RMAI Update May 2025

The Consumer Financial Protection Bureau (CFPB) has recently undertaken a sweeping rollback of prior policy positions, withdrawing 67 pieces of guidance and interpretive rules, some dating as far back as 2011. These withdrawals, highlighted in the May 12^th RMAI Member Alert (click here), include documents that directly affect the receivables management industry, such as guidance on medical debt reporting, nursing home debts, and furnisher investigation procedures.

In a separate federal register notice this week, the CFPB announced that it is withdrawing the proposed data broker rule. Acting CFPB Director Russell Vought stated that the Bureau had determined the proposed rule was “not necessary or appropriate at this time,” citing recent updates to the agency’s policies. Originally proposed in December 2024, the rule aimed to classify data brokers as consumer reporting agencies under the Fair Credit Reporting Act (FCRA), which would have imposed additional regulatory requirements. RMAI submitted written comments on the proposed data broker rule, asserting that the Bureau exceeded its statutory authority in several aspects of the proposal.

This regulatory reversal coincides with the CFPB’s ongoing legal efforts to dismantle certain rules issued under the Biden Administration. Notably, the Bureau has signaled its intent to also withdraw a final rule that would prohibit credit reporting agencies from including medical debts on consumer credit reports. Originally slated to take effect in March, the rule’s implementation was delayed following a 90-day stay issued by U.S. District Judge Sean Jordan of the Eastern District of Texas. The new effective date is currently set for June 15, pending further legal developments.

This regulatory rollback follows the request of Republican members of the House Financial Services Committee, as noted in their March 28^th letter to Acting Director Russell Vought, where they asked for his review of several CFPB final and proposed rules, guidance, and advisory opinions. Rodney Hood, Acting Comptroller of the OCC, received a similar letter on March 28^th from the Committee. Like the CFPB, the OCC acted and on May 8, 2025, adopted an interim final rule restoring streamlined procedures for bank merger reviews and rescinding its 2024 policy statement. The move by the OCC follows strong industry opposition and a Senate vote to overturn the 2024 rule, which critics said created unnecessary burdens and uncertainty. The OCC’s action reflects bipartisan support for a more predictable and balanced merger review process and aligns with similar steps taken by the FDIC earlier this year.

Leadership at the CFPB also remains in flux. President Trump’s nominee to head the Bureau, Jonathan McKernan, who had been awaiting Senate confirmation, has been re-designated for a new role as Undersecretary for Domestic Finance at the U.S. Department of the Treasury. As a result, McKernan is no longer under consideration to lead the CFPB. The Bureau will continue under the acting leadership of Office of Management and Budget Director Russell Vought until a new nominee is named and confirmed. These shifts come amid broader structural and policy changes at the agency.

On Capitol Hill, efforts to reduce the CFPB’s authority and funding continue. On April 30, the House Financial Services Committee advanced its portion of the federal budget package, which includes a proposed 60% reduction in the CFPB’s budget, estimated to save approximately $1 billion. This move follows a March oversight hearing where the Committee considered ten legislative proposals aimed at reforming or constraining the Bureau’s operations.

And last week, a coalition of 233 current and former lawmakers, including the full Senate Democratic caucus, filed an amicus brief defending the CFPB against the Trump Administration’s attempted shutdown. Led by Reps. Waters and Jeffries and Sens. Schumer and Warren, the brief asserts that only Congress, not the executive branch, has the constitutional authority to create or dismantle agencies. Lawmakers warn that eliminating the CFPB would harm consumers and disrupt financial oversight.

These developments represent a continued reorientation of federal consumer financial protection policy and continue to have significant implications for the receivables industry.

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. RMAI has retained lobbyists in 10 states (which ties a record) so far in 2025: California, Colorado, Maine, Michigan, Nevada, New Mexico, New York, Oregon, Vermont, and Wyoming.

If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel & Senior Director of Government Affairs David Reid at (916) 779-2492 or [email protected].

