RMAI Update August 2023

Congress
Congress is now on recess for the month of August. The House returns September 12; the Senate returns September 5. Upon their return from recess, Congress will have limited time before the end of the fiscal year to focus on key priorities including: FY2024 federal funding bills (or a continuing resolution to keep the government funded beyond September 30th if a deal isn’t reached); the FY2024 National Defense Authorization Act (NDAA); and the FAA reauthorization bill. Following these urgent priorities, Congress will likely shift to other key priorities, though it remains unclear how much legislative time and bipartisan appetite there will be to actually advance them. Such priorities in the House and/or Senate include:

• Oversight and Investigations;
• 2023 Farm Bill;
• Permitting reform;
• Online safety;
• Holding bank executives accountable;
• Cannabis banking;
• CFPB reform;
• ESG;
• Addressing American competitiveness with respect to China;
• Lowering the cost of insulin and prescription drugs;
• Combatting the fentanyl crisis;
• Promoting community health;
• Addressing rail safety;
• Artificial Intelligence (AI) innovation and regulation; and,
• Advancing judicial nominations

At the end of July, Senators Chris Murphy (D-CT) and Mike Braun (R-IN), both of whom sit on the Senate HELP Committee, introduced the Strengthening Consumer Protections and Medical Debt Transparency Act. According to their press release, the bill would require that:

• “HHS creates a publicly available database of annual reporting from hospitals, freestanding facilities, and large provider practices with information about whether they use collection agents, the process for assigning debt to a collection agent, and the number of Extraordinary Collection Actions, as defined by the IRS, they have initiated. HHS will maintain a public list of any health care entity that does not submit the required information each year.
• Before an entity can send debt into collections, health care entities should ensure that all insurance coverage appeals have been resolved and determine whether the patient qualifies for assistance.
• Health care entities, or their contracted debt collection agencies, shall not enter into extraordinary collection until 180 days after an initial bill is sent and the debtor’s identity has been confirmed.
• Health care entities provide the patient with an itemized statement of the debt owed as well as detailed receipts of payments made within 30 days.
• A health care entity or its agent who fail to comply with changes under the Act is liable to the patient for actual damages and up to $1,000. In the case of a class action suit, damages are the amount each plaintiff could have recovered, not to exceed $2 million. If the patient is successful, then attorney’s fees and other costs also can be recovered.
• The Consumer Financial Protection Bureau (CFPB) issue a biennial report on medical debt and review the public database for its application to the CFPB’s risk supervision program.”

Because the bill was introduced with bipartisan support, particularly by members who tend to cross the aisle relatively frequently to work on bipartisan legislation, it is possible that this legislation could gain traction in Congress this fall. Moreover, medical debt has tended to be an issue with general bipartisan support, and has remained on the radar of both the Senate HELP and Senate Banking Committees, as well as their House Committee counterparts, during the 117th and 118th Congresses. However, Congress has an extensive legislative agenda awaiting their return in September with more pressing priorities. As such, it remains unclear at this point if there will be sufficient time and appetite to move this bill on its own, though it is possible that it could be swept into a broader package near the end of the year if one comes to fruition. We expect to know more in the coming weeks upon Congress’ return from recess. More information is available in the full text of the bill here, and a one-pager here.

Administration
On July 26, the CFPB issued a new Supervisory Highlights, which found unfair, deceptive, and abusive acts or practices across many consumer financial products between July 2022 and March 2023. In the press release, Director Chopra noted, “The CFPB is also inspecting more financial data brokers engaged in consumer reporting, as well as nonbank entities using authorities that previously went unused.” The report highlights:

• Shifts in car pricing leading to more delinquencies in auto lending;
• Unlawful debt collection attempts including on medical debt; and
• Illegal payday lender collection practices;

More information is available in the press release here and the Supervisory Highlights here.

On July 20, the CFPB published a report highlighting risks that employer-driven debt poses to employees. After a review of responses to the CFPB’s public inquiry launched in June 2022, the analysis describes the growing prevalence of employer-driven debt and challenges workers and consumers face when they become indebted to an employer or an employer’s affiliate as a condition of employment. Other risks identified in the report include:

• Workers are rushed through the loan sign-up process;
• Employers use bait-and-switch fine print;
• Employer-driven debt puts up barriers to career advancement and higher wages.

