RMAI SEEKS COMMENTS ON PROPOSED CHANGES TO CERTIFICATION PROGRAM
The Certification Council is proposing edits to the Receivables Management Certification Program (RMCP). The Council is required to perform a review of certification program standards at least annually to ensure the program reflects “evolving industry best practices, input from key stakeholders and communities of interest, areas of Council concern, and recent regulatory and statutory changes.”
The proposed changes to the Certification Governance Document have been posted on the RMAI website HERE. RMAI members are encouraged to review the changes and email any comments they have to firstname.lastname@example.org no later than February 27, 2019.
Here is a summary of the major substantive changes to Certification Standards contained in version 7.0:
- Appendix A – Standard # A9 (Payment Processing) – Amends the policy to state that if a consumer refund takes longer than 30 days to process, the Certified Company shall document the reason for the delay in processing the refund.
- Appendix A – Standard # A18 (States of Emergency) – Changes the title from “natural disasters” to “states of emergency” and provides more clarification on when a Certified Company should refrain from consumer contact.
- Appendix A – Standard # B1 (Required Data & Documents) – Adopts data and documentation requirements when purchasing bankruptcy and medical accounts (takes effect August 1, 2019 and only applies prospectively).
- Appendix B – Vendor Certification – Expands the certification program to provide a new voluntary certification for vendors who work with or seek to work with RMAI certified debt buying companies, law firms, and collection agencies.
- Removes Canadian Certification from the RMAI Program – RMAI will not be offering Canadian certification.
Here is a summary of the major substantive changes to Administrative Provisions contained in version 7.0:
- Article 3.7(A)(4) – Council Authority – Provides the Council with powers to suspend a Certified Party by a two-thirds vote, provided that such action is deemed to be an emergency and is based on credible information. The Certified Party will be sent a certified letter and email within 24 hours of an emergency suspension stating the reasons for the suspension and inviting a response. Any suspension by emergency action of the Council shall require the Council to review, discuss, and/or modify said action within seven (7) days after receiving additional information on the matter from the Certified Party.
- Article 8.4(C) – Authorized Audit Providers – Empowers the Audit Committee to approve Authorized Audit Providers without also receiving Council approval. This is similar to the power granted the Administration & Budget Committee and the Educational Requirements Committee.
- Article 9.6 – Emergency Action – Provides the Remediation Committee, by a two-thirds vote, the authority to recommend to the Council the immediate suspension of a Certified Party provided that such action is deemed to be an emergency and is based on credible information.
- Article 10.2 – Background Check Fee – Permits RMAI to charge foreign applicants for individual certification the differential cost between a domestic background check and a foreign background check if the Administration & Budget Committee has reason to believe a more in depth background check is warranted.
- Appendix F – Section F.3 – Remediation Procedures – Permits the Remediation Committee to allow the RMAI Executive Director or staff to contact a Certified Party to request corrective action without a formal Remediation Agreement if the deficiency is “minor in nature and can be easily rectified.”
When responding via email, please: (1) indicate “30-Day Comment” in the email subject line, (2) provide your name and company name in the body of the message, and (3) indicate the page and section number from the Certification Governance Document that your comment is referencing.
Based on comments received from this 30-day comment period, additional edits may be incorporated prior to final adoption. If you have any questions, please contact RMAI at (916) 482-2462.