RMAI Update June 2023

Just in the nick of time, Congress passed, and the President signed the Fiscal Responsibility Act of 2023 (the debt ceiling legislation).  Impacting the industry was the inclusion of language that prohibits the Department of Education from extending the suspension of payments on federal student loans beyond sixty days after June 30, 2023. Accrual of interest and collections will also resume at that time. Democrats on Capitol Hill have been very vocal via Amicus Briefs and various speeches defending the CFPB funding structure. It is anticipated that the Supreme Court will hear oral arguments in the Fall of 2023, with a decision sometime in the Spring of 2024.

On June 13th and 14th, CFPB Director Rohit Chopra appeared before the Senate Banking Committee and House Financial Services Committee, respectively, for his semi-annual report to Congress.  With the House controlled by the Republicans and the Senate by the Democrats, the hearings took on a very different tone in each committee.

On the regulatory front, on June 1, the CFPB issued a Notice on Advisory Committees Solicitation of Applications for Membership. Applications will be accepted from July 3 – July 16. RMAI encourages any interested member to apply for the Consumer Advisory Committee. It has been a long time since industry has been represented on the advisory committee.

RMAI volunteers are meeting regularly to draft Comments to the CFPB’s proposed policy to define “Abusive” in UDAAP. Comments are due the beginning of July.

Not a week goes by that we are not reading a release from the CFPB, FTC or other regulators on new policy, guidance, or enforcement actions that inform the industry on how to operate their businesses. Compliance with this myriad of recommendations/propositions requires constant vigilance.  RMAI will continue to endeavor to provide meaningful interpretations to our members via Member Alerts, webinars and live programming.  Please be sure your compliance personnel are utilizing RMAI as a resource.

We are at that time of year where the number of states that are in session are far outnumbered by the states that have adjourned. Presently, there are 14 states in session and by the end of the month that number will stand at 10 states (although some of those states are unofficially adjourned).

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 [email protected]. 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 “book account” which would force all litigation through a contract theory for litigation. [RMAI and an industry coalition are in opposition to the bill and have suggested alternative language to the sponsor.]

Colorado HB 1126 [Chapter 374] Effective: August 8, 2023 – This law prohibits consumer reporting agencies from including information related to a medical debt on a consumer report. The bill defines “medical debt” as “debt arising from health-care services, as defined in section 10-16-102 (33), or health-care goods, including products, devices, durable medical equipment, and prescription drugs. “Medical debt” does not include debt charged to a credit card unless the credit card is issued under an open-end or closed-end credit plan offered specifically for the payment of health-care services or health-care goods.” [RMAI fought the expansive definition which would have included medical debt charged on a credit card, including a bottle of Tylenol purchased from a grocery store. Through the efforts of RMAI, our Colorado lobbyist, and other industry partners we were able to get an exemption for credit card debt unless the credit card was offered specifically for the payment of health-care services or health-care goods.]

Colorado SB 93 [Chapter 152] Effective: May 4, 2023 – This law adopts changes related to the collection and litigation of medical debt, including: (1) defines “medical debt” as “debt arising from health-care services, as defined in section 10-16-102 (33), or health-care goods, including products, devices, durable medical equipment, and prescription drugs. “Medical debt” does not include debt charged to a credit card”; (2) caps the rate of interest on medical debt at 3% per annum; (3) upon written request, requires a debt collector or collection agency to provide to the consumer an itemization of the charges and additional prescribed data and documents; (4) establishes requirements relating to payment plans for medical debt; (5) requires a debt collector or collection agency that files a legal action to collect medical debt to include an itemization of the charges and, prior to the entry of a default judgment against the creditor, provide evidence of the debt; (6) makes it a deceptive trade practice to violate provisions of the act; and (7) requires a health-care provider or health-care facility to provide, upon request of a prospective patient, an estimate of the total cost of a health-care service to a person who intends to self-pay for the service. [RMAI fought the expansive definition which would have included medical debt charged on a credit card, including a bottle of Tylenol purchased from a grocery store. Through the efforts of RMAI, our Colorado lobbyist, and other industry partners we were able to get an exemption for credit card debt.]

Maryland HB 127 [Chapter 709] Effective: October 1, 2023 – This law provides that the district court may not, in aid of enforcement or execution of a money judgment resulting from a small claim action, order an individual to: (1) appear for an examination; or (2) answer interrogatories.