More information is available in the press release here and the issue spotlight report here.

On July 7, the CFPB, Department of Health and Human Services (HHS), and Treasury Department launched a joint inquiry into high-cost specialty financial products, such as medical credit cards and installment loans, being pushed on patients to pay for routine medical care. According to their press release, “The three agencies seek information about the prevalence of these products, patients’ experiences with them, and health care providers’ incentives to offer these high-cost products to patients, which may include avoiding the insurance claims process and financial assistance programs.” Public comments are due by September 11. The full RFI is available here.  RMAI is in the process of drafting comments now.

On June 20, the FTC and Department of Health and Human Services’ Office for Civil Rights issued a joint letter to approximately 130 hospital systems and telehealth providers to alert them of the data privacy risks of online technologies that may share a user’s sensitive health information. More information and the copies of the letters are available here.

Other Updates of Interest
On July 31, several trade associations, including the American Bankers Association, American Financial Services Association, Mortgage Bankers Association, National Association of Federally-Insured Credit Unions, National Council of Higher Education Resources, and Student Loan Servicing Alliance, submitted a joint comment on the FCC’s recent Notice of Proposed Rulemaking (NPRM) on robocalls and robotexts. According to their press release, “the trades highlighted the legal standard of ‘any reasonable means’ to revoke consent is difficult to interpret for callers and encourages legal action. Instead, the trades urged the FCC to express that ‘a business and its customer may contractually agree to specific and reasonable methods by which the customer may revoke consent to receive autodialed or prerecorded calls or text messages.’ Additionally, the groups argued that revocation of consent should only apply to the type of information in the original text or call.” More information is available in the full text of the comment letter here.

In June, it was announced that oral arguments for the CFSA v. CFPB Supreme Court case would be scheduled to be heard on October 3, 2023. As such, the final decision for this case is unlikely to be released until potentially December 2023 (at the earliest), or more likely in June 2024. More information on the case status is available here.

Looking ahead to the Fall, RMAI leadership will return to Washington DC to meet with key members of the House Financial Services Committee and the Senate Banking Committee to provide an update on the industry, and to focus their attention on how the RMAI Receivables Management Certification Program sets industry best practices through comprehensive standards to ensure consumers are protected during the professional and ethical collection of legitimate financial obligations (debt).

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. If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel David Reid at (916) 779-2492 or dreid@rmaintl.org. The following bills of concern are a sample of the legislation that RMAI is currently engaging on behalf of the industry:

California AB 1414 – This bill would exclude consumer credit accounts from the definition of “common counts” which would force all litigation through a contract theory for litigation. [RMAI and an industry coalition are in opposition to the bill.]

Massachusetts SB 629 – 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, 2024. [RMAI has been opposing this bill since 2014 when it was first introduced. After eight years of negotiations and countless amendments, RMAI and the consumer advocates agreed to amendments that will remove RMAI’s opposition to the bill once the bill is amended. 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.]

Michigan SB 408 – This bill would among other things: (1) increase the garnishment exemption from 30x federal minimum wage to 80x state minimum wage; (2) limit garnishment to 10% of earnings in excess of the garnishment exemption and then 15% of any earnings over $1,200; (3) create a wild card exemption up to $17,000; (4) eliminate all tax garnishments for judgments obtained pursuant to a “consumer debt”; and (5) increase the homestead exemptions from $35,000 to $250,000 ($350,000 for seniors and those with disabilities); and (6) increase various property exemptions including for automobiles, household goods, tools of the trade, agricultural, etc. [RMAI is developing a coalition to vigorously oppose this bill. RMAI has retained a state lobbyist.]