Top Issue: Medical Debt
Medical debt legislation remains the most active subject matter that RMAI is lobbying on in 2025. Currently, we are tracking 130 medical debt bills in the nation and successfully lobbied the bill in 11 states. We continue to fight an Oregon proposal. RMAI’s singular concern on these bills is the definition of “medical debt.” We are advocating for a narrow definition that ensures the definition does not include various consumer credit products, including credit cards, bank loans, and home equity lines of credit. There are 32 states with medical debt bills, including: Arkansas, Connecticut, Florida, Georgia, Hawaii, Illinois, Indiana, Kentucky, Maine, Maryland, Massachusetts, Minnesota, Missouri, Montana, Nebraska, Nevada, New Hampshire, New Mexico, New York, North Carolina, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Texas, Vermont, Virginia, Washington, and Wyoming.

Several important non-medical debt bills RMAI is engaged on include:

California SB 706 – This bill would: (1) prohibit a charged-off consumer debt from being sold or assigned more than one year after the debt was charged off; (2) require a charge-off creditor to notify the consumer when the creditor sells or assigns a charged-off consumer debt to a debt buyer; (3) prohibit an action from being brought to recover a charged-off consumer debt within two years after the date the creditor provided a notice of default or delinquency to the consumer or 90 days after the debt was charged off, whichever occurs earlier; and (4) prohibits a debt buyer from bringing an action to recover a charged-off consumer debt after one year from the date the debt was charged off. [RMAI is in strong opposition, along with a large coalition within the financial services industry. This bill is the first, to RMAI’s knowledge, to reduce the statute of limitations to below 3 years on a consumer debt. This bill would essentially impose a 90-day SOL on banks and a one-year SOL on debt buyers. This bill failed in committee and is dead for the year.]

Massachusetts SB 735 – This bill would, among other things: (1) increase the garnishment exemption from 50x state minimum wage to 65x state minimum wage; (2) reduce the statute of limitations (SOL) in an action for the collection of a consumer debt from six to five years; (3) prohibit the revival of a debt that is beyond the statute of limitations through the making of a payment; and (4) reduce 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 January 1, 2026. [RMAI has been opposing this bill since 2014 when it was first introduced. After eight years of negotiations and countless amendments, RMAI, other industry participants, and consumer advocates agreed to amendments that resulted in a neutral position by the industry. Among items removed from the bill through RMAI’s efforts from its 2014 introduction: (a) 90x minimum wage garnishment exemption; (b) expungement of the debt once the SOL expires; (c) reducing the SOL from six to three years; (d) preventing the tolling of the SOL through a payment prior to the expiration of SOL; (e) reducing the enforcement of a judgment from 20 to 5 years with no renewal; (f) applying the bill’s provisions to real property; and (g) once the consumer exceeds the exemption threshold, only being able to garnish on income above the threshold.]

Nevada SB 142 – This bill would, among other things: (1) amend the wage garnishment laws to exempt up to 90% of weekly disposable income; (2) exempt $5,000 in a personal bank account, (3) require a CPI adjustment to exemptions every three years; and (4) increase the homestead exemption to equity in property up to $605,000 and outlines conditions under which proceeds from the sale of a homestead remain exempt. [RMAI strongly opposes the wage and bank garnishment provisions. RMAI has a lobbyist in NV where we are actively lobbying against passage of the bill.]

New York AB 5537 / SB 4271 – This bill would establish a state-wide debt collector license in New York under the authority of the Department of Financial Services (the same agency that licenses the banking and insurance industries and which for the last 11 years has promulgated rules for debt collectors). [RMAI has been working with the legislature on amendments to various versions of this bill for years and has been successful in obtaining most of our requested amendments in the current draft. RMAi is presently opposed to this version because the bill does not preempt New York City licensure and rulemaking. RMAI is seeking preemption of all municipal licensing and regulatory requirements.]

New York Attorney General UDAAP Program Bill — The New York Attorney General has proposed a bill that would strengthen New York’s UDAAP provisions. However, RMAi is in strong opposition due to the bill containing: (1) a private right of action where the consumer does not have to show an actual injury and (2) a public registry of all UDAAP settlements. [RMAI has had three very constructive meetings with the New York Attorney General’s Office in the past month explaining our opposition. Through RMAI’s efforts and that of the New York Business Council, of which RMAI is a member, we believe the bill will see amendments after its introduction.]

Eighth Circuit Holds Cost of Envelope and Postage Enough for Article III Standing
Ebaugh v. Medicredit, Inc., No. 24-1838, 2025 U.S. App. LEXIS 8530 (8th Cir. Apr. 11, 2025)

A consumer failed to make timely payments on medical bills and received a demand for payment from a collection agency.  The consumer contacted an attorney who advised the agency that the consumer was represented, that she refused to pay the debt, and that further communication and collection efforts should cease.  Thereafter, the agency sent a letter directly to the consumer with a settlement offer, and the consumer mailed the letter to her attorney.