Maryland HB 686 [Chapter 567] Effective: July 1, 2023 – This law, among other things, eliminates requirements for collection agencies to maintain separate licenses for branch locations and authorizes them to conduct business at multiple licensed locations under a single license and provides the State Collection Agency Licensing Board the ability to impose bonding requirements from $50,000 to $1,000,000 for each licensee based on statutorily adopted criteria.

Minnesota SB 2744 [Chapter 57] Effective: January 1, 2024 – This law, among other things, adopts provisions related to coerced debt [see, sections 69-73 (pages 153-158)]. Coerced debt is when all or a portion of debt in a debtor’s name has been incurred as a result of: (1) the use of the debtor’s personal information without the debtor’s knowledge, authorization, or consent; (2) the use or threat of force, intimidation, undue influence, harassment, fraud, deception, coercion, or other similar means against the debtor; or (3) economic abuse perpetrated against the debtor. To make a claim of coerced debt, the debtor must be a victim of domestic abuse, harassment, or sex or labor trafficking. A debtor must, by certified mail, notify a creditor (includes debt buyers) that the debt or a portion of a debt on which the creditor demands payment is coerced debt and request that the creditor cease all collection activity on the coerced debt. The notification and request must be in writing and include documentation. The creditor, within 30 days of the date the notification and request is received, must notify the debtor in writing of the creditor’s decision to either immediately cease all collection activity or continue to pursue collection. If the creditor does not cease collection, the debtor may bring an action against the creditor.

Nevada AB 223 [Vetoed by Governor] – This bill would have required collection agencies to provide debtors without charge: (1) a payoff letter within 10 business days of a consumer request and (2) a satisfaction letter within 5 business days after the date on which the debtor satisfies the claim. The bill also provides for a private right of action for failure to provide a payoff letter in the required time. [RMAI was able to obtain some modest amendments; however, we remained in opposition.]

Nevada SB 276 – This bill would modernize the Nevada Collection Agency Act to among other things: (1) require debt buyers to be licensed as collection agencies; (2) allow debt collectors to work remotely; (3) eliminate separate licenses for branch offices; (4) change “qualified managers” to “compliance managers” and require only a single compliance manager for the corporate entity rather than one for each location; (5) in certain circumstances, where the compliance manager is a chief compliance officer, eliminate the required test; (6) eliminate antiquated posting requirements of licenses; and (7) exempt debt buyers from trust account requirements. [RMAI sponsored the introduction of this bill. The bill has passed both houses of the legislature by a unanimous vote and is awaiting action by the Governor.]

Oregon HB 2008 – This bill, among other things, would: (1) increase the auto exemption from $3,000 to $15,000; (2) increase various personal household property exemptions; (3) increase the homestead exemption from $40,000 to the median housing price for single-family dwellings in the county in which the homestead is located; and (4) protect approximately $52,000 in wages from garnishment. The bill would also authorize the award of punitive damages as part of a private right of action. [RMAI, while acknowledging some of the exemption thresholds could be increased, is strongly opposed to this bill as it is currently drafted. RMAI will be working with an industry coalition to seek amendments.]

Vermont SB 33 [Chapter 46] Effective: June 5, 2023 – This law, among other things, increases the small claims court jurisdiction from $5,000 to $10,000; except, it will not have jurisdiction over actions for collection of any debt greater than $5,000.00 arising out of: (1) a consumer credit transaction as defined in 15 U.S.C. Section 1679a; or (2) medical debt as defined in 18 V.S.A. Section 9481.

Washington SB 5173 [Chapter 393] Effective: July 23, 2023 and sunsets on July 1, 2025; section 2 of the bill takes effect on July 1, 2025 – This law updates the state property exemption provisions. The most notable changes include: (1) increasing the auto exemption from $6,500 to $15,000; (2) increasing the tools of the trade exemption from $10,000 to $15,000; and (3) doubling of the exemption amount for married couples when a marital status is declared. [RMAI worked with an industry coalition to fight this legislation and was able to achieve amendments that would eliminate an automatic doubling of the exemption for married individuals and an automatic cost of living adjustment.]

 

Seventh Circuit Requires Courts to “Rigorously Analyze” Class Action Claims
Eddlemon v. Bradley Univ., 65 F.4th 335 (7th Cir. 2023)

Due to the COVID-19 pandemic, a university offered only 14 weeks of classes instead of the scheduled 15 weeks described in its Academic Catalog.  The catalog expressly stated it served as a contract between the university and students.  The university did not offer students a pro-rata refund for tuition or activity fees.

