RMAI Update April 2020

In response to the COVID-19 state of emergency, the Receivables Management Association International (RMAI) is issuing updates periodically with guidance for our members.  RMAI maintains a COVID-19 resource page on the RMAI website that is accessible without a member password. Included on this webpage are COVID-19-related member alerts, webinars, regulatory and legislative resources, Executive Orders, and emergency court rules. We update the site daily, so please check back often for updates.

Please note, there will be NO office closures this month.  The RMAI staff is continuing to work from home during the COVID-19 situation, and is available by phone and email.

As always, RMAI is engaged on many fronts. Related to the COVID-19 national emergency, RMAI  is relaying our concerns – to the CFPB, Senate Leadership, House of Representative Leadership, key committee leadership in the Senate and House, and the administration – with various proposals that would put outright and complete bans on the collection of debt. In all cases, we offer reasonable solutions and closely monitor the series of COVID-19 relief bills (commonly referred to Phase I, Phase II, etc.) for any language affecting the industry. This week, we updated RMAI’s COVID-19 guidance to advise members not to seek the federal stimulus funds in their debt collection efforts. This advice has also been communicated to Treasury Secretary Mnuchin and other Federal policymakers.

Related to the CFPB’s Supplemental Rule on Time-Barred Debt Disclosures, the Comment period continues to run. RMAI is currently surveying members on their business practices related to time-barred debt. In the meantime, the Federal Committee is drafting comments and will incorporate data received from the survey.

RMAI is actively monitoring over 300 bills that may impact the receivables industry in both positive and negative ways. Here are a few noteworthy bills that have been introduced:

California SB 908 – This bill would require debt collectors (collection agencies, debt buyers and collection law firms) to be licensed by the Department of Business Oversight in California. The bill generally contains requirements similar to other state licensing requirements and unlike New York’s licensing proposal does not contain conduct limitations. It does contain language which would allow consumers to access a licensee’s bond. [RMAI has met with the sponsor’s office and provided them redlines. RMAI’s redlines, among other things, would place limitations on consumers’ access to bonds; allow a family of companies to share a license; place a cap on annual fees; protect confidential business records; and delay the effective date until January 1, 2022.]

Maine LD 1053 [Chapter 622 of the Laws of 2020] – This bill would reduce the 20-year statute of limitations for acting on a judgment to 10 years with a 10-year renewal. The law takes effect on September 1, 2020. [The bill originally would have deemed any judgment or decree of any court based upon a consumer obligation “paid and satisfied” at the end of one year unless within that period the judgment creditor has commenced an enforcement action on the judgment or decree. It was through RMAI’s efforts and the efforts of the RMAI lobbyist we were able to negotiate a compromise with Maine consumer advocates. The bill passed both houses of the legislature and was signed into law by Governor Mills on March 18, 2020.]

Maryland HB 365 – This bill would change the wage garnishment exemption from 30x federal minimum wage to 30x state minimum wage. [An industry coalition fought adoption of this bill for years as the sponsor was seeking to adopt a 50x state minimum wage threshold. Industry and the sponsor compromised by keeping the multiplier the same but switching from federal to state minimum wage. The amended bill has passed both houses and is awaiting submission to the Governor Hogan.]

Massachusetts SB 578/HB 919 – This bill among other things would: (1) reduce the statute of limitations in an action for the collection of a consumer debt from six to four years to be measured from the earlier of the date of charge-off, placement for collection, or 180 days after the last regular payment; (2) prohibit payments made prior to the limitations period expiring from tolling the statute; (3) prohibit any attempt to collect a consumer debt once the statute of limitations has expired but would allow a debt collector to accept an unsolicited voluntary consumer payment on a debt; (4) extinguish judgments after five years unless the creditor takes action to enforce the judgment; and (5) reduce the percentage that is subject to wage garnishment. [RMAI has retained a lobbyist to oppose the bill in its current form. RMAI participated in a stakeholder roundtable requested by the committee chair in January 2020. Working with a receivables industry coalition, RMAI has exchanged several redlines with consumer advocates. While we have made progress, more work is needed. Given the interruptions caused by the pandemic, it is not clear if this bill will be considered in 2020.]

