In This Update
On Capitol Hill, medical debt continues to receive increasing attention. The issue remained a focus following last month’s Senate vote on the Congressional Review Act resolution related to the CFPB’s medical debt rule. The motion failed 50-48. The resolution sought to overturn the Trump administration’s rollback of the Biden-era CFPB medical debt rule.
Additional medical debt legislation also continues to emerge. Last year, Sen. Jeff Merkley (D-OR) introduced S. 2519, which would broadly prohibit the reporting of medical debt to credit reporting agencies. Similarly, Sen. John Kennedy (R-LA) introduced S. 4622, the PATCH Act, earlier this year. The bill would likewise prohibit the reporting of medical debt and restrict the use of medical debt information in underwriting decisions. While major medical debt legislation remains difficult to advance this year, particularly as House leadership has signaled opposition to non-germane additions to legislation expected to move through Congress, states continue pursuing their own medical debt frameworks and restrictions.
At the CFPB, the Bureau continues to undergo significant operational and leadership changes. Under federal law, Acting Director Russ Vought cannot continue serving in that role past August 1. This month, the White House nominated Brian Johnson to serve as the next Director of the CFPB. Johnson is currently a senior executive at Capital One and previously worked at Patomak Global Partners and Alston & Bird. He also served as Deputy Director of the CFPB during the first Trump Administration and held several positions at the agency between 2017 and 2020, following earlier service on the House Financial Services Committee staff from 2012 to 2017.
Meanwhile, Mark Paoletta was named Deputy Director of the CFPB. Paoletta is a close ally of Vought and has played a significant role in efforts to reduce the size and scope of both the CFPB and the broader federal government.
The CFPB also recently implemented several changes to its website. The Bureau updated its homepage and removed the prior emphasis on filing complaints. Previously, visitors to the CFPB website were automatically directed to the complaint submission page. The CFPB has now returned to a more traditional agency homepage, with complaint submission still available through navigation links on the site. In addition, the CFPB removed thousands of webpages and historical records, including all Supervisory Highlights reports dating back to 2012. Those reports had long been utilized by compliance professionals to monitor examination priorities and enforcement trends.
Finally, RMAI and industry stakeholders recently filed comments with the FCC regarding the Commission’s proposed offshore call center and customer service rulemaking, which could significantly impact lawful financial services communications and vendor operations.
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:
Colorado SB 26-139 [Chapter 131] Effective: January 1, 2027 – This bill law replaces the prior artificial intelligence law that was enacted in 2024. The law eases some requirements on developers and deployers while providing consumer’s notice if covered automated decision-making technology (ADMT) is used to make consequential decisions and the right to receive additional information in the event ADMT makes a consequential decision that results in an adverse outcome. [RMAI was supportive of the repeal of the prior law and was neutral on this legislation.]
Maine LD 588 [Chapter 201] Effective: July 14, 2026 – This law expands Maine’s existing statutory prohibitions on reporting medical debt by eliminating the exception that allowed reporting after 180 days and specifically indicating that a medical creditor, debt collector, or debt buyer is prohibited in reporting a consumer’s medical debt to a consumer reporting agency. [RMAI was neutral on the bill because the bill cross-referenced the existing statutory definition of “medical debt” that RMAI was instrumental in getting adopted which carved out open and closed lines of credit, including general purpose credit cards.]
Vermont HB 385 [Chapter 106] Effective: July 1, 2028 – This law establishes protections and remedies for victims of a debt arising from intimidation, violence, or domestic abuse. The law requires specific documentation to substantiate claims of coerced debt, including police reports, court orders, and certifications from qualified professionals. Creditors are required to cease collection efforts upon receiving a debtor statement of coerced debt and adequate documentation and notify credit reporting agencies to delete adverse information related to such debts. The law also provides civil legal remedies, allowing debtors to defend against claims of coerced debt and hold perpetrators liable. Creditors can seek recovery from the perpetrators of coerced debt. [Through RMAI advocacy, testimony, the involvement of RMAI’s lobbyist, and coordinating with the Vermont Bankers Association, RMAI has been able to obtain several favorable amendments during the legislative process.]
Virginia HB 1725 [Chapter 692] Effective: July 1, 2026 – This law prohibits large healthcare facilities and medical debt buyers from charging interest or late fees on medical debt until 90 days after the final invoice due date, with a cap of three percent per annum. The act restricts medical creditors and debt collectors from engaging in extraordinary collection actions, such as causing arrests or foreclosures, and mandates a 120-day waiting period before such actions can be initiated. Additionally, it requires medical creditors to enter into agreements with debt buyers to prevent excessive collection practices and ensures that any excess payments made by patients are refunded within 60 days. Violations of this act are considered prohibited practices under the Virginia Consumer Protection Act, with enforcement provisions applicable. [RMAI was opposed to this legislation due to the specific reference to debt buyers; however, its provisions are similar to laws adopted in other states, including California.]