A student, the plaintiff, filed a putative class action complaint on behalf of himself and all others similarly situated against the university alleging the catalog was a contract and that the university’s change to its curriculum was therefore a breach of contract and resulted in unjust enrichment.

The trial court certified two classes of students, one related to the tuition and the other for the activity fees, and the university filed an interlocutory appeal of the trial court’s certifications, specifically challenging the trial court’s analysis of the commonality and predominance requirements.

The U.S. Court of Appeals for the Seventh Circuit began with an explanation that for class certification, “plaintiffs must first meet the following four requirements: numerosity, commonality, typicality, and adequacy of representation.  Then, where, as here, certification is sought under Rule 23(b)(3), common questions of law or fact must predominate over individual inquiries, and class treatment must be the superior method of resolving the controversy.”

The Court agreed with the university that “a district court must rigorously analyze the requirements of Rule 23,” and that certification is appropriate only if the district court does so.”  The university contended the trial court erred in that respect “by relying solely on [plaintiff’s] allegations, without assessing the record.”

The Court agreed on both the issue of commonality and predominance, noting “the district court repeatedly referred to [plaintiff’s] allegations without addressing his proffered evidence (e.g., the Academic Catalog) or examining how he would prove his allegations with common evidence,” and “the court’s predominance analysis merely accepted [plaintiff’s] proffered common questions without referring to the common evidence presented to answer those questions. As such, the court’s certifications rest on an error of law and amount to an abuse of discretion.”

The university also contended that “the trial court did not identify or separately analyze the elements of [plaintiff’s] claims,’ which it  argued “was critical to the court’s predominance analysis.”  Addressing this, the Court explained “determining whether predominance is satisfied “requires more than a tally of common questions; the district court must consider their relative importance. . . we have explicitly instructed district courts to “begin the class certification analysis by identifying the elements of the plaintiff’s various claims.”

Here, the Court observed that the trial court “should have identified the elements of [plaintiff’s] two claims and separately analyzed them to better understand the relationship between each claim’s common and individual questions. Instead, it listed one common question for each class without explaining that question’s ‘relative importance’ to each claim, whether any individual questions exist, or how the common question predominates over individual ones.  That proved fatal to the court’s certification analysis.”

In conclusion, Seventh Circuit held the trial court “did not conduct the rigorous analysis required by Rule 23,” and vacated the class certifications and remanded the case for further proceedings.

Eighth Circuit Holds Modification of Bankruptcy Plan Requires a “Substantial Change in Circumstances”
Swackhammer v. Swackhammer (In re Swackhammer), No. 22-6006, 2023 Bankr. LEXIS 1343 (B.A.P. 8th Cir. May 23, 2023)

For several years in a row, a bankruptcy court allowed Chapter 12 debtors to modify their confirmed plan, each time over the objection of the debtors’ primary secured creditor who appealed.  The creditor argued that the court should have required the debtors “to show ‘unanticipated, substantial change in circumstances’ before confirming a proposed modified plan.”

On appeal, the U.S. Bankruptcy Appellate Panel for the Eighth Circuit described the issue as “whether the bankruptcy court abused its discretion by confirming the debtors’ fourth modified plan under 11 U.S.C. § 1229 without requiring the debtors to show an ‘unanticipated and substantial change in circumstances’ and whether, under whatever standard applicable to plan modifications, the court’s factual findings were clearly erroneous.”

Section 1229(a) provides, in part:  “At any time after confirmation of the plan but before the completion of payments under such plan, the plan may be modified, on request of the debtor, the trustee, or the holder of an unsecured claim . . . (2) to extend the time for payments.”

Additionally, § 1229(b) requires that modified plans comply with the requirements of § 1225(a), among others, which governs when a plan shall be confirmed.  The Court explained that “compliance with § 1225(a) means that, among other requirements, the court must find that the debtor ‘will be able to make all payments under the plan and to comply with the plan’ – the so-called feasibility requirement of § 1225(a)(6).”  The Court noted that the “language in § 1229 is nearly identical to that governing modification of chapter 13 plans under § 1329.”

The debtors argued that they were not required to show an unanticipated and substantial change in circumstances, and “numerous bankruptcy courts [] apply § 1229 on its terms without reading any additional requirements into the statute.”