New York AB 6909-B/SB 4827-B – This bill called the “Consumer Credit Fairness Act” would: (1) reduce the statute of limitations from six to three years on consumer credit transactions; (2) “extinguish” the right to collect on consumer debt past the statute of limitations; (3) require the mailing of a notice by the court clerk after filing proof of service of the summons and complaint; (4) require specific data to be included in the complaint; and (5) require the provision of form affidavits. [RMAI has a New York lobbyist and is working closely with a coalition of industry lobbyists to fight this bill. The coalition participated in a roundtable discussion with the Senate sponsor and consumer groups on November 26, 2019,  in New York City in an attempt to find some common ground. The meeting went better than the industry anticipated. Industry submitted new redlines in January. Given that the New York Legislature is not in session due to the ongoing pandemic, we are not sure when an amended version of the bill will be made available by the sponsors. It is probably now unlikely that this bill will be considered in 2020.]

New York AB 9508/SB 7508 (Governor’s Proposed Budget Bill – Part LL on p. 131) – This bill would license debt collectors in New York State. Much of the language is common to state licensing laws. However, there are highly problematic provisions which would prohibit: (1) calls later than 8 p.m.; (2) calls to the consumer’s place of employment; (3) communicating with the consumer more than 2 times in 7 days; (4) communicating by means of electronic communication; and (5) communicating by voicemail if it is “reasonably known” to be accessed by others. [Due to the ongoing pandemic, the debt collection licensing provisions as well as other non-critical policy issues were removed from the New York budget. While we expect to see this proposal return again, passage in 2020 is now unlikely given that the virus has shortened their 2020 session. RMAI will continue to work with our NY lobbyist and the Governor’s office to get our concerns addressed.]

Washington HB 2476 [Chapter 30 of the Laws of 2020] – This law requires debt buyers to provide basic account-level information in or attached to a complaint. Portions of the bill text was modeled after Colorado’s 2017 debt buyer law which RMAI supported. The law takes effect on June 11, 2020. [RMAI and other industry participants retained lobbyists to negotiate this bill. It was through these negotiations that took place prior to bill introduction that we were able to alter the original bill draft (that was very problematic) to the language adopted in Colorado. Post-introduction, RMAI and industry participants agreed to compromise language which resulted in amended text which RMAI supported. The bill passed both houses of the legislature and was signed into law by Governor Inslee on March 18, 2020.]

If you are interested in obtaining a copy of the RMAI state tracking list, please contact David Reid at [email protected].

Third Circuit Reverses Itself on “In Writing” Requirement

Riccio v. Sentry Credit, Inc., No. 18-1463, 2020 U.S. App. LEXIS 10073 (3d Cir. Mar. 30, 2020)

Nearly 30 years after authoring an opinion that has been rejected by the Second, Fourth and Ninth Circuits and ignored by the First, Fifth, Sixth and Seventh Circuits, the Third Circuit finally acknowledged that its original interpretation of 15 U.S.C. 1692g(a)(3) of the Fair Debt Collection Practices Act was wrong.

The validation notice requires a debt collector provide the consumer a notice containing, among other things, the following:

• 1692g(a)(3): “a statement that unless the consumer, within 30 days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector;” and
• 1692g(a)(4): “a statement that if the consumer notifies the debt collector in writing within the 30-day period that the debt, or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a judgment against the consumer and a copy of such verification or judgment will be mailed to the consumer by the debt collector;”

As background, in Graziano v. Harrison, 950 F.2d 107 (3d Cir. 1991), a collector sent a letter advising a consumer that his dispute must be in writing.  The Third Circuit held that “given the entire structure of section 1692g, subsection (a)(3) must be read to require that a dispute, to be effective, must be in writing.”