The consumer filed a lawsuit against the agency alleging violations of the Fair Debt Collection Practices Act.  Specifically, she alleged a violation of 15 U.S.C. § 1692c(c) for sending the letter to her following a cease and desist demand, and § 1692c(a)(2) for contacting her after being informed she was represented by counsel.  Among her various claims of injuries, the consumer stated she had to review the letter, place it in an envelope worth approximately $.08, affix a  stamp that cost $.06, and walk it to the mailbox.  The trial court dismissed the lawsuit for lack of Article III standing, and the consumer appealed.

On appeal, the U.S. Court of Appeals for the Eighth Circuit held, in an unpublished opinion, that  the consumer “clearly alleged facts demonstrating that she suffered a concrete injury when she purchased postage and an envelope to send [the agency’s] improper communication to her counsel, an act that was caused by the FDCPA violation and that was necessary to allow reassertion of [the consumer’s] right not to be contacted directly while represented by counsel.”

The Court therefore reversed the judgment of the trial court and remanded the matter for further proceedings.

Ninth Circuit Focuses on “Materially Misleading” Standard in FCRA Case
Davis v. PNC Bank, N.A., No. 24-2564, 2025 U.S. App. LEXIS 9908 (9th Cir. Apr. 25, 2025)

Two consumers filed a lawsuit against a creditor alleging it violated the Fair Credit Reporting Act (“FCRA”) and the California Rosenthal Act by continuing to report their vehicle loan as having an unpaid balance after it had been refinanced and paid off.

The trial court granted the creditor’s motion for summary judgement on the FCRA claim finding there was “no genuine dispute of fact that [the creditor’s] reporting was not ‘patently incorrect’ in violation of the FCRA.”  The court explained that the consumers total payments were $81.11 less than the original loan amount, so the “reports that the [original] loan had an outstanding balance were not ‘incomplete or inaccurate’ on this basis.”

The trial court also the creditor’s motion for summary judgment on the Rosenthal claim based on the dismissal of the FCRA claim.

On appeal, in an unpublished opinion, the U.S. Court of Appeals for the Ninth Circuit found the trial court’s finding on the FCRA claim was correct, but nevertheless erred “in holding that this was the only theory of FCRA liability alleged by the [consumers].”  The Court explained that “information furnished to credit reporting agencies (“CRAs”) may be ‘incomplete or inaccurate’ under § 1681s-2(b) where it is ‘materially misleading’—even though the information is technically correct.”

In this case, the Court found that the consumers “sufficiently alleged that [the creditor’s] reports were materially misleading because the reports failed to inform the CRAs of the parties’ ‘bona fide dispute’ regarding the loan balance.”  Although the theory of the consumers’ complaint was incorrect by not explicitly stating the reports were materially inaccurate, the Court noted that “a plaintiff ‘does not need to plead specific legal theories in the complaint, as long as the opposing party receives notice as to what is at issue in the lawsuit.’”

Based on this, the Court vacated the trial courts summary judgment rulings and remanded the matter for further proceedings.

Third Circuit Holds FCRA “Technically Correct” Information Can Be Inaccurate
Ritz v. Equifax Info. Servs., LLC, No. 23-2181, 2025 U.S. App. LEXIS 10835 (3d Cir. May 6, 2025)

Two consumers leased a vehicle from a dealership, and the lease was then assigned to a motor vehicle finance company on the same terms as the original lease.  Near the end of the lease, the consumers received an email instructing them to schedule an appointment with the dealership for an inspection and return of the vehicle.  They did not make an appointment, but did return the vehicle to the dealership on the due date.

Since they didn’t have an appointment, “the dealership refused to accept the vehicle, inspect the vehicle, or provide plaintiffs with a mileage statement they were required to sign under the lease terms.”  The dealership didn’t report the vehicle as being returned, the finance company continued to charge the consumers monthly and, when they didn’t pay, reported the delinquency to the credit reporting agencies (“CRAs”).  Then ensued the following:

• The finance company reviewed the complaints and asked the dealership for an explanation;
• The dealership stated the consumes didn’t follow procedures and abandoned the vehicle;
• The finance company adjusted the consumers’ balance to zero and made an internal request to its credit team for the delinquency to be removed from the consumers’ credit report;
• The credit team ignored the request because the vehicle’s VIN, as reported by the dealership, contained a typographical error;
• The consumers disputed the reporting with the CRAs, which forwarded the disputes to the finance company, and the finance company continued to report the delinquency;
• Following additional complaints to the finance company and to the Consumer Financial Protection Bureau, the finance company removed the delinquency.