The Eighth Circuit disagreed, citing its own decision in In re Johnson, 458 B.R. 745 (B.A.P. 8th Cir. 2011), where it held that “modification of a confirmed chapter 13 plan should be limited to situations in which there has been a substantial change in circumstances.”

Nevertheless, the Court noted that the debtor testified “that he was unable to meet his crop yield projections because of a delay in financing that year (as well as previous years). That delay caused his cash rent landlords to turn to other farmers, so he lost acreage on which he could farm ‘outright.’”  The Court concluded that “a loss of acreage for outright farming would constitute a substantial change in circumstances, whether unanticipated or not.”

Regarding the feasibility requirement, the Court found that “given that the projections and other exhibits the bankruptcy court reviewed are not in the record on appeal, we cannot say that the bankruptcy court clearly erred in finding that the [debtors] would be able to make their payments and to comply with the plan . . .”

Accordingly, the Eighth Circuit affirmed the decision of the bankruptcy court.

Seventh Circuit Finds Cost of Postage Establishes Concrete Injury for Article III Standing
Mack v. Resurgent Capital Servs., L.P., No. 21-2792, 2023 U.S. App. LEXIS 14354 (7th Cir. June 7, 2023)

A consumer defaulted on her credit card account, which was subsequently sold to a debt buyer.  The debt buyer’s servicer then retained a collection agency to collect the debt.  The collection agency sent a letter to the consumer informing her of her right to dispute the debt and in that letter identified a bank as the “original creditor” and the debt buyer as the “current creditor.”

The consumer mailed a letter to the collection agency disputing the amount of the debt but never received verification of the debt.  Her cost for the certified mailing was $10.15.

The consumer next received a letter from the debt buyer’s servicer which again informed her of her right to dispute the debt, identified the bank as the “original creditor,” but identified the debt buyer as the “current owner.”

The consumer alleged she was “confused and alarmed” by the letter from the servicer since she had already requested verification from the collection agency, heard nothing from them, and “was now being told that she would have to request validation again from a different company or the creditor would assume the debt was valid.  Accordingly, she sent another letter disputing the debt, but this time to the servicer.  The cost of postage was $3.95.

Three months after sending the second dispute letter, and receiving no response from anyone, she filed a class action lawsuit against the debt buyer and its servicer for violations of the Fair Debt Collection Practices Act.  Specifically, she alleged the servicer’s letter “used false, deceptive, misleading and unfair or unconscionable means to collect or to attempt to collect a debt in violation of sections 1692e, 1692e(10), and 1692f; it failed to adequately state the name of the creditor to whom the debt was owed in violation of section 1692g(a)(2).”

The trial court granted the defendants’ motion to dismiss under Rule 12(b)(1) for lack of standing and the consumer appealed, asserting “that the district court erred when it found that the time, effort and out-of-pocket costs expended in sending a second validation request were not adequate to establish standing.”

The U.S. Court of Appeals for the Seventh Circuit began by explaining that “a plaintiff must have “(1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision. To establish injury in fact, a plaintiff must show that he or she suffered ‘an invasion of a legally protected interest’ that is ‘concrete and particularized’ and ‘actual or imminent, not conjectural or hypothetical.’”

In response to the defendants’ contention that the consumer “pled nothing more than confusion, [and] that confusion alone is insufficient to establish a concrete harm,” the Court explained that  a complaint “does not need detailed factual allegations,” but factual allegations must be enough to raise a right to relief above the speculative level.”

Here, the Court held that “it is reasonable to infer that [the consumer] re-disputed the debt, and in doing so suffered a concrete injury at least in the form of postage paid to send the second validation request. . . The [servicer’s] Letter thus caused her to suffer a concrete detriment to her debt-management choices in the form of the expenditure of additional money to preserve rights that she had already preserved.”

Based on this, the Court reversed the ruling of the trial court and remanded the matter.

Sixth Circuit Holds Single Ringless Voicemail Enough for Article III Standing
Dickson v. Direct Energy, LP, No. 22-3394, 2023 U.S. App. LEXIS 13537 (6th Cir. June 1, 2023)

A consumer alleged he received numerous unauthorized, prerecorded ringless voicemails (“RVMs”) on his cell phone from the defendant, claiming violation of the Telephone Consumer Protection Act which “prohibits making any call, to any telephone number, ‘using any automatic telephone dialing system or an artificial or prerecorded voice’ absent an emergency or the recipient’s prior express consent. 47 U.S.C. § 227(b)(1)(A)(iii).”

