5th Cir. 2022), in which the Court ruled that the method used to fund the CFPB was prohibited by the U.S. Constitution’s Appropriations Clause.

In Moroney, the CFPB issued a Civil Investigative Demand to a law firm seeking certain documents. When the law firm refused to hand over the documents, the CFPB filed a lawsuit in federal district court to enforce it. The district court granted the request and the law firm appealed.

On appeal, the law firm made several arguments why the CID could not be enforced, one of which relied on the Fifth Circuit’s recent ruling. The Second Circuit rejected them all and affirmed the district court’s order.

The Second Circuit explained that in Community Financial, “the Fifth Circuit concluded that Congress ‘ceded direct control over the CFPB’s budget by insulating it from annual or other time limited appropriations’ and ‘ceded indirect control by providing that the CFPB’s self-determined funding be drawn from a source that is itself outside the appropriations process,’ namely, the Federal Reserve System. This structure, according to the Fifth Circuit, constitutes ‘a double insulation from Congress’s purse strings,’ which runs ‘afoul of the separation of powers embodied in the Appropriations Clause.’”

The Second Circuit disagreed.  “We cannot find any support for the Fifth Circuit’s conclusion in Supreme Court precedent . . . [or] in the Constitution’s text,”  the Second Circuit panel wrote. Citing a 1990 Supreme Court decision, the Second Circuit concluded that a funding scheme that is “authorized by a statute” is all that is required under the Appropriations Clause, which is what Congress did in 2010 when it crafted the CFPB’s funding scheme in section 1017 of the Dodd-Frank Act.

The Fifth Circuit’s reasoning that annual or “time limited appropriations” are a necessary element missing from the Bureau’s funding scheme fared no better. The text of the Constitution, the Second Circuit noted, only places time limitations on funds to “raise and support an army.” Since no other funding has such a limitation, by negative implication the Fifth Circuit could not impose one.

In Community Financial, the U.S. Supreme Court granted the CFPB’s Petition for a Writ of Certiorari on February 27, 2023.

Illinois Supreme Court Holds Each Violation of the Biometric Information Privacy Act Constitutes a New Claim
Cothron v. White Castle Sys., 2023 IL 128004

A manager for a restaurant brought a class action suit in federal court against the restaurant on behalf of a putative class of employees who allegedly scanned their fingerprints to access their paystubs and company computers. The manager alleged that the restaurant unlawfully collected her alleged biometric information and disclosed it to its third-party vendor in violation the Illinois Biometric Information Privacy Act (“BIPA”), 740 Ill. Comp. Stat. Ann. 14/1, et seq.

The restaurant filed a motion for judgment on the pleadings, arguing that the manager’s claims were untimely because they first accrued when BIPA went into effect in 2008, more than 10 years before the complaint was filed. The manager responded by arguing that a new claim accrued each time she scanned her fingerprints, and the restaurant chain sent her biometric data to its third-party authenticator.

The trial court agreed with the manager and denied the restaurant’s motion. The trial court later certified its order for immediate interlocutory appeal, finding that its decision involved a controlling question of law on which there was substantial ground for disagreement.

The U.S. Court of Appeals for the Seventh Circuit accepted the certification and found the parties’ competing interpretations of claim accrual reasonable under Illinois law and thus certified the following question to the Illinois Supreme Court:

Do section 15(b) and 15(d) claims accrue each time a private entity scans a person’s biometric identifier and each time a private entity transmits such a scan to a third party, respectively, or only upon the first scan and first transmission?

The Illinois Supreme Court noted that section 15(b) of BIPA mandates informed consent from an individual before a private entity collects biometric identifiers or information. Specifically, section 15(b) provides that “[n]o private entity may collect, capture, purchase, receive through trade, or otherwise obtain a person’s or a customer’s biometric identifier or biometric information unless it first . . . receives a written release executed by the subject of the biometric identifier or biometric information or the subject’s legally authorized representative.”

The Court disagreed with the restaurant that the collection of biometric identifiers could happen only once since the restaurant chain obtained employees’ fingerprint and stored them in its database and employees were then also required to use their fingerprints to access paystubs or company computers. The Court determined that the restaurant “fail[ed] to explain how such a system could work without collecting or capturing the fingerprint every time the employee needs to access his or her computer or pay stub.”

The Court then turned to section 15(d), which provides a privacy entity may not “disclose, redisclose, or otherwise disseminate a person’s or a customer’s biometric identifier or biometric information” without informed consent.  As with section 15(b), the Court concluded that “the plain language of section 15(d) applies to every transmission to a third party.”

In conclusion, the Court held “that the plain language of section 15(b) and 15(d) shows that a claim accrues under the Act with every scan or transmission of biometric identifiers or biometric information without prior informed consent.”

RMAI’s state and federal advocacy is so busy we needed to update the Legislative Fund infographic showing where your donations go. We thank all Legislative Fund contributors for your support of our receivables management industry advocacy. We encourage those who haven’t contributed yet to do so.