Ninth Circuit Holds Text Messages Are Not Analogous to Prerecorded Voice Messages
Trim v. Reward Zone USA LLC, No. 22-55517, 2023 U.S. App. LEXIS 20445 (9th Cir. Aug. 8, 2023)

A consumer alleged she received at least three text messages on her cell phone from a company to which she had never provided consent.  She filed suit against the company alleging that the “that the text messages constituted ‘prerecorded voice messages,’” and therefore violated the Telephone Consumer Protection Act (TCPA) which, in part, prohibits making a call to a cell phone using an artificial or prerecorded voice without consent. 47 U.S.C. § 227(b)(1)(A).

The trial court held that “the text messages did not use voices and therefore did not violate the applicable section of the statute,” dismissed the cause with prejudice, and the consumer appealed.

The U.S. Court of Appeals for the Ninth Circuit began by determining “whether congressional intent regarding the definition of ‘voice’ is clear because when the meaning of a statute is clear, the ‘sole function of the courts’ is to “enforce [the statute] according to its terms.”

In this case, the court held “that Congress clearly intended “voice” in 47 U.S.C. § 227(b)(1)(A) to encompass only audible sounds, because the ordinary meaning of voice and the statutory context of the TCPA establish that voice refers to an audible sound.”

Therefore, the Court affirmed the decision of the trial court.

Seventh Circuit Upholds Agency’s Bona Fide Error Defense
Ross v. Fin. Asset Mgmt. Sys., Inc., No. 22-1272, 2023 U.S. App. LEXIS 17924 (7th Cir. July 14, 2023)

A consumer defaulted on a debt and received a letter from a collection agency.  The letter: 1) informed the consumer of the right to dispute the debt; and 2) identified an address and website where consumers could direct disputes.

Instead of following the dispute instructions, the consumer creatively tracked down the email addresses of the agency’s CEO and its VP of Operations and sent his dispute to them knowing their roles were “unrelated to the day-to-day responsibilities of consumer dispute communications.”  Although the agency trained its corporate officers how to forward such disputes to the customer service department, the consumer’s disputes were not forwarded for reasons unknown.

While this was occurring, a collector from the agency called the consumer’s wife several times and asked if she would pass a message on to her husband.  The wife was not responsible for the debt, and despite training and appropriate collection software, the collector failed to code the wife’s telephone number as that of a third party.

The wife sued the collection agency alleging the calls violated the Fair Debt Collection Practices Act (FDCPA).  Specifically, she alleged the agency violated 15 U.S.C. § 1692g(b) “by continuing debt collection activities after [the consumer] disputed the debt and without first providing verification of the debt.”  She also alleged violations of § 1692d and 1692d(5) because: “(1) [the agency] continued to call [her] after [the consumer] disputed the debt, (2) [the agency continued to call [her] after she notified [the agency] that [the consumer] does not use her phone, and (3) [the agency] disconnected calls with [her] after she answered.

The trial court granted the agency’s motion for summary judgment, concluding: 1) that the wife was not a “consumer” under the FDCPA and therefore could not bring a claim; 2) no reasonable jury could find violations of § 1692d and  §1692d(5); and 3) even if a jury could find violations, the agency was entitled to a bona fide error defense.  The wife appealed.

The U.S. Court of Appeals for the Seventh Circuit, for the sake of efficiency, assumed without deciding that the wife could potentially have a private right of action.  With that out of the way, the Court explained that “the bona fide error defense requires a debt collector to show that (1) the violation was not intentional, (2) the violation resulted from a bona fide error, and (3) the debt collector maintained procedures reasonably adapted to avoid any such error.”

Procedurally, the wife waived consideration of the first two elements.  Regarding the third, the Court described in detail the training and the many procedures and safeguards the agency had in place to prevent the alleged violations.  Thus, the court found that the agency’s bona fide error defense precluded liability and reiterated that “if [the agency’s] procedures had been followed, [the wife’s] number would have been immediately placed on a do-not-call list, and [the wife] would not have continued to receive calls. That is all the third element requires of debt collectors.”

Therefore, the Court affirmed the decision of the trial court.