Nevertheless, most courts outside of the Third Circuit simply read the statute as it was written and did not require a debtor to dispute a debt in writing under § 1692g(a)(3).  Further, so long as a collector copied and pasted the text of § 1692g(a) into their letters, courts within the Third Circuit were primarily concerned with other language in letters that could overshadow the requirement that disputes be in writing.  For example, in Caprio v. Healthcare Revenue Recovery Group, 709 F.3d 142 (3d Cir. 2013), a letter that invited a debtor to call the collector if it had any disputes triggered a violation of the FDCPA.  Based on the reasoning from Graziano, Caprio held that inviting a debtor to call a collector to make a dispute contradicted the requirement that all disputes had to be in writing.

Eventually, cases emerged alleging that a letter sent to a consumer that quoted the language of the FDCPA verbatim actually violated the FDCPA, which is exactly what happened in Riccio.  The collector’s letter included the § 1692g(a) language, and Riccio filed suit arguing that the letter did not explicitly require disputes to be in writing. Sentry Credit moved for judgment on the pleadings and its motion was granted.

On appeal, the Third Circuit decided to revisit its holding in Graziano. Interestingly, the court succinctly explained that the plain reading of § 1692g(a)(3) confirmed that disputes did not have to be in writing unlike § 1692(g)(4) and (5) which specifically have “in writing” requirements.  The court noted that the Second, Fourth and Ninth Circuits previously split with the Third Circuit and its holding in Graziano, finding instead that there was no requirement for disputes to be in writing and also that the First, Fifth, Sixth and Seventh Circuits did not require a written dispute either.

Riccio requested that the holding not be applied retroactively to her claim, but the Third Circuit declined the request, explaining that “our holding today is the controlling interpretation of federal law and must be given full retroactive effect in all cases still open on direct review and as to all events, regardless of whether such events predate or postdate our announcement of the rule. . . We will, therefore, apply to this case our new rule that debt collectors need not require debtors to dispute the validity of their debt in writing.” Looking at it from the perspective of collectors, the court added this interesting footnote:

We do not suggest that debt collectors who sent Graziano-compliant letters before today will be on the hook for failing to foresee our change in the law. Just as collectors who act “in good faith in conformity with any [agency] advisory opinion” cannot be liable if that “opinion is amended, rescinded, or” judicially invalidated, § 1692k(e), collectors should not be penalized for good-faith compliance with then-governing caselaw. To that end, we note district courts can withhold damages for unintentional errors, § 1692k(b), award no damages for trivial violations, § 1692k(a)(1), and even award attorney’s fees to the collector if the debtor’s suit “was brought in bad faith and for the purpose of harassment,” § 1692k(a)(3). See generally Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. 573, 597-99, 130 S. Ct. 1605, 176 L. Ed. 2d 519 (2010). We have confidence in district courts to exercise that discretion appropriately.

In conclusion, the Third Circuit stated “that debt collection notices sent under § 1692g need not require that disputes be expressed in writing. In doing so, we overrule Graziano’s contrary holding. Because Sentry Credit’s notice perfectly tracked § 1692g’s text, we will affirm the judgment of the District Court.”

5th Circuit Holds That Stating An Amount “May” Increase Does Not Violate FDCPA

Salinas v. R.A. Rogers, Inc., No. 19-50618, 2020 U.S. App. LEXIS 7958 (5th Cir. Mar. 12, 2020)

In Salinas, a consumer obtained a loan from a credit union (“creditor”) for personal, family or household use.  The debtor eventually defaulted, and a debt collection agency mailed a collection letter to the debtor listing $4,629.96 as the “Principal Balance” and “Total Amount Due” on the account, and “Interest” and “Fee[s]” as $0. The collection letter included a statement that “[i]n the event there is interest or other charges accruing on your account, the amount due may be greater than the amount shown above after the date of this notice.”

The debtor characterized the statement as an improper attempt to induce payment because the debt collector was not permitted to collect interest or other charges on debts owed to the creditor, and the loan agreement itself did provide for the addition of interest or other charges.

On this basis, the debtor filed a putative class action complaint in federal court alleging that the collection letter’s language was false, deceptive and misleading in violation of section 1692e of the FDCPA, and seeking certification of a class of “[a]ll consumers within the State of Texas that have received collection letters from [debt collector] concerning debts from [creditor] within one year prior to filing of this complaint which falsely represent to the consumer that interest or other charges may accrue.”