Fourth Circuit Affirms Rejection of Collection Law Firm’s Attempt to Compel Arbitration
Jackson v. Protas, Spivok & Collins LLC, No. 25-1971, 2026 U.S. App. LEXIS 14147 (4th Cir. May 18, 2026)
A debt buyer purchased a consumer’s loan and subsequently retained a law firm file a collection lawsuit when the consumer failed to pay. Although the law firm dismissed the case with prejudice, the consumer filed a lawsuit against the debt buyer and the law firm “which he styled as a class action challenging the legality of their ‘practice of suing on time-barred debt.’”
The debt buyer and the law firm sought to compel arbitration based on the arbitration provision in the consumer’s promissory note with the original creditor. In relevant part, the provision stated:
“You” and “your” mean [Original Creditor], any person servicing this Note for [Original Creditor], any subsequent holders of this Note or any interest in this Note, any person servicing this Note for such subsequent holder of this note, and each of their respective parents, subsidiaries, affiliates, predecessors, successors, and assigns . . . .
“Claim” means any dispute, claim, or controversy . . . arising from or relating to this Note . . . .
Any Claim shall be resolved, upon the election of either you or me, by binding arbitration . . . .
The debt buyer claimed it was a “subsequent holder” of the note, while the law firm claimed it was “servicing” the note. The trial court rejected both arguments, holding that the debt buyer waived its right to arbitrate by filing suit against [the consumer] in state court, and the law firm was not a party to the arbitration agreement. The law firm appealed.
On appeal, the U.S. Court of Appeals for the Fourth Circuit affirmed the trial court’s ruling. In its unpublished opinion, the Court considered various definitions for “servicing,” but ultimately settled on “to collect payments and maintain a payment schedule for (a loan).” The Court believed this appropriate because “[i]t limits the scope of the arbitration agreement to a specific kind of entity, rather than opening it up to an unlimited universe of them,” and was “consonant with the way the term is used in the borrower registration agreement…”
In the Court’s opinion, the law firm’s activities did not meet this definition since “[i]t did not maintain a payment schedule for the loan, collect regular payments, keep records of regular payments, send and receive regular communications, or in any other way administer the loan,” and instead performed an entirely different function by “preparing and submitting briefs in a collection lawsuit against the debtor.”
Third Circuit Affirms Dismissal of FCRA Claim Not Objectively and Readily Verifiable
Bandes v. TransUnion LLC, No. 25-3184, 2026 U.S. App. LEXIS 13364 (3d Cir. May 8, 2026)
A consumer filed a lawsuit under the Fair Credit Reporting Act (“FCRA”) against a credit reporting agency (“CRA”) and a debt buyer, claiming that the debt buyer furnished inaccurate information about his debt to the CRA, which then reported it as “active and in collections.” The consumer did not dispute incurring the debt or failing to repay it, but argued that the debt could not be “in collections” because a Pennsylvania state court had dismissed the debt buyer’s suit to collect the debt with prejudice for failure to prosecute.
The trial court dismissed the complaint on the grounds that the consumer did not allege any actionable inaccuracy in the report of his debt. The court found that the claim was based on a legal conclusion rather than a factual inaccuracy, as the consumer argued that the dismissal with prejudice precluded the debt buyer from collecting the debt in court.
On appeal the U.S. Court of Appeals for the Third Circuit explained that the consumer characterized his claim as factual even though the basis was that “the dismissal with prejudice of that suit means that [the debt buyer] can never again seek to collect the debt in court.”
The Court noted that the Third Circuit had not resolved the question “whether a legal defense to a debt can render a report of that debt ‘inaccurate’ for FCRA purposes.” It explained that other circuits were split, with some requiring “a showing of strict factual inaccuracy, while others hold[ing] that a legal dispute can qualify so long as its effect on the debt is ‘objectively and readily verifiable.’”
Here, the Court found it did not have to decide that issue because even if a legal dispute could make the report of a debt inaccurate under the FCRA, the consumer failed to show in an “objectively and readily verifiable way” that the dismissal of the collection lawsuit would have the preclusive effect claimed. In fact, the Court noted that “Pennsylvania courts typically do not give preclusive effect to dismissals for failure to prosecute even when such dismissals are with prejudice.”