The consumers filed a lawsuit against the finance company alleging it violated the Fair Credit Reporting Act (“FCRA”), specifically, 15 U.S.C. § 1681s-2, “by reporting a past due balance to CRAs after receiving notice of [the consumers’] disputes with those CRAs.”  The finance company “argued the reporting was accurate because the vehicle was not properly returned since the car was not inspected and accepted by the dealership with a signed odometer statement in accordance with the lease agreement.”

The trial court granted the finance company’s motion for summary judgment, finding that the “ultimate resolution of the dispute in [the consumers’] favor did not, in and of itself, render its prior credit reporting inaccurate.”  Additionally, it found that the “dispute largely boiled down to ‘a contract dispute, not a factual inaccuracy,’ and held as a matter of law that such a dispute is not actionable under FCRA.”  The consumers appealed.

In a non-precedential opinion, the U.S. Court of Appeals for the Third Circuit began by explaining that those who furnish information to the CRAs, like the finance company, have a duty after receipt of a consumer’s dispute to “’conduct an investigation with respect to the disputed information’ and ‘report the results of the investigation to the consumer reporting agency.’ 15 U.S.C. § 1681s-2(b)(1)(A), (C).”

The Court also explained that the FCRA provides a private right of action for violations of § 1681s-2(b), provided: “(1) the plaintiff must make a prima facie showing that the . . . furnisher provided incomplete or inaccurate information, and (2) the plaintiff must . . . show that the incompleteness or inaccuracy was the product of an unreasonable investigation.”

On the first point, the Court noted that “[a]lthough it is unresolved whether reported information that is subject to a legal dispute can be ‘inaccurate’ or ‘incomplete’ under the statute, it is well established that factually incorrect information is ‘inaccurate’ for purposes of FCRA,” and even “’technically correct’ information is inaccurate if it creates a materially misleading impression such that it can be expected to have an adverse effect.”

Here, the Court concluded that the trial court erred in granting summary judgment because a jury could have found the finance company’s reporting inaccurate or misleading when: “(1) [the finance company’s] complaints department had repeatedly found that [the consumers] had no outstanding obligation . . . and (2) the record indicate[d] that the reason the delinquency was not removed was because the dealership had made a typographical error in its letter . . . and the credit reporting department repeatedly declined to correct the delinquency on this basis.”

The Court held similarly on the second point, noting that “a jury could have determined from the record that the continued reporting of a past due balance may not have been due to a bona fide belief that [the consumers] were liable, but rather because different departments failed to communicate with one another about [the consumers’] case, in part due to a typographical error by the dealer. And a jury could have concluded that [the finance company’s] investigation was unreasonable based on the credit reporting team’s refusal to consider (1) evidence suggesting its credit reporting might be inaccurate—namely, the dealership letter and complaints department’s repeated service requests—and (2) attempts to determine whether the dealership letter pertained to the [consumers’} account, despite the typographical error.”

For these reasons, the Third Circuit reversed the order of the trial court and remanded the matter for further proceedings.

Amicus appellants and appellees included the CFPB, Americas Credit Unions, ACA International, The Association of Credit and Collection professionals, Consumer Data Industry Association, U.S. Chamber of Commerce, American Bankers Association, American Financial Services Association, Consumer Bankers Association, Independent Community Bankers of America, and Mortgage Bankers Association.

RMAI Continues Its Advocacy
RMAI actively monitors legislation across the country to protect your best interests. Recently, RMAI has opposed Oregon S.B. 605, met with California State Senator Josh Becker’s staff regarding S.B. 468, engaged with Assembly Member Rebecca Bauer-Kahan’s office and sponsor on A.B. 10108, and traveled to New York for its annual Lobby Day. Looking ahead, RMAI will provide testimony on Nevada A.B. 250 and submit letters of opposition to Massachusetts H. 1386 and Connecticut S.B. 2.