Ninth Circuit Holds Cell Phone Subscriber Has Article III Standing in TCPA Case Even Though Not the Primary User
Hall v. Smosh Dot Com, Inc., 72 F.4th 983 (9th Cir. 2023)

A consumer provided a cell phone to her son after placing it on the National Do-Not-Call Registry, which she stated was done “to obtain solitude from invasive and irritating solicitation calls and to protect her minor son from being inundated with advertisers and data miners.”

Thereafter, a company sent five allegedly unsolicited marketing text messages to that cell phone.  The consumer then filed suit against the company claiming a violation of the Telephone Consumer Protection Act, specifically 47 U.S.C. §227(c).

The trial court dismissed the matter “for lack of Article III standing, reasoning that [the consumer] failed to allege she was the ‘actual user’ of the phone or the ‘actual recipient’ of the five text messages at issue.”

The U.S. Court of Appeals for the Ninth Circuit summarized the issue as “whether the owner and subscriber of a phone with a number listed on the Do-Not-Call Registry, who may not be the phone’s primary user, suffers an injury in fact when the phone receives unsolicited text messages.”

The Court noted that it had “previously held that the receipt of unsolicited telemarketing phone calls or text messages in violation of the TCPA is a concrete injury in fact sufficient to confer Article III standing,”  and that  “the TCPA establishes the substantive right to be free from certain types of phone calls and texts absent consumer consent.”

The Court noted that the receipt of text messages did result in a cognizable injury, but acknowledged that “the party seeking review be himself among the injured.”  Nevertheless, the court explained that “nothing in our precedent or the text of the TCPA suggests that the owner of a cell phone must also be the phone’s primary or customary user to be injured by unsolicited phone calls or text messages sent to its number in violation of the TCPA.”

The court concluded that “the fact that the primary or customary user of a phone may suffer a concrete injury from an unwanted call or text message does not preclude the phone’s owner and subscriber from suffering the same.”

Therefore, the Court reversed the dismissal of the complaint for lack of standing and remanded the matter for further proceedings consistent with its opinion.

Thank You to our Executive Summit Silent Auction Donors and Winners!
Thank you to all of our 2023 Executive Summit Silent Auction donors and bidders, and our attendees who won the donated items. Proceeds from the Silent Auction directly benefit RMAI’s Legislative Fund. This year, the Executive Summit Silent Auction brought in $11,460!

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. Click here to see a list of current contributors on the right-side bar.

Annual Conference Proposal Selection
RMAI’s annual Call for Proposals deadline was Monday, August 7th, and we are no longer accepting proposals. Our Conference and Education committees will be reviewing the 2024 Annual Conference proposals in the next month and will notify the contact person on the proposal whether they were selected or not selected.

Selection Process 
Presentation selection is determined on a variety of considerations including but not limited to:

• Appropriateness/relevance of and interest in topic
• Expertise of presenter(s)/author(s)
• RMAI membership status
• RMAI Receivables Management Certification Program status
• Completeness of proposal, including all confirmed presenter(s)/author(s)
• New/next generation speakers

RMAI reserves the right to make recommendations for content revisions and presenter/author changes prior to selection. Participation as a presenter/author is by invitation only.

Upcoming Webinars – Complimentary Registration for RMAI Members
Register now for our August 16th webinar, Bridging the Gaps Between Operations, IT and Compliance where our presenters will delve into equipping attendees with the knowledge and skills needed to optimize operational efficiency, harnessing technological advancements, and navigating complex regulatory environments.

Register now for our August 30th webinar, Around the Safeguards Rule in Eighty Days, where our presenters will address the main points of the Rule, share the recent RMAI survey results on any obstacles that your organization may be facing, and provide insights addressing matters raised in the survey responses.

Register now for our September 6th webinar, What Drives the Auto Finance Asset Class, where our presenters from the Auto Finance Working Group will update attendees on the auto finance asset market and preview the soon-to-be-released primer paper covering such topics as data and documentation, chain of title, and best practices. They’ll also share their expertise for how best to break into (or stay in) the auto deficiency market.

Recorded Webinars
If you missed our July 26th on strategies to enhance client/creditor collaboration and opportunities, you can register for the recordings on our Online Education webpage which will be available for one (1) year.