In its unpublished opinion, the Third Circuit concluded:
In sum, even if a legal dispute as to a debt could raise a cognizable FCRA inaccuracy, [the consumer] has not raised the kind of objectively and readily verifiable dispute that might qualify. To be clear, we express no opinion on whether [the debt buyer] can still seek to collect [the consumer’s] debt in any court proceeding. We instead hold only that resolution of that issue is not so obvious as to render the description of [the consumer’s] debt as “in collections” inaccurate under the FCRA.
RMAI Legislative Fundraising Committee Outreach
The Legislative Fundraising Committee is working to ensure that RMAI can continue its advocacy efforts. With new legislation that can impact your business, it is more important than ever to ensure that your voice is heard. This year, RMAI has tracked countless bills across the country, covering issues like medical debt, AI, data privacy, and more. The Legislative Fundraising Committee will continue to reach out to members for donations, so keep an eye out for correspondence. Your donations make a difference, allowing RMAI to lobby on your behalf across the country.
If you’d like to contribute to the Legislative Fund, you can Donate Here. We will add your company name to our list of Legislative Fund contributors on our website.
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 July 14th webinar on Semantics (Title and Description coming soon!)
Recorded Webinar
Recorded on June 2, 2026, you can register for Better Conversations, Better Outcomes: Collecting with Call Models. Our presenters, Andrew Domino with Bridgeforce and Jason Hinkle with Shepherd Outsourcing, walked through a sample call model structure and showed how it can be taught in a way to align better with agent skillsets, consumer expectations, and current regulations.
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 renewed Certified Receivables Vendor (CRV)!
CRCP New
Ben Carroccio, Sunrise Credit Services
Steven Fishbein, Asset Recovery Solutions
Barbara Nilsen, Blitt & Gaines
Brandon Shampoe, Allied Alliance Group, Inc.
CRCP Renewals
Nicholas Capezza, Bayview Solutions, LLC
Michael Cassidy, Velocity Portfolio Group, Inc.
Angie Christiansen, Accelerated Portfolio Inc.
Jason Davis, CastleWise Licensing
Ross Enders, Bedard Law Group P.C.
Patrick Green, Crown Asset Management
Michael Hyla, Atlantic Recovery Solutions
Tom Ludwig, National Loan Exchange
Aurora Sain, RMAI
William Shaulis, The Cadle Company
Jan Steiger, Retired
Alexandra Taylor, Credit First National Association
Kyle VonAllmen, Starmark Financial
CRB Renewal
SAM Inc., Solutions for Account Management
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 and game-oriented resources will help you feel less intimidated and more confident in how to obtain certification at any level.
Individual Certification
Business/Vendor Certification
- 7 Steps to Earn the Certified Receivables Business (CRB) Designation
- 7 Steps to Earn the Certified Receivables Vendor (CRV) Designation
- CRB Timeline
View our full list of certification resources.
Take Advantage of Educational Opportunities for You and Your Team
Remember, one of your benefits of membership with RMAI is complimentary and discounted registration for live and recorded webinars. Not only do these educational webinars advance your knowledge, but they are an excellent training resource for your team, and the credits count toward the Certified Receivables Compliance Professional (CRCP) designation. Catch them live or watch the recording after – you can see all previously recorded webinars on our website here.
As an RMAI member, you also get a discount on sponsoring educational webinars. Showcase your company by sponsoring a webinar. Sponsorship gets you and your brand in front of a captive audience of our most engaged members for the live webinar as well as for the following 12 months on the recorded webinar. You will also have the option to give a 2–3-minute pitch at the beginning of the live webinar to introduce your product. Contact Shannon Parod to sponsor a webinar!
Welcome, New Members
- WF Recovery, LLC | LA
- Nationwide Credit Corporation | VA
- ALLDIGI TECH INC. | NJ
- The Hallstrom Law Firm | AZ
- First Technology Federal Credit Union | OR
- Marcardis Law Firm PA | FL
For a complete list of RMAI members, login to check out the Member Directory.
RMAI LEGISLATIVE FUND CONTRIBUTORS JUNE 1, 2025 – JUNE 12, 2026
DIAMOND ($50,000+)
PRA Group, Inc.
Resurgent Holdings, LLC
Velocity Portfolio Group, Inc.
TITANIUM ($25,000+)
Absolute Resolutions Corp.
Cavalry Portfolio Services, LLC
Midland Credit Management
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
Couch Lambert
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
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
Crown Asset Management, LLC
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
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
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