The consumer filed a putative class action lawsuit and asserted that “he was harmed by these communications because they tied up his phone line, cost him money, and were generally a nuisance,” and “that the calls disturbed his solitude and invaded his privacy.”  However, during discovery, an expert witness determined that of all the alleged RVMs, only one was from the company, and the company moved to dismiss arguing the consumer “had suffered no concrete injury.”

The trial court granted the motion, holding that the consumer’s receipt of a just one RVM “did not constitute a concrete harm sufficient for Article III purposes because (a) he could not recall what he was doing when he received the RVM, (b) he was not charged for the RVM, (c) the RVM did not tie up his phone line, and (d) he spent an exceedingly small amount of time reviewing the RVM.”  The consumer appealed.

The US Court of Appeals for the Sixth Circuit began by explaining that “to determine whether an intangible harm—such as [the consumer’s] receipt of an unsolicited RVM—rises to the level of a concrete injury, courts may look to (1) history and tradition and (2) Congress’s judgment in enacting the law at issue.”

On the first point, the Court noted that it had recently held that “receipt of one unwanted voicemail ‘is injury enough’ to establish Article III standing because ‘[t]he intrusion caused by unwanted phone calls bears a close relationship to the kind of harm’ protected by common-law intrusion upon seclusion.”

As to whether just one RVM was enough, the court explained “it is immaterial that an independent common-law cause of action for intrusion upon seclusion requires evidence of calls ‘repeated with such persistence and frequency’ amounting to ‘hounding’ of the plaintiff. . .because in measuring concreteness, the inquiry centers on the kind of harm at issue rather than the degree of that harm.”

On the second point, the Court observed that “Congress enacted the TCPA after finding that unrestricted telemarketing practices harm consumers. The law is intended to protect from invasions of privacy wrought by unauthorized automated and prerecorded calls. . . Here, [the consumer] alleges that he received such an unsolicited marketing call from [the defendant] . . .  He also validly maintains that receipt of this message invaded his privacy. His injury therefore falls within the ambit of what Congress deemed to be an actionable harm when it enacted the TCPA.”

Finding both prongs of the standing analysis met, the Sixth Circuit reversed the trial court’s dismissal and remanded the matter.

RMAI’s Pre-Summit Silent Auction Opens Monday, June 19th
The 2023 Executive Summit Silent Auction’s pre-Summit online auction will open Monday, June 19th, and close Monday, July 3rd at 6:00 pm (PDT). These exclusive offerings allow you to indulge yourself in merchandise or unforgettable experiences you can enjoy during your trip to Monterey: enjoy a sunset catamaran cruise, take a guided e-bike tour on the 17-Mile Drive, or explore three more exciting items.

If you are planning to come early, stay later, or both, these auction items can be added to your itinerary while you’re in Monterey!

Executive Summit On-Site Silent Auction
The 2023 Executive Summit Silent Auction will be an on-site event only for registered attendees and will include 25 items donated by your peers. We are still accepting donated items for the auction catalog. If your company would like to donate an item, please fill out our donation form.

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.

Call for Proposals
RMAI’s Call for Proposals was sent to you all on June 5, 2023, and we are accepting proposals for the following:

• An education session at the 2024 Annual Conference
• An educational webinar
• An article for the spring or fall annual publications (print/digital)
• An education session at the 2024 Executive Summit

Please submit your proposals no later than Monday, August 7th.

Upcoming Webinar
Register now for July 19th webinar, Stand Out for the RIGHT Reasons: Strategies to Enhance Client/Creditor Collaboration and Opportunities.  Our presenters will highlight solutions to properly monitor, manage, and educate your clients/creditors with industry changes that can impact daily processes and strategies, through a thoughtful discussion on how to effectively engage clients and prospective clients to build confidence, enhance collaboration, and increase placements.

Recorded Webinars
If you missed our May 31st webinar on compelling arbitration or our June 13th on vendor and service provider controls, 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 webinars.

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

CRCP New
Angela Erwin, Finvi
Dana Hoover, Collection Attorneys USA
Zachariah Shlachtman, Lockhart, Morris & Montgomery

CRCP Renewals
Nichole Brehmer, Stenger & Stenger
Staci Evans, Accelerated Portfolio/Vance & Huffman LLC
Katie Head, Branding Arc
Bill Sorgatz, The Bureaus, Inc.