Your donations make a difference and enable RMAI to continue these important advocacy efforts. If you’d like to contribute to the Legislative Fund, you can Donate Here. We will add your Company name to our list of Legislative Fund contributors on our website.

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.

Recorded Webinars
With April and May being a busy time for webinars you can catch up on all the latest and greatest and earn your certification credits as well for your Certified Receivables Compliance Professional (CRCP) designation.

Recorded on April 16, 2025, register for FCRA Regulatory Requirements and Practical Solutions for Compliance.  In this webinar, our presenters dove into what’s new on the regulatory front for credit reporting, and what hasn’t changed but what remains important across furnishing, disputes and usage and discuss strategies to help furnishers and end users satisfy compliance expectations.

Recorded on April 29, 2025, register for D.C. Download: Behind the Headlines on Capitol Hill, CFPB, and DOGE. In this webinar, our presenters gave exclusive updates in Congress, updates on regulatory actions, agency agendas, and legal challenges shaping the financial services landscape.

Recorded on May 6, 2025, register for New York City’s Twisted Path to an Amended Debt Collection Rule. This presentation explored communication restrictions; the limited creditor exemptions and why they are more limited than you might think; verification; validation and noticing requirements; and why this latest version is bound to harm consumers and the credit industry.

Recorded on May 8, 2025, register for California DFPI Examinations Under the Debt Collection Licensing Act. In this webinar, our presenters led a robust discussion on preparing for a California DFPI Debt Collector Licensee (DCL) exam.

Click here for more information on our live and recorded educational webinars. Contact Shannon Parod at [email protected] to find out more about sponsoring an RMAI webinar.

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

CRCP New
Brittney Rocha, Velo Law Office
Paula Fox, Southwood Financial

CRCP Renewals
Lindsey Flewelling, Law Offices of James R. Vaughan
Anthony Guajardo, Integras Capital Recovery
Jill Pheffer, Crown Asset Management
Keshonda Walker, InvestiNet

CRB Renewals
Diverse Funding Associates
Plaza Services

View all certified businesses and vendors.
View all certified individuals.

Resources for Individual and Business or Vendor Certification
RMAI has developed certification resources for our members who are going through the individual or business/vendor certification and aren’t sure where to start or aren’t sure how long the process takes. These easy to follow and game-oriented resources will help you feel less intimidated and more confident in how to obtain certification at any level.

Individual Certification

• CRCP Timeline
• 7 Steps to Earn a Certified Receivables Compliance Professional (CRCP) Designation

Business/Vendor Certification

• 7 Steps to Earn the Certified Receivables Business (CRB) Designation
• 7 Steps to Earn the Certified Receivables Vendor (CRV) Designation
• CRB Timeline

View our full list of certification resources.

Executive Summit Early Registration Ends Soon!
Don’t miss the deadline to receive the Early Member Rate when you register for the 2025 Executive Summit – June 11^th, 2025 is the last day to register to take advantage of the best deal of the summer! Network with your industry peers while you enjoy the beauty of the Woodstock Inn & Resort in Woodstock, Vermont. Don’t forget, you can earn credits for both the Certified Receivables Compliance Professional (CRCP) designation and Continuing Legal Education (CLE) at this event.  Register today to make sure you don’t miss out!

Check Out RMAI’s Resource Library
Remember that the RMAI Resource Library is here for you! Whether you’re looking for certification, compliance, or membership resources, or even White Papers and advertising guidelines, all the information you’ll need is available in our easy to navigate Resource Library.

Welcome, New Members

• United Credit Services Group PTE, LTD | TW
• Abstrakt | AZ
• Scheer, Green and Burke LPA | OH
• 1^st Franklin Financial Corporation | TX

For a complete list of RMAI members, login to check out the Member Directory.

2025 RMAI Executive Summit | August 5-7, 2025

Registration is now open!

Legislative Fund Contributors May 1, 2024 – May 14, 2025

DIAMOND
Absolute Resolutions Corp.
Cavalry Investments, LLC
Crown Asset Management, LLC
Financial Recovery Services, Inc.
Resurgent Holdings, LLC
Second Round, LP
TRAKAmerica
Velocity Portfolio Group, Inc.

