RMAI Update March 2024

On Thursday, March 7, the House Financial Services Subcommittee on Financial Institutions and Monetary Policy convened a hearing entitled Politicized Financial Regulation and its Impact on Consumer Credit and Community Development. The topics most relevant to the ARM industry were:

1) The CFPB Rule on Late Fees and Proposed Rule on Overdraft Fees       

The hearing focused primarily on the recent finalized CFPB rule on late fees as well as the proposed rule on overdraft fees.  Republicans overwhelmingly criticized the Bureau by identifying the second order effects of the rules.  Chairman Barr argued that the cost of credit will increase, while access to credit will decrease.  Congressman Luetkemeyer said that this rule will incentivize people to pay late.  He also made the point that people pay for overdraft coverage and appreciate that service.  Congressman Williams suggested that the Bureau’s actions would result in less loans and fewer services.  Congressman Timmons said that the fees pay for other services the financial institution can offer, and said they also serve as a deterrent to bad behavior.  Congresswoman Kim stressed that diverse communities will be harmed by less consumer rewards, higher maintenance fees and higher interest rates to make up for the loss of revenue from the fees that are being capped.

Democrats roundly defended the Bureau’s rule and proposed rule as good for the consumer.  Ranking Member Foster said that surprise junk fees are not a hallmark of an efficient free market.  He argued that high fees prevent some individuals from accessing the banking system.  Congressman Sherman said the Bureau should be applauded for ending bad practices which will result in billions of dollars in savings for the American people.  Congressman Casten said he would like to know how much of the fees are levied to recoup costs versus how much are levied to discourage late payments.  Interestingly, Congressman Vargas specified that he is concerned on the effect the rules will have for credit unions specifically.

Of the witnesses, Mr. Anthony, Ms. Johnson, and Ms. Harbin were largely in agreement, often disagreeing with Mr. Sueiro.  Ms. Johnson pointed out that a late fee could not be considered a junk fee. Mr. Anthony said that there was no economic problem that needed to be solved with these rules.  Ms. Harbin said repeatedly in her testimony and in response to questions that “These fees do not exist in a vacuum.”  She made the point that each rule and regulation has a compounding effect on financial institutions’ ability to provide good services.  Mr. Sueiro said that financial institutions need to reimagine their relationships with their customers, saying these rules will lower the unbanked rate in the country and bring more equity to the financial services industry.

2) The Politicization of the CFPB

Republicans spent much of their time criticizing what they referred to as the “politicization” of the CFPB.  This argument routinely referenced two points: 1) Biden’s campaign team often talks about a “war on prices” and the rule was released close to the State of the Union, and 2) “junk fees” is just a made-up term that has no legal definition but polls well with the public.  When making this second point, Chairman Barr declared that the CFPB could no longer be construed a truly independent regulator, and therefore should have more oversight from Congress.  Barr’s attack continued by criticizing what he referred to as Director Chopra’s “I know it when I see it” form of identifying bad behavior.

Congressman Luetkemeyer offered that Director Chopra only uses the term “junk fees” as a way to utilize UDAAP for industries or entities he personally does not like.  Congressman Loudermilk predicted that President Biden would reference junk fees and the CFPB’s actions in his State of the Union in order to improve his poll numbers.  Congressman Timmons said the Biden Administration is using the CFPB illegally in an attempt to buy votes.

Unsurprisingly, Democrats defended the CFPB and defended the use of “junk fees.”  Ranking Member Foster spoke of the spread-out oversight before the CFPB, necessitating the Bureau’s creation.  Congressman Sherman thanked God for the CFPB’s billions returned to individuals and gave an impromptu definition of junk fees as fees you don’t expect until the end of the transaction.  Congressman Vargas complimented the CFPB’s work to protect veterans and said junk fees are those fees the American people don’t feel are appropriate.  Congressman Casten agreed with Republicans that the CFPB is too political, but he placed blame with former President Trump’s administration.

Of the witnesses, Mr. Anthony suggested that the CFPB’s actions are to shore up President Biden’s reelection efforts.  In a response to Congressman Posey’s question, Mr. Anthony said junk fees do not have meaning and change day to day.  Ms. Harbin said it is unfair to label something as a “junk fee” since they are open and transparent ahead of time with consumers.  Ms. Johnson said that the CFPB prioritized politics and exceeded its authority.

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. In 2024, RMAI has so far retained lobbyists in the following states: California, Colorado, Maine, Michigan, Minnesota, New York, New York City, Oregon, and Rhode Island. RMAI has also provided a financial contribution to a Nevada coalition fighting two ballot initiatives. 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 is a sample of the legislative activity over the prior month that has direct impact on the industry:

California AB 1160 – This bill would prohibit a college from refusing to provide a diploma for a current or former student on the grounds that the student owes a debt or using the issuance of a diploma as a tool for debt collection. [RMAI is neutral on this bill. RMAI was initially opposed to the bill as the original language contained a provision which prohibited the use of collection agencies for the collection of student debt and prohibited the sale of student debt. RMAI successfully worked to have these provisions removed from the bill. This bill has passed the Assembly.]

California SB 1061 – This bill would probit a person from furnishing information regarding a medical debt to a consumer credit reporting agency and would make a medical debt void and unenforceable if information regarding the medical debt is furnished to a consumer credit reporting agency. The bill would broadly define medical debt to mean “a debt related to, in whole or in part, a transaction, account, or balance arising from a medical service, product, or device.” However, it would specifically exempt debt charged to a credit card unless the credit card is issued under an open-end or closed-end plan offered specifically for the payment of medical services. [RMAI is seeking a narrower definition of “medical debt” that would tie it to medical debt directly owed to a person or facility licensed in California that provides medical services.]

Maine LD 2115 – This bill would require hospitals to offer a patient the ability to pay off their debt for the same price a debt buyer is purchasing their account prior to its sale. [This bill would create a first in the nation requirement which RMAI strongly opposes. RMAI testified in opposition to the bill in print and provided input on alternative bill language the sponsor is considering.]

Massachusetts HB 4429 – 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, 2025. [RMAI has been opposing this bill since 2014 when it was first introduced. After eight years of negotiations and countless amendments, RMAI, other industry participants, and consumer advocates agreed to amendments that resulted in a neutral position by the industry. 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”; (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 and an industry coalition are vigorously opposing this bill. RMAI has retained a Michigan lobbyist. RMAI had in-person meetings with the bill sponsors and key legislators in October, followed by two virtual meetings with the Senate sponsor, to express our concerns. We anticipate several amendments proposed by the industry to be accepted by the sponsor and are awaiting the draft before we determine our next steps. The earliest the bill will likely be considered is in April.]

Minnesota SF 4065 / HF 4100 – This bill would among other things: (1) reduce Minnesota’s six-year statute of limitations to three years on all consumer debts; (2) create a flat exemption amount of $5,000 on bank accounts; (3) increase the exemption on wage garnishment from 40x to 80x state minimum wage; (4) reduce the allowable garnishment percentage from 25