CRB New
Southwood Financial, LLC

CRB Renewal
Lippman Recupero

Did You Know? Facts About Business/Vendor Certification

• Business certification is available to all RMAI members whether you are a debt buyer (Consumer and Commercial), collection agency, collection law firm, broker, defense law firm, process server, vendor or originating creditor.
• Certified businesses are the only voting members of RMAI.
• Being a Certified Receivables Business (CRB) has proven to reduce litigation exposure which reduces litigation costs. RMAI recently updated our 2019 white paper to include fresh data about our certified businesses as it relates to litigation and complaints. The revised white paper will be available to members very soon. Per the 2019 version of the white paper, on average, after completing the certification, CRBs experience a 6.53% decrease in litigation due to decreased consumer complaints and adherence to consumer protection standards.

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 [email protected].

Register for Executive Summit
Registration is open for the 2023 Executive Summit, August 1-3, Monterey, California. While you’re at it, make your reservation at The Monterey Plaza Hotel & Spa before rooms set aside for our group sell out. The Executive Summit always delivers a perfect blend of networking and education for boosting your business and your brand. See you in Monterey!

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

RMAI 2023 Executive Summit | August 1-3, 2023
2023 Fall Networking & Baseball | September 11, 2023
2024 RMAI Annual Conference | February 5-8, 2024

The RMAI offices will be closed Tuesday, July 4, in observance of Independence Day.

Thank you to our June 1, 2022 through June 13, 2023 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Encore Capital Group, Inc.

Financial Recovery Services, Inc.

First Financial Portfolio Services, LLC dba FFAM360 Capital

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Second Round, LP

TRAKAmerica

Velocity Portfolio Group, Inc.

Platinum $10,000

Blitt and Gaines, P.C.

EverChain

Garnet Capital Advisors, LLC

InvestiNet, LLC

National Credit Adjusters, LLC

Plaza Services, LLC

Provana, LLC

T & I Enterprises, LLC

Unifund CCR LLC

Velo Law Office

Gold $7,500

Halsted Financial Services, LLC

Klima, Peters & Daly, P.A.

Pressler, Felt and Warshaw, LLP

Ragan & Ragan, PC

Rausch Sturm, LLP

Superlative RM

Silver $5,000

Andreu, Palma, Lavin & Solis,  PLLC

AscensionPoint Recovery Services, LLC

CKS Financial

Corporate Advisory Solutions, LLC

DebtNext Software, LLC

Digital Recognition Network

FMA Alliance, Ltd

National Loan Exchange, Inc.

Pharus Funding, LLC

Spring Oaks Capital, LLC

Bronze $2,500

Absolute Resolutions Corp.

Acctcorp International, Inc.

Actuate Law, LLC

Aldridge Pite Haan, LLP

Central Portfolio Control, Inc

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Invenio Financial, a Phillips & Cohen Associates company

January Technologies, Inc.

Kredit Financial Inc.

Premier Forty Financial, LLC

RAzOR Capital, LLC

Resurgence Capital, LLC

Security Credit Services, LLC

Slovin & Associates

Stillman Law Office

Suttell & Hammer

Tobin & Marohn

Troutman Pepper

TrueAccord

Venable LLP

Vertican Technologies, Inc.

Weltman, Weinberg & Reis Co., L.P.A.

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

D & A Services, LLC

Dobberstein Law Firm, LLC

Epicenter Technologies Pvt. Ltd.

Equabli, Inc

FLOCK Specialty Finance

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Guglielmo & Associates, PLLC

Hunt & Henriques, LLP

International Debt Buying Consultants, LLC

Investment Retrievers, Inc.

Jefferson Capital Systems, LLC

Kota Business Solutions LLC

Law Offices of Goldberg & Oriel

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Mandarich Law Group LLP

Markoff Law LLC

Maxwell & Graves Solutions, 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

Quantum3 Group, LLC

RevSpring

Robinson Hoover & Fudge, PLLC

Scott & Associates, PC

Sequium Asset Solutions, LLC

SimpleCertifiedMail.com

Skit.ai

Stenger & Stenger P.C.

Stone, Higgs & Drexler

The Cadle Company

US Mortgage Resolution, LLC

USASF Servicing, LLC

VeriFacts, LLC.

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

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

Simmonds & Narita LLP

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