TITANIUM
Garnet Capital Advisors, LLC

PLATINUM
Andreu, Palma, Lavin & Solis,  PLLC
Blitt and Gaines, P.C.
Cascade365 Family of Companies
DebtNext Software, LLC
InvestiNet, LLC
Klima, Peters & Daly, P.A.
Pharus Funding, LLC
T & I Enterprises, LLC
Velo Law Office

GOLD
Rausch Sturm, LLP

SILVER
Firstsource
Halsted Financial Services, LLC
National Credit Adjusters, LLC

BRONZE
Central Portfolio Control, Inc
Corporate Advisory Solutions, LLC
D & A Services, LLC
Equabli, Inc
Resurgence Capital, LLC
Security Credit Services, LLC
Superlative RM
Tromberg, Morris & Partners, PLLC

BRASS
AAA Lenders Inc
Acctcorp International, Inc.
Advancial Federal Credit Union
AgreeYa Solutions, Inc.
Aldridge Pite Haan, LLP
ARM Compliance Business Solutions LLC
ARS National Services, Inc.
Balbec Capital
Basham & Scott, LLC
Bayview Solutions, LLC
CBE Companies
Cedar Global Solutions LLC dba Remote Scouts
Channel Payments, Inc.
CMS Services
CNG/Axcess Financial Services, Inc.
Collection Attorneys USA LLC
CompuMail Information Systems
ConServe
Cornerstone Licensing Services
Couch Lambert
Credit Control, LLC
Credit Corp Solutions Inc.
FDR Alliance LLC
FLOCK Specialty Finance
FMA Alliance, Ltd
ForgiveCo PBC Inc
Frost Echols LLC
G. Reynolds Sims & Associates, P.C.
Genesis Recovery Services
Gordon, Aylworth & Tami, P.C.
Grassy Sprain Group, Inc
Guglielmo & Associates, PLLC
InterProse
Jefferson Capital Systems, LLC
Kino Financial Co., LLC
Law Office of James R. Vaughan, P.C.
Mandarich Law Group LLP
Markoff Law LLC
Moss & Barnett, P.A.
Mountain Peak Law Group, PC
National Debt Holdings, LLC
NCB Management Services, Inc.
Nelson & Kennard
NICE
Nuvei Technologies Inc.
PaymentVision (Autoscribe)
PCI Group Inc.
Phin Solutions, LLC
Plaza Services
Premium Asset Recovery Corp (PARC)
Pressler, Felt and Warshaw, LLP
RAS LaVrar LLC
Reassigned Numbers Database (RND)
Remitter
Revenue Assistance Corporation dba Revenue Group
Robinson Hoover & Fudge, PLLC
SAM – Solutions for Account Management, Inc.
Scott & Associates, PC
Shepherd Outsourcing, LLC
Slovin & Associates
Smith Debnam Narron Drake Saintsing & Myers, LLP
SMS Financial, LLC
Stillman Law Office
Stone Creek Financial Inc.
Stone, Higgs & Drexler
Suttell & Hammer
The Cadle Company
The Moore Law Group
The Oakes Law Firm, LLC
Tratta
Troutman Pepper Locke
Troy Capital, LLC
Vertican Technologies, Inc.
Womble Bond Dickinson
Zarzaur & Schwartz, P.C.

OTHER
Actuate Law, LLC
Alliance Credit Services, Inc.
Bedard Law Group, P.C.
C & E Acquisition Group, LLC
Caddis Funding LLC
CASA Receivables Management, LLC
Ceteris Portfolio Services LLC dba J.J. Marshall & Associates
Cohen & Cohen Law, LLC
Complete Credit Solutions, Inc.
Consuegra & Duffy, PLLC
Convoke, Inc.
Credit Management Corporation
Denali Capital, LLC
First Credit Services, Inc
First Financial Asset Management, Inc. (FFAM 360)
Harvest Strategy Group, Inc.
Hudson Cook, LLP
Indiana Receivables, Inc.
Kaleo Legal
London & London
Martin Golden Lyons Watts Morgan PLLC
MauriceWutscher LLP
McGlinchey Stafford, PLLC
National Recovery Associates, Inc.
National Recovery Solutions, LLC
Payment Savvy, LLC
Pro Forma Inc
SIMM Associates, Inc.
Sonnek & Goldblatt, Ltd.
Tavelli Co., Inc. dba Tavco Credit Services
The Law Offices of Ronald S. Canter, LLC
Vargo & Janson, P.C.