The parties did not dispute that (1) the debt collector did not collect interest or charges on debts referred to it for collection from the creditor; and, (2) the subject credit agreement was silent as to whether interest or other charges could accrue in the event of a default.

The debt collector moved for summary judgment on the basis that the collection letter “clearly and unambiguously state[d] the amount of the debt” in compliance with the FDCPA, and that the “plain statement” that the total amount due was $4,629.96 and interest and fees were $0 was “not undercut by the contingent (but obviously inapplicable rather than ‘applicable’) language of the [challenged] sentence.”

The trial court granted summary judgment in the debt collector’s favor on different grounds, reasoning that the letter was not false, misleading, or deceptive because the creditor could have elected to charge interest on the defaulted loan under the Texas Finance Code section 302.002, and the letter was “not confusing on its face.”  Salinas v. R.A. Rogers, Inc., No. SA-18-CV-733-XR, 2019 WL 2465325, at *5 (W.D. Tex. June 13, 2019) citing Tex. Fin. Code § 302.002 (“Texas law stipulates that a six percent interest rate may be applied to the principal balance of the loan starting thirty days after payment is due when the obligor has not agreed on an interest rate.”).  The debtor appealed.

On appeal, the debtor argued that reversal was warranted because (1) the collection letter’s “utterly false” conditional statement violated the FDCPA, and (2) the trial court improperly drew one or more inferences in the debt collector’s favor by inferring that the debt collector would collect interest based on the fact that it could under Texas law, and improperly required evidence of “subjective confusion” on the part of the debtor.

Addressing these arguments in order, the Fifth Circuit first turned to the plain language of § 1692e of the FDCPA, which prohibits “[t]he false representation of the character, amount, or legal status of any debt” or of “any services rendered or compensation which may be lawfully received by any debt collector for the collection of a debt,” and also “any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer.” Section 1692(e)(2)(A), (e)(2)(B) and (e)(10).

The debtor argued on appeal that the collection letter implied a false proposition that interest or other charges could accrue on the account in the absence of payment despite the fact that no circumstances would allow his debt to increase due to interest or other charges while being collected upon by the debt collector.

To the extent the debtor claimed that the collection letter’s language was “false,” the Fifth Circuit rejected this argument as “downright frivolous,” reasoning that the use of the term “in the event” merely expressed a truism the equivalent of “if,” and does not state that the lender or debt collector would or could collect interest.

Turning to whether the collection letter was deceptive or misleading, the Fifth Circuit concluded that reading the letter as a whole, not even the unsophisticated or least sophisticated consumer would conclude that interest or other charges would accrue absent prompt payment. The letter simply warned of a possible outcome “in the event such charges are accruing.” (emphasis in original).

Notably, in affirming the judgment of the trial court, the Fifth Circuit also observed::

What is more, the outcome [the debtor] proposes would force collection agencies to sift through applicable statutes and loan contracts to determine with absolute certainty, for each and every account, whether interest or other charges might possibly accrue, insofar as some debt collectors have been exposed to FDCPA liability for omitting statements similar to the one at issue here.

Indiana Supreme Court: 3 Statutes of Limitations Options Available to Mortgagees 

Blair v. EMC Mortg., LLC, 139 N.E.3d 705 (Ind. 2020)

The Indiana Supreme Court recently held that there are important legal differences between closed-end installment contracts (such as ordinary mortgage loans) and open-end accounts (such as HELOCs) when considering statute of limitations, and there is no need to impose a rule of reasonableness when a lender sues for payment on a closed-end installment contract.

The mortgagors executed a 15-year note and mortgage beginning in 1993.  The note allowed the lender to accelerate and demand immediate payment in full upon default. The mortgagors defaulted on the note in June 1995, the original lender filed for bankruptcy, and the note and mortgage were eventually transferred and assigned to another entity (“bank”) in July 2000. The bank chose not to sue the mortgagors until July 3, 2012, four and a half years after the note matured.

