RMAI Update July 2026 - Receivables Management Association International

In This Update

Federal policymakers continued to focus on several issues affecting the receivables industry, including federal medical debt legislation, upcoming CFPB leadership changes, artificial intelligence, student loans, and illegal robocalls.

On Capitol Hill, medical debt remains a priority. Multiple bills have been introduced this congress that would prohibit medical debt from appearing on consumer credit reports. Earlier this session, Sen. Jeff Merkley (D-OR) and Sen. John Kennedy (R-LA) each introduced legislation that would prohibit the reporting of medical debt to consumer reporting agencies. More recently, Rep. Rashida Tlaib (D-MI) introduced broader legislation that would also strengthen procedures for blocking fraudulent information from credit reports and preventing the reinsertion of fraudulent tradelines. Although the proposals differ in scope, each would significantly reduce the role of credit reporting as a collection tool for medical debt.

At the Consumer Financial Protection Bureau (CFPB), a federal court has temporarily paused the Bureau’s planned reduction in force until the Senate acts on President Trump’s nomination of Brian Johnson to serve as CFPB Director. The incoming director, pending his Senate approval, is expected to determine the agency’s future staffing and organizational structure. Meanwhile, the CFPB’s latest regulatory agenda identifies two items of particular interest to the receivables industry: a proposed Larger Participant rule expected in September and a UDAAP rulemaking anticipated in November. RMAI previously submitted comment on the Larger Participant proposal. The Bureau also signaled it may revisit its credit card late fee regulation after submitting a request for interagency review, although details have not yet been released.

The Federal Trade Commission (FTC) continues to increase its focus on artificial intelligence. The agency recently issued a proposed policy statement explaining how it intends to apply existing Section 5 authority to AI systems. The proposal centers on the “suppression of accuracy,” warning that companies could face deceptive practices claims if they intentionally alter or steer AI outputs without adequately disclosing those changes. RMAI will continue monitoring these developments, particularly as AI tools become more prevalent in both private industry and government oversight.

The FTC also reported approximately 471,000 debt collection complaints in 2025, more than doubling the previous year’s total. Much of the increase appears to coincide with rising consumer delinquencies and the resumption of collection activity on defaulted federal student loans. As complaint volumes continue to rise, RMAI remains engaged with regulators to promote complaint integrity and ensure policymakers consider the broader economic context when evaluating complaint data.

Separately, House Republicans introduced legislation that would begin transferring responsibility for federal student loan administration from the Department of Education to the Department of the Treasury, starting with defaulted loans. While implementation remains uncertain, the proposal reflects the Trump Administration’s desire to reduce the role of the Department of Education.

Finally, communications policy continues to evolve. A bipartisan coalition of 49 state and territorial attorneys general recently urged the Federal Communications Commission (FCC) to strengthen rules aimed at preventing scammers from obtaining and misusing legitimate telephone numbers for illegal robocalls and text messages. RMAI will continue monitoring the proceeding to help ensure that any new requirements effectively target illegal actors without creating unnecessary burdens for legitimate, highly regulated financial services companies.

RMAI is synonymous with our government advocacy initiatives – it is one of the pillars which our association has been built upon – fighting for the interests of our members. Our association has had an unparalleled level of success in amending and stopping harmful legislation.

A good measure of our success has come from the volunteer efforts of RMAI’s State Legislative Committee and the generosity of our members to the Legislative Fund which helps pay for our lobbying efforts. If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel & Senior Director of Government Affairs David Reid at (916) 779-2492 or [email protected].

Here is a sample of bills we are actively monitoring/lobbying:

Michigan HB 6205 – This bill would codify new exemptions from garnishment, including means-tested public assistance, unemployment compensation, federal and state earned income tax credits, disability benefits, and worker’s disability compensation benefits. The bill also sets the following limits on the amount of wages subject to garnishment: (1) for weekly gross wages up to $1,925, only the lesser of 20% of garnishable earnings or the amount exceeding 30 times the federal minimum wage can be garnished and (2) for wages above $1,925 per week, up to 30% of garnishable earnings may be garnished. [These changes aim to provide clearer protections for certain types of income and set more precise limits on wage garnishment, aligning with efforts to safeguard low-income individuals and those receiving public benefits from excessive debt collection.]

