Affiliated businesses (debt buying companies, collection law firms, and third-party collection agencies) may share certification under a “Family of Companies” designation provided that all of the businesses meet the following criteria:
- Have the same Chief Compliance Officer (CCO)
- Have the same executive management team that exerts control over business operations (this requirement may be waived by the Administration & Budget Committee if there exists other unifying factors that would preclude its necessity)
- Maintain a uniform network of compliance on all accounts serviced between the business entities
- Are governed by the same corporate policies and procedures
- Agree to be audited in a single unified audit
- Agree any Deficiency and Remediation against one business entity will apply to all of the business entities
NOTE: Businesses that do not meet all of the Family of Companies criteria will need to maintain separate business certifications.