The trial court issued an order foreclosing the mortgage but limited the bank’s recovery to the payments and interest which accrued after July 3, 2006 – six years prior to the date when the mortgagors pursued their claim – based on Indiana’s six-year statute of limitations.The mortgagors appealed.

In its appellate brief, the bank stated that, although it did “not agree with the trial court’s conclusions regarding the impact of the [mortgagors] statute of limitations defense,” it did “not appeal the same.”

The Court of Appeals reversed, finding that “a party is not at liberty to stave off operation of the statute [of limitations] inordinately by failing to make demand.”  Here, because the original lender did not accelerate the note within six years of the mortgagors’ initial default, the Court of Appeals held that the bank waited “an unreasonable amount of time” and could not recover.

On transfer to the Indiana Supreme Court, the mortgagors argued that failing to exercise the acceleration clause within six years of default was unreasonable, and thus the bank’s claim should be time-barred. The mortgagors contended, that when a mortgagee “has the option to accelerate payments but is not required to do so, some reasonableness limitation is necessary to ensure that ‘the creditor is not at liberty to stave off operation of the limitations period inordinately by failing to make demand.’”

The bank countered there are “three possible points in time when the statute of limitations could have been triggered: (1) as each installment payment became due; (2) upon an exercise of the optional acceleration clause, had it chosen to accelerate; or (3) upon loan maturity.” Thus, the bank argued its claim was timely because it was asserted within six years of many of the mortgagors’ missed installment payments and within six years of the note’s maturity date.

The Indiana Supreme Court found that “for purposes of the statute of limitations, closed installment contracts should be treated differently than open accounts” and two statutes of limitations would apply.

Indiana Code section 34-11-2-9 is the general statute of limitations for “action[s] upon promissory notes.” This statute states that such an action “must be commenced within six (6) years after the cause of action accrues.” I.C. § 34-11-2-9.

Additionally, Indiana’s Uniform Commercial Code gives two alternative deadlines for asserting a cause of action upon such a note: “within six (6) years after the due date or dates stated in the note or, if a due date is accelerated, within six (6) years after the accelerated due date.” I.C. 26-1-3.1-118.

The Indiana Supreme Court further noted that “[t]hese statutes’ plain language shows that they are not mutually exclusive when applied to an action on a promissory note.”

The Court concluded “that Indiana’s two applicable statutes of limitations recognize three events triggering the accrual of a cause of action for payment upon a promissory note containing an optional acceleration clause.”

First, “a lender can sue for a missed payment within six years of a borrower’s default.”

Second, “a lender can exercise its option to accelerate and fast-forward to the note’s maturity date, rendering the full balance immediately due. The lender must then bring a cause of action within six years of that acceleration date.”

Third, “a lender can opt not to accelerate and sue for the entire amount owed within six years of the note’s date of maturity.”

The Indiana Supreme Court affirmed the trial court’s order limiting the bank’s recovery to the payments and interest which accrued after July 3, 2006 further explaining that “ordinarily, lenders may recover the entire amount owed on a promissory note by filing suit within six years of the note’s maturity date, if they choose not to exercise the note’s optional acceleration clause.”

However, here, the bank refrained from asking for full relief and the Court declined to grant relief beyond what the bank sought.

6th Circuit Reverses Dismissal of FDCPA Claim of Improper Text Viewable Through Envelope Window

Cagayat v. United Collection Bureau, Inc, No. 19-3431, 2020 U.S. App. LEXIS 7234 (6th Cir. Mar. 9, 2020)

In Cagayat, the consumer allegedly received two collection letters that had a glassine window through which the words “Collection Bureau” were “written on the inward side of the paper page inside the envelopes and allegedly visible through each envelope’s glassine window.” In addition, she alleged that “someone looking at the envelopes in normal lighting can clearly read . . . the message: ‘call our toll-free Consumer Service Hotline at 1-866 . . . Collection Bureau . . . Compliance Department . . . account number on all communications.’”