Donate here to contribute to the RMAI Legislative Fund. We will add your company name to our list of contributors on the RMAI website, in the Fall 2023 RMAI Insights magazine, and on the big sign at the 2024 Annual Conference.

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.

Looking for New and Fresh Speakers and Sponsors
RMAI’s Education Committee developed new webinar content for the remainder of the year and is looking for speakers and sponsors. If you are interested in speaking and have expertise in any of these topics or in sponsoring, we would love to hear from you.

• Compelling Arbitration
• Vendor & Service Provider Controls
• How to Educate Clients/Creditors on Industry Hot Topics
• Auto Case Law & Regulations
• Look Back at 2023 and Future for 2024 with the CFPB
• Diversity, Equity & Inclusion

Sponsoring a webinar is a great way to get you and your brand in front of our members and share a little bit about your company. When you sponsor a webinar, you receive a variety of benefits for both the live presentation and recording, including:

• Logo placement on the live webinar marketing flyer, weekly e-blasts and social media posts distributed to over 1,500 industry professionals and made available on the RMAI website
• Logo placement on the RMAI website for the live webinar
• Continued logo placement for one (1) year on the RMAI website for the recorded webinar
• Final attendee list with full contact information pre-and post-webinar
• Sponsor introduction by RMAI host
• Option to give sponsor pitch (2-3 minutes) at beginning of live webinar
• Choice of providing your own customized sponsor slide OR logo placement on RMAI sponsor slide in PPT Presentation to complement sponsor introduction and sponsor pitch

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

Miss a Webinar?
If you missed our April 13th webinar, Understanding Your Cyber Coverage and How It Can Help You Survive an Attack, you can register for the recording which will be available for one (1) year. Click here for more information on our live and recorded webinars.

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

CRCP New
Anibal Alvear, Synergetic Communication
Grissel Henriquez, Debt Direct Portfolio Management
Ari Lustbader, AKPC
M. Dylan McClleland, Judgment Exchange
Lauren Valenzuela, TrueAccord Corp.
Viacheslav Volotovskiy, Vie Key Consulting SARLS

CRCP Renewals
Christy Barger, Cornerstone Support, LLC
Peter Fitzpatrick, Oak Harbor Capital, LLC
Anthony Guajardo, Integras Capital Recovery
Laura Jensen, Absolute Resolutions Corp.
Kelly Knepper-Stephens, TrueAccord CorP
Heather Kochamba, Balbec Capital, LP
Mark Lesinski, Landmark Strategy Group, LLC
William Marohn, Tobin & Marohn
Richard Marshall, Velocity Portfolio Group, Inc
Colene McNinch, Maxwell & Graves Solutions, LLC
W. Peter Ragan, Velocity Portfolio Group, Inc.
Karl Ryan, Interim Capital Group
Scott Richards, Indiana Receivables
Tessie Saich, Investment Retrievers, Inc.
Richard Segol, Alliance Credit Services, Inc.
Lindsey Svenson, Velocity Portfolio Group, Inc.
John Touhey, B-Lo

CRB Renewals
Capio
First Financial Portfolio Services (FFAM360)
Genesis Recovery Services
Halsted Financial Services, LLC
Investment Retrievers, Inc.
Kino Financial Co., LLC
Metacorp, LLCThe Cadle Company

Vendor Certification
Earning RMAI’s Vendor Certification is a great way to show that your company is maintaining compliance by following uniform industry standards of best practice. Companies that qualify for the Certified Receivables Vendor (CRV) designation include vendors providing a product or service to the receivables management industry, brokers, process servers, and defense law firms. If your business falls under any of those categories, your company can earn the CRV designation by complying with the applicable Receivables Management Certification Program standards:

For Vendors (Series 100):

• Maintain compliance with seven (7) standards of Appendix B, Series 100 outlined in version 11.0 of the Governance Document.
• Three-Year certification term
• Pre-Certification audit required using an RMAI Authorized Audit Provider
• One (1) individual from your company must be individually certified and serve as Chief Compliance Officer for your certified business.

For Brokers (Series 100 and 200):

• Maintain compliance with seven (7) standards of Appendix B, Series 100 plus six (6) additional standards specific to brokers (refer to Appendix B, Series 200) which are outlined in version 11.0 of the Governance Document.
• Three-Year certification term
• Pre-Certification audit required using an RMAI Authorized Audit Provider
• One (1) individual from your company must be individually certified and serve as Chief Compliance Officer for your certified business.

For Process Servers (Series 100 and 300):

• Maintain compliance with seven (7) standards of Appendix B, Series 100 plus six (6) additional standards specific to brokers (refer to Appendix B, Series 300) which are outlined in version 11.0 of the Governance Document.
• Three-Year certification term
• Pre-Certification audit required using an RMAI Authorized Audit Provider
• One (1) individual from your company must be individually certified and serve as Chief Compliance Officer for your certified business.

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.