Pennsylvania HB 801 – This bill would enact the Uniform Law Commission’s (ULC) Uniform Consumer Debt Default Judgments Act (UCDDJA), which aims to standardize the process for obtaining default judgments in consumer debt collection cases. It applies to unsecured consumer debts, secured consumer debts when seeking a money judgment, and deficiencies remaining after the disposition of secured property. The act mandates specific requirements for complaints in such cases, including detailed information about the consumer, the debt, and the plaintiff’s authority to collect it. [RMAI spent over three years as an observer on the ULC drafting committee to ensure the uniform act, if adopted by a state, worked for RMAI’s members. A portion of the uniform act was modeled on provisions contained in the RMAI Certification Program. RMAI is in support of its adoption. The UCDDJA has been adopted into law in Virginia and Washington.]

Pennsylvania HB 1731 – This bill would enact the Consumer Debt Collection Fairness Act which would require debt collectors and debt buyers to provide the following documentation in a summons and complaint when initiating legal action: (1) the name of the original creditor; (2) the last four digits of the account number; (3) an itemized statement of the amount owed (including charge-off balance, post-charge-off interest or fees, and payments or credits applied); (4) proof of ownership of the debt (with a chain of title if the debt has been sold); and (5) a copy of the original contract or charge-off statement demonstrating the consumer’s liability. The bill also reduces the statute of limitations from 4 to 3 years. Furthermore, courts are prohibited from entering default judgments in consumer debt cases unless the plaintiff submits an affidavit of facts based on personal knowledge, all required documentation, and proof that the consumer was properly served and notified of their rights. Each lawsuit must also include a separate “Notice of Consumer Rights,” informing the consumer of their right to dispute the debt, request documentation, and seek legal assistance. [RMAI opposes this legislation. RMAI feels that the Uniform Law Commission’s uniform act of default judgments is a much better vehicle for reform. RMAI has retained a lobbyist to advocate our position.]

Litigation Risks: Digital Privacy Claims and Website Accessibility
RMAI members should be aware of litigation risk related to website compliance and digital communications. While this is not a new emerging issue, RMAI continues to receive reports that it remains ongoing. Plaintiffs’ firms continue targeting companies under California’s Invasion of Privacy Act (CIPA), often alleging unlawful website tracking, chat features, session replay technology, or data-sharing practices. In addition, businesses across industries are facing lawsuits alleging websites are not accessible to individuals with disabilities under the Americans with Disabilities Act (ADA). Members should consider reviewing their website practices, vendor technologies, privacy disclosures, consent mechanisms, and accessibility standards with legal counsel and appropriate technology professionals to help mitigate potential exposure.

For more information:
California’s Invasion of Privacy Act: A New Frontier for Website Tracking Litigation
ADA Website Accessibility Lawsuits: How to Protect Your Business

California Court of Appeal Holds Concrete Injury Unnecessary for FCRA Willful Violation Claims
Askins v. CRST Expedited, Inc., 120 Cal. App. 5th 1190 (2026)

A consumer filed a lawsuit against a company alleging violations of the Fair Credit Reporting Act (“FCRA”) due to the company’s failure to provide legally compliant disclosure and authorization forms before conducting background checks on job applicants. The consumer claimed the forms were not clear standalone disclosures, and were lengthy, confusing, and contained extraneous information.

The consumer moved for class certification, which was granted, but later decertified after the California Court of Appeal, Fifth District’s decision in Limon v. Circle K Stores Inc., 84 Cal. App. 5th 671, 300 Cal. Rptr. 3d 572 (2022). Limon held that an FCRA plaintiff in California must show a concrete injury, not merely a statutory or informational violation. Relying on Limon, the trial court concluded the consumer’s alleged confusion and lack of knowledge were insufficient because they were merely “informational” harms. The consumer appealed.

On appeal, the California Court of Appeal, First District, explained that the California standing doctrine differs from federal Article III standing. Federal courts require injury in fact, causation, and redressability, but California courts are not bound by Article III, even when adjudicating federal statutory claims. In California, standing for statutory causes of action is primarily a matter of statutory interpretation in which courts ask whether the statute grants the plaintiff a sufficient interest to sue. The Court framed the dispositive issue as whether the FCRA itself requires proof of actual injury for a willful violation claim seeking statutory damages.

The Court concluded that the FCRA’s text and history show that it does not. 15 U.S.C. § 1681n allows a consumer to recover either actual damages or statutory damages of $100 to $1,000 for willful noncompliance, along with possible punitive damages, costs, and attorney’s fees. The Court interpreted Congress’s use of the disjunctive “or” as an indication actual damages and statutory damages are separate remedies. The Court believed that requiring proof of actual injury for statutory damages would erase the distinction Congress created.