The consumer sued the collection agency alleging that the collection letters violated the FDCPA and the Ohio Consumer Sales Practices Act (CSPA). The collection agency moved to dismiss. The trial court granted the motion and dismissed both claims with prejudice.

The consumer appealed, arguing that:  (1) the trial court’s “finding that the exhibits contradicted the factual assertions was an improper finding of fact reserved for the jury”; (2) “impermissible language clearly visible from the exterior of an envelope violates 15 U.S.C. § 1692f(8) regardless of its location on the mailing”; and (3) the trial court “improperly applied the ‘least sophisticated consumer’ standard in finding that the contested language cannot be clearly read without unusual strain or effort because the language is upside down and backwards when the envelopes are held right-side up.”

On appeal, the Sixth Circuit agreed with appellant’s argument that the trial court erred in dismissing her complaint based on contradictions between the letters attached to the complaint and its allegations.  The Court explained that “[r]ather than viewing the factual allegations in the complaint in the light most favorable to [plaintiff] and determining whether the evidence presented in the exhibits contradicts those facts, the district court summarily concluded that the contested language was not ‘clearly visible’ and could not be read ‘without unusual strain or effort.’”

The Sixth Circuit disagreed with the trial court’s determination that the least sophisticated consumer could not read the disputed language “without unusual strain or effort because those words are printed on the opposite side of the Letters and are upside-down and backwards.’”  The Court found that “it is reasonable to conclude that discovery will reveal that the Letters, when viewed in normal lighting, display clearly visible language that indicates that the communications pertain to collection of a debt.”

The Court also concluded that the trial court improperly applied the least sophisticated consumer standard in coming to its conclusion, reasoning that a “person handling or viewing one of the Letters could easily rotate the letter to read the words ‘Collection Bureau.’ . . . Thus, the nature of the Letters would be apparent on the face of the envelope to anyone handling the mail.”

Turning to the consumer’s remaining state law claim, the Sixth Circuit held that its FDCPA analysis applied equally to the CSPA claim for the purposes of remand.

Accordingly, the judgment of the trial court was reversed and the case was remanded.

UPCOMING WEBINARS

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CONGRATULATIONS TO OUR NEW AND RENEWED CERTIFIED BUSINESSES, VENDORS, AND INDIVIDUALS!

CRCP – New

Julie Brown – Ceaanate Group
Jacob Corlyon – Capital Collection Management LLC
Tim Elizarraraz – Scott & Associates PC
Rebecca Garland – Verifacts II, LLC
Renee Hulett – Recovery Management Solutions LLC
David Lippman – Lippman Recupero, LLC
Brenda Meli – SAM, Inc.
Frank Moore – SCJ Commercial Financial Services
Scott Ogden – SCJ Commercial Financial Services
Lori Patnode – National Credit Adjusters, LLC
Andrew Roskam – Acctcorp International, Inc.
Loree Rowland – Credit Shop
Sean Williams – Williams Rush & Associates

CRCP – Renew

Celeste Anderson – Equifax, Inc.
David Barrett – Portfolio Investment solutions, LLC
Brian Bowers – Financial Recovery Services, Inc.
J Duke Edwards – J Duke Edwards PC
Tracey Gibson – Unifund CCR, LLC
Bryan Hosto – Converging Capital, LLC
Jake Jones – Resurgent Capital Services
Kevin Luebke – Southern Capital Finance Group, LLC
Anne Thomas – Cavalry Portfolio Services, LLC
Nicole Whitcomb- Gelinas – ABC Legal

CRB – New

Consumer Adjustment Company, Inc.
Kino Financial Co. LLC
Metacorp LLC

CRB – Renewal

Collins Asset Group
Mjollner Group

View all certified businesses and vendors
View all certified individuals

For questions about certification, contact Caitlyn Vaden at (916) 482-2462 or [email protected].

RMAI works hard to open new markets and promote the industry at various conferences and events.

Thank you to our March 2019 – March 12 , 2020 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Financial Recovery Associates, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Titanium $15,000

Platinum $10,000

CKS Financial

Crown Asset Management, LLC

Unifund CCR, LLC

Velocity Portfolio Group, Inc.