2023 NCBA Connect Conference | May 3-5, 2023
RMAI 2023 Executive Summit | August 1-3, 2023
2023 Fall Networking & Baseball | September 11, 2023
2024 RMAI Annual Conference | February 5-8, 2024

Thank you to our April 1, 2022 through April 6, 2023 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

First Financial Portfolio Services, LLC

Midland Credit Management

Resurgent Holdings, LLC

Second Round, LP

Velocity Portfolio Group, Inc.

Titanium $15,000

Blitt and Gaines, P.C.

Pressler, Felt and Warshaw, LLP

Platinum $10,000

Andreu, Palma, Lavin & Solis,  PLLC

Cascade365 Family of Companies

FMA Alliance, Ltd

Garnet Capital Advisors, LLC

InvestiNet, LLC

National Credit Adjusters, LLC

Plaza Services, LLC

Unifund CCR LLC

Gold $7,500

Miller and Steeno, P.C.

Ragan & Ragan, PC

Rausch Sturm, LLP

Superlative RM

Silver $5,000

AscensionPoint Recovery Services, LLC

CKS Financial

Corporate Advisory Solutions, LLC

DebtNext Software, LLC

Digital Recognition Network

EverChain

Halsted Financial Services, LLC

Klima, Peters & Daly, P.A.

National Loan Exchange, Inc.

Pharus Funding, LLC

Provana, LLC

Spring Oaks Capital, LLC

T & I Enterprises, LLC

Tromberg, Morris & Poulin, PLLC

Velo Law Office

Bronze $2,500

Absolute Resolutions Corp.

Acctcorp International, Inc.

Central Portfolio Control, Inc

Couch Lambert

RAzOR Capital, LLC

Resurgence Capital, LLC

Security Credit Services, LLC

Stillman Law Office

Tobin & Marohn

Troutman Pepper

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

Brass $1,000

Action Collection Agencies, Inc.

Actuate Law, LLC

Advancial Federal Credit Union

AKCP LLC

Aldridge Pite Haan, LLP

Arbeit

Arko Consulting LLC

Balbec Capital

Barron & Newburger, P.C.

Beam Software

Bread Financial

Butler & Associates, P.A.

C&R Software

Call Center Services International

Capio

CBK, Inc.

CCMR3

Cedar Holdings International Inc. DBA Cedar Financial

Commercial Credit Group Inc.

Commercial Funding Inc.

Convergence Acquisitions, LLC

Cornerstone Support, LLC

CSS Impact

D & A Services, LLC

Dobberstein Law Firm, LLC

Epicenter Technologies Pvt. Ltd.

Equabli, Inc

FLOCK Specialty Finance

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Guglielmo & Associates, PLLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Hunt & Henriques, LLP

International Debt Buying Consultants, LLC

Invenio Financial, a Phillips & Cohen Associates company

Investment Retrievers, Inc.

January Technologies, Inc.

Jefferson Capital Systems, LLC

Kota Business Solutions LLC

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Mandarich Law Group LLP

Maxwell & Graves Solutions, LLC

Metacorp, LLC

Mountain Peak Law Group, PC

National Debt Holdings, LLC

Nelson & Kennard

NRA Group, LLC

Nuvei

PCI Group Inc.

Phin Solutions, LLC

Portnoy Schneck, LLC

Premier Forty Financial, LLC

Quall Cardot, LLP

Quantum3 Group, LLC

RevSpring

Robinson Hoover & Fudge, PLLC

Scott & Associates, PC

Sequium Asset Solutions, LLC

SimpleCertifiedMail.com

Skit.ai

Slovin & Associates

Solutions by Text

Stenger & Stenger P.C.

Stone, Higgs & Drexler

Suttell & Hammer

Synergetic Communication Inc

The Cadle Company

TrueAccord

US Mortgage Resolution, LLC

USASF Servicing, LLC

Venable LLP

VeriFacts, LLC.

Vertican Technologies, Inc.

VoApps, Inc.

Other

Alliance Credit Services, Inc.

ARM Compliance Business Solutions LLC

Atlas Acquisitions

Bedard Law Group, P.C.

CMS Services

Coastal Law Firm, APLC

Converging Capital, LLC

Convoke, Inc.

Credit Corp Solutions Inc.

Credit Management Corporation

D1AL

InDebted

Kino Financial Co., LLC

Kirschenbaum & Phillips, P.C.

Law Offices of Steven Cohen LLC

London & London

Martin Lyons Watts Morgan PLLC

MauriceWutscher LLP

Moss & Barnett, P.A.

National Recovery Solutions, LLC

Portfolio Recovery Associates, LLC

Poser Investments, Inc.

ProVest LLC

Receivables Management Association International

Resource Management Services, Inc.

SAM – Solutions for Account Management

SCJ Commercial Financial Services

Simmonds & Narita LLP

Sonnek & Goldblatt, Ltd.

Stone Creek Financial Inc.

Tate & Kirlin Associates, Inc.

The Oakes Law Firm, LLC

Troy Capital, LLC

United Acquisitions, LLC

Vargo & Janson, P.C.

Venandi Systems, LLC