The Court also relied heavily on the statutory language and historical context. It observed that when Congress amended the FCRA in 1996, it added the statutory damages remedy as part of provisions titled “Minimum Civil Liability for Willful Noncompliance.” The court reasoned that this reflected an intent to impose a minimum level of liability for willful violations, including cases where actual damages cannot be proved. It contrasted this with negligent FCRA violations, for which the statute permits only actual damages. That difference reinforced the conclusion that Congress intentionally made statutory damages available for willful violations without requiring proof of actual injury.

Finally, the court also tied the standing analysis to the substantive purposes of the FCRA. It identified the FCRA’s relevant purposes as ensuring accurate consumer reporting, promoting error correction, and protecting privacy. A deficient disclosure before an employment background check interferes with those interests because the consumer is not placed in a position to understand the report process, object to it, decline it, or take steps to verify or correct information. Even if the resulting report contains no inaccuracies, the Court held that failure to provide the required disclosure deprives the consumer of the procedural and privacy protections Congress enacted.

Though not deciding whether the consumer was an appropriate class representative, the Court reversed the decision of the trial court decertifying the class.

RMAI’s Legislative Fund Supports Another Successful Year for State Lobbyists
2026 has been an amazing year for our state lobbyists. Thanks to your generous donations, RMAI had successes in Colorado, Indiana, and Illinois with legislation pertaining to medical debt, as well as success in New York and Vermont with legislation regarding coerced debt. We look forward to continuing our efforts state-to-state next year, advocating for you and your businesses. You can donate now to the Legislative Fund to lay the foundation of another successful year of state and federal advocacy!

If you would like to contribute to the Legislative Fund and be featured on our website, you can donate here. You can view a list of current Legislative Fund donors here.

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.

Upcoming Webinar
Register for our September 15^th, UDAAP by Analogy: Using Other Federal and State Statutes to Define and Enforce UDAAPs webinar. Our presenters Stefanie Jackman with Troutman Pepper Locke, Jo Ann Needleman with Clark Hill, and Manny Newburger with Barron & Newburger, P.C. will provide an in-depth examination of UDAAP, exploring how both federal and state laws define unfair, deceptive, and misleading practices. We’ll also examine statutes such as FDCPA Section 15 U.S.C. § 1692d, which state regulators frequently rely on when pursuing state-level UDAAP actions—even against businesses that may not traditionally fall within the statute’s scope.

Recorded Webinars

Recorded on June 25, 2026 you can register for What’s New from Recent Uniform Default Judgment Legislation. Our presenters, Rebekah Henderson with Velocity Portfolio Group, Chris Mandarich with Mandarich Law Group LLP, and Brit Suttell with Barron & Newburger, P.C. explored both the substance of recent legislation, as well as other state procedures to also protect the consumer from defaults through mediation, remote hearings and more.

Recorded on July 14, 2026 you can register for Semantics Matter: How Terminology can Avoid or Create Compliance Risks. Our presenters, John Bedard with Bedard Law Group, P.C., and Chuck Dodge with Hudson Cook, LLP discussed this important topic for debt buying and collections businesses.

Click here for more information on our live and recorded educational webinars. Contact Shannon Parod-Tsui at [email protected] to find out more about sponsoring an RMAI webinar.

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

CRCP New
Don DiGiacomo, Landmark Strategy Group
Daniel Frisicaro, American Coradius International
Jessica Hill, Troy Capital
Scott Morris, Tromberg, Miller, Morris & Partners
Julio Pautt, RevNow
Joshua Wade, Southwood Financial

CRCP Renewals
Nicole Green, Cascade Receivables Management
Doug Handschumacher, Crown Asset Management
Andrew Roskam, Orbita Capital

CRB New
Alliant Capital Management
Intercap Services
RevNow
Unifin

View all certified businesses and vendors.
View all certified individuals.

Resources for Individual and Business or Vendor Certification
RMAI has developed certification resources for our members who are going through the individual or business/vendor certification and aren’t sure where to start or aren’t sure how long the process takes. These easy to follow resources will help you feel less intimidated and more confident in how to obtain certification at any level.

Individual Certification

Business/Vendor Certification

View our full list of certification resources.

There’s Still Time to Register for Executive Summit
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 still open for the Executive Summit, taking place at the Skamania Lodge in Stevenson, WA, August 4-6th. Connect with industry colleagues during our education sessions while you enjoy the picturesque New England countryside. Sponsorship is available too! Register and find out more.

Send Us Your Press Releases and Boost Your Reach with a Sponsored Social Media Post
We want to share your news! Make sure RMAI is on your press release distribution list. As a benefit of membership, RMAI posts members’ press releases to Member News on the RMAI website. As another benefit of membership, RMAI members can purchase sponsored social media posts ($200 each). To get in front of RMAI’s audience, contact Communications & Administrative Coordinator, Aurora Sain at [email protected].