Click here for more information on our live and recorded educational webinars.

Congratulations to our new and renewed Certified Receivables Compliance Professionals (CRCP) and renewed Certified Receivables Business (CRB).

CRCP New
Alicia McKeighan, ConServe
Robert Salmon, George Brown Associates

CRCP Renewals
Donna Boyd, First Financial Portfolio Services
Svetlana Daily, Resurgence Capital Group
Michael Kane, Unifund
Mellisa Massey, National Credit Adjusters
Jim Mastriani, Velocity Portfolio Group
Shannon Parod, RMAI
Rajeesh Ramakrishnan, First Credit Services
David Reid, RMAI
Stacy Stein, Mountain Peak Law Group
Carole Wiegel, The Bureaus Inc.

CRB Renewal
Recovery Management Solutions

Turn In Credit Forms and Submit Your Application for New or Renewal Certification
If you just came back from the Executive Summit in Monterey, CA and earned credits towards individual certification, now is the time to complete any remaining credits you may need. Remember, complimentary registration to live and recorded educational webinars is a benefit of RMAI membership. Or, if you have now completed all of your education credits, you can submit your Certified Receivables Compliance Professional application now, and we will review it at our next monthly meeting. Meetings take place once a month on the last Thursday of each month.

View all certified businesses and vendors.
View all certified individuals.
View educational requirements for certified individuals.

For questions about certification, contact RMAI at (916) 482-2462 or email cert@rmaintl.org.

RMAI Membership Approved Bylaws Changes
On July 21, 2023, the RMAI Membership approved several changes to the RMAI Bylaws, including:

1. Current associate debt buyer members will be required to become certified by January 1, 2025, to maintain their membership. If you are a current associate debt buyer, there is an advantage to getting certified prior to March 1, 2024, as on that date, the Receivables Management Certification Program will require a pre-certification audit as a condition to certification. RMAI staff can assist you with any questions concerning certification. Please contact Shannon Parod, Director of Certification and Education, at (916) 482-2462 or sparod@rmaintl.org.
2. A second dedicated seat on the RMAI Board of Directors for non-debt buying businesses has been established. With this change, one director seat will be dedicated to a Certified Collection Agency and one director seat to a Certified Collection Law Firm. Prior to this change, the RMAI Board of Directors had only one dedicated director seat for a Certified Collection Agency or a Certified Law Firm.

2024 Annual Conference DEI Scholarship
The Diversity Equity Inclusion (DEI) Annual Conference Scholarship is open to all receivables management professionals employed by Certified Receivables Business and Certified Receivables Vendor members, who have never attended an in-person RMAI event (i.e., Annual Conference, Executive Summit, or Fall Networking) and are viewed as emerging leaders in their organization. DEI Annual Conference Scholarship sponsorships fund the scholarship.

Click here for more information including the required forms to apply and how to sponsor. Applications must be submitted on or before October 13, 2023.

Register for Fall Networking & Baseball
Remember, one of the most valuable and popular benefits of your RMAI membership is attending our events at a discounted member registration rate. Registration is open now for Fall Networking & Baseball, taking place in Denver, CO, on Monday, September 11! Connect with industry colleagues during the no-host lunch and pre-game reception, and while you take in a Chicago Cubs vs. Colorado Rockies baseball game. The fan atmosphere makes renewing and building connections easy and enjoyable. Sponsorships are available too! Register and find out more.

RMAI’s leadership cultivates relationships within the receivables management industry to expand business opportunities for members.

2023 Fall Networking & Baseball | September 11, 2023
RMAI Member Orientation Session via Zoom | September 13, 2023
2024 RMAI Annual Conference | February 5-8, 2024

Thank you to our August 1, 2022 through August 9, 2023 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

TRAKAmerica

Velocity Portfolio Group, Inc.

Platinum $10,000

Blitt and Gaines, P.C.

