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. RMAI members are encouraged to review the changes and email any comments they have to firstname.lastname@example.org no later than January 28, 2022.
Here is a summary of the major substantive changes to Certification Standards contained in version 10.0:
- Appendix A – Standard # A2 (Insurance Coverage) – Adds a $1 million-dollar Cyber Crime Policy requirement.
- Appendix A – Standard # A5 (Consumer Complaint and Dispute Resolution) – Adds to the list of what a “reasonable” Consumer Complaint & Dispute Resolution Policy should contain.
- Appendix A – Standard # A22 (Discriminatory Collection Practices) – Creates a new standard that requires Certified Companies to maintain a policy which prevents discriminatory collection practices. The criteria for this standard was developed by the RMAI Artificial Intelligence Working Group.
- Appendix A – Standard # A23 (Communication Restrictions) – Creates a new standard that requires a Certified Company to record consumer communication restrictions and based on statutory, regulatory, or contractual requirements transmit those restrictions to clients, agents, or purchasers.
- Appendix A – Standard # B1 (Required Data & Documents) – Adopts data and documentation requirements when purchasing installment loans (takes effect August 1, 2022 and only applies prospectively). The criteria for this standard was developed by the RMAI FinTech Working Group.
- Appendix A – Standard # B4 (Sale Restrictions) – Adds additional sale restrictions for when an account has been permanently closed due to hardship or permanently closed by a regulatory or judicial order.
- Appendix B – Standard # 104 (Insurance Coverage) – Adds a $1 million-dollar Cyber Crime Policy requirement for certified vendors.
Here is a summary of the major substantive changes to Administrative Provisions contained in version 10.0:
- Article 3.3 – Composition – Expands the size of the Certification Council from 11 members to 12 members by adding a second Originating Creditor member to the Council.
- Article 6.8 (D) – Class Format – With the exception of CCOs, allows certified individuals to take all of their classes in any educational format of their choosing (in-person, online, recorded, or combination). CCOs will have to have 12 live credits.
- Article 8.5 (D) – Scope of the Full Compliance Audit – In certain circumstances, RMAI businesses will have the option to have virtual in-person audits.
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.
This Member Alert is intended for members of the Receivables Management Association International, is for informational purposes only, and is in no way intended to provide legal advice. Members are encouraged to consult with an attorney of their choice for legal advice concerning this matter.