Gold $7,500

Second Round, LP

Silver $5,000

Digital Recognition Network

Diverse Funding Associates, LLC

First Financial Portfolio Service, LLC

Garnet Capital Advisors, LLC

Plaza Services, LLC

Bronze $2,500

Absolute Resolutions Corp

Reynolds Sims & Associates, P.C.

Glass Mountain Capital, LLC

International Debt Buying Consultants, LLC

Jefferson Capital Systems, LLC

National Loan Exchange, Inc.

RAzOR Capital, LLC

Security Credit Services, LLC

The Bureaus, Inc.

Brass $1,000

Andreu, Palma, Lavin & Solis, PLLC

Atlas Acquisitions

Balbec Capital, LP

C & E Aquisition Group

Central Portfolio Control, Inc.

Equifax, Inc.

Geist Holdings, Inc.

Indiana Receivables, Inc.

Investment Retrievers, Inc.

Jon Mazzoli

Jormandy, LLC

Kino Financial Co., LLCF

Ontario Systems, LLC

Stenger & Stenger P.C.

The Cadle Company

The Law Offices of Ronald S. Canter, LLC

Tobin & Marohn

TrueAccord

U.S. Equities Corp.

United Holding Group

Verifacts, Inc.

Vertican Technologies, Inc

Other

Accelerated Data Systems

Acctcorp International, Inc.

Actuate Law, LLC

AGORA Data, Inc.

Aldridge Pite Haan, LLP

Alliance Credit Services, Inc.

Arko Consulting LLC

Attunely Inc.

Autovest, LLC

Ballard Spahr LLP

Butler & Associates, P.A.

Capio

Capital Solutions Bancorp, LC

CBE Group, Inc.

CMS Services

Complete Credit Solutions

Comtronic Systems, LLC

Conquest Receivables

Convergence Acquisitions, LLC

Converging Capital, LLC

Convoke, Inc.

Credit Control, LLC

Credit Management Corporation

D & A Services, LLC

David Reid

DebtTrader

Delev & Associates, LLC

Delta Outsource Group, Inc.

Diverse Funding Associates, LLC

DNF Associates LLC

Dynamic Recovery Solutions

Federal Pacific Credit Company

FLOCK Specialty Finance

FMS, Inc.

Fort Crook Financial Co.

Full Circle Financial Services, LLC

Genesis Recovery Services

Halsted Financial Services, LLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Hudson Cook, LLP

Hunt & Henriques

Jan Stieger

Keith D. Weiner & Associates Co., LPA

Kirschenbaum & Phillips, P.C.

Law Office of James R. Vaughan, P.C.

Law Offices of Daniel C. Consuegra, P.L.

Law Offices of Steven Cohen, LLC

Lockhart, Morris & Montgomery, Inc.

London & London

Maurice Wutscher LLP

Mercantile Adjustment Bureau, LLC

Metronome Financial LLC

Midwest Fidelity Services, LLC

Monarch Recovery Management, Inc.

MRS BPO, LLC

Mullooly, Jeffrey, Rooney & Flynn, LP

National Check Resolution, Inc.

National Recovery Associates

National Recovery Solutions, LLC

NCB Management Services, Inc.

NDS, LLC

Palinode, LLC

PCI Group, Inc.

Pharus Funding, LLC

POM Recoveries, Inc.

Portfolio Group Investors, LLC

Poser Investments, Inc.

Premier Forty Financial, LLC

RAS LaVrar LLC

Resource Management Services, Inc

RIP Medical Debt

Riveride Sunnyhood Acquisitions, Inc.

Rocky Mountain Capital Management, LLC

Runci Group

Sandia Resolution Company, LLC

Simmonds & Narita LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stephen L. Bruce & Associates

Superlative RM

Tag Process Service, Inc.

Troutman Sanders LLP

Troy Capital, LLC

Universal Fidelity LP

USI Solutions, Inc.

Vargo & Janson, P.C.

Venable LLP

Viking Client Services, Inc.

VoApps

ZenResolve