EverChain

Garnet Capital Advisors, LLC

InvestiNet, LLC

Provana, LLC

Second Round, LP

T & I Enterprises, LLC

Unifund CCR LLC

Gold $7,500

Pressler, Felt and Warshaw, LLP

Rausch Sturm, LLP

Silver $5,000

Andreu, Palma, Lavin & Solis,  PLLC

Corporate Advisory Solutions, LLC

Digital Recognition Network

FMA Alliance, Ltd

Klima, Peters & Daly, P.A.

National Loan Exchange, Inc.

Pharus Funding, LLC

Spring Oaks Capital, LLC

Velo Law Office

Bronze $2,500

Absolute Resolutions Corp.

Acctcorp International, Inc.

Actuate Law, LLC

Aldridge Pite Haan, LLP

Central Portfolio Control, Inc

DebtNext Software, LLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Invenio Financial, a Phillips & Cohen Associates company

January Technologies, Inc.

Kredit Financial Inc.

Premier Forty Financial, LLC

Quantum3 Group, LLC

RAzOR Capital, LLC

Resurgence Capital, LLC

Suttell & Hammer

Tobin & Marohn

Troutman Pepper

TrueAccord

Venable LLP

Brass $1,000

Action Collection Agencies, Inc.

Advancial Federal Credit Union

AKCP LLC

Arbeit

Arko Consulting LLC

Balbec Capital

Barron & Newburger, P.C.

Beam Software

Bread Financial

Butler & Associates, P.A.

C&R Software

Call Center Services International

Capio

Cascade365 Family of Companies

CBK, Inc.

CCMR3

Cedar Holdings International Inc. DBA Cedar Financial

Commercial Credit Group Inc.

Commercial Funding Inc.

Convergence Acquisitions, LLC

Cornerstone Support, LLC

CSS Impact

Dobberstein Law Firm, LLC

Epicenter Technologies Pvt. Ltd.

First Financial Portfolio Services, LLC dba FFAM360 Capital

FLOCK Specialty Finance

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Guglielmo & Associates, PLLC

Halsted Financial Services, LLC

Hunt & Henriques, LLP

Huntington Debt Holding LLC

International Debt Buying Consultants, LLC

Investment Retrievers, Inc.

Jefferson Capital Systems, LLC

Kota Business Solutions LLC

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Mandarich Law Group LLP

Markoff Law LLC

Metacorp, LLC

Mountain Peak Law Group, PC

National Debt Holdings, LLC

Nelson & Kennard

NRA Group, LLC

Nuvei

PCI Group Inc.

Phin Solutions, LLC

Portnoy Schneck, LLC

Quall Cardot, LLP

RevSpring

Robinson Hoover & Fudge, PLLC

Scott & Associates, PC

Sequium Asset Solutions, LLC

SimpleCertifiedMail.com

Skit.ai

Slovin & Associates

Stenger & Stenger P.C.

Stone, Higgs & Drexler

The Cadle Company

US Mortgage Resolution, LLC

USASF Servicing, LLC

VeriFacts, LLC.

Vertican Technologies, Inc.

VoApps, Inc.

Other

Alliance Credit Services, Inc.

ARM Compliance Business Solutions LLC

Atlas Acquisitions

Bedard Law Group, P.C.

CMS Services

Coastal Law Firm, APLC

Converging Capital, LLC

Convoke, Inc.

Credit Corp Solutions Inc.

Credit Management Corporation

D1AL

InDebted

Kino Financial Co., LLC

Kirschenbaum & Phillips, P.C.

Law Offices of Steven Cohen LLC

London & London

Martin Lyons Watts Morgan PLLC

MauriceWutscher LLP

Miller and Steeno, P.C.

Moss & Barnett, P.A.

National Recovery Solutions, LLC

POM Recoveries, Inc.

Poser Investments, Inc.

ProVest LLC

Receivables Management Association International

Resource Management Services, Inc.

SAM – Solutions for Account Management

Sandia Resolution Company, LLC

SCJ Commercial Financial Services

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stone Creek Financial Inc.

The Oakes Law Firm, LLC

Troy Capital, LLC

United Acquisitions, LLC

Vargo & Janson, P.C.

Venandi Systems, LLC

WebRecon LLC

Womble Bond Dickinson