Help RMAI Grow
Membership dues are 50% off during the third quarter of 2026. Do you know a company that would make a great RMAI member? Offer to be one of their references and refer them to the online membership application. Now is a great time to join RMAI!

For a complete list of RMAI members (including contact information), login to check out the Member Directory.

2026 RMAI Executive Summit | August 4-6, 2026

2027 Annual Conference | February 8-11, 2027

DIAMOND ($50,000+)

Crown Asset Management, LLC

PRA Group, Inc.

Resurgent Holdings, LLC

Velocity Portfolio Group, Inc.

TITANIUM ($25,000+)

Absolute Resolutions Corp.

Cavalry Portfolio Services, LLC

Midland Credit Management

Second Round, LP

PLATINUM ($10,000+)

Garnet Capital Advisors, LLC

Halsted Financial Services, LLC

Pharus Funding, LLC

Plaza Services

Stenger & Stenger P.C.

T & I Enterprises, LLC

TrueAccord

GOLD ($5,000+)

InvestiNet, LLC

Jefferson Capital Systems, LLC

National Credit Adjusters, LLC

Security Credit Services, LLC

Velo Law Office

SILVER ($2,500+)

Central Portfolio Control, Inc

Mountain Peak Law Group, PC

Troy Capital, LLC

CONTRIBUTORS

Advancial Federal Credit Union

Aldridge Pite Haan, LLP

American Coradius International LLC

Andreu, Palma, Lavin & Solis, PLLC

Arko Consulting LLC

ARM Compliance Business Solutions LLC

ARS National Services, Inc.

Balbec Capital

Bankrupt Debt Services

Basham & Scott, LLC

Bread Financial

Buffaloe & Vallejo, PLC

Call Center Services International

CASA Receivables Management, LLC

Cascade365 Family of Companies

CBE Companies

CNG/Axcess Financial Services, Inc.

Cohen & Cohen Law, LLC

Collection Attorneys USA LLC

CompuMail Information Systems

Connect International

ConServe

Consuegra & Duffy, PLLC

Converging Capital, LLC

Convoke, Inc.

Cornerstone Licensing Services

Cozen O’Connor

Credit Brokers LLC

Credit Control, LLC

Credit Management Corporation

D & A Services, LLC

D1AL

David Reid

Debt Sales Partners

Exelero Corp.

FDR Alliance LLC

Financial Recovery Services, Inc.

First National Collection Bureau

Floatbot, Inc

FLOCK Specialty Finance

FMA Alliance, Ltd

FMS, Inc.

ForgiveCo PBC Inc

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Grassy Sprain Group, Inc

Guglielmo & Associates, PLLC

Healthcare Finance Direct, LLC

Hilco Receivables, LLC

Indiana Receivables, Inc.

Invenio Financial, a Phillips & Cohen Associates company

Kino Financial Co., LLC

Klima, Peters & Daly, P.A.

Kompato AI Inc.

Landmark Strategy Group, LLC

Latitude Software

LexisNexis Risk Solutions

Mandarich Law Group LLP

Markoff Law LLC

National Enterprise Systems, Inc.

National Loan Exchange, Inc.

National Recovery Associates, Inc.

National Recovery Solutions, LLC

NCB Management Services, Inc.

NICE

Nutun CX (PTY) LTD

Nuvei Technologies Inc.

Orbita Capital Group, LLC

Overtime.ai

PCI Group Inc.

Phin Solutions, LLC

Poser Investments, Inc.

Premier Bankcard

Premium Asset Recovery Corp (PARC)

Primeritus Financial Services, Inc.

Pro Forma Inc

Quality Acceptance

Rausch Sturm, LLP

RevSpring

Risk Strategies

Robinson Hoover & Fudge, PLLC

Roosen, Varchetti & Olivier, PLLC

Rossman Kirk, PLLC

SAM – Solutions for Account Management, Inc.

SCJ Commercial Financial Services

Scott & Associates, PC

Shepherd Outsourcing, LLC

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solvo Solutions, LLC

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Suttell & Hammer

The Cadle Company

The Forwarders List of Attorneys

The Law Offices of Ronald S. Canter, LLC

The Moore Law Group

The Oakes Law Firm, LLC

Tobin & Marohn

Troutman Pepper Locke

Vargo & Janson, P.C.

VeriFacts, LLC.

Womble Bond Dickinson

World Credit Recovery LLC

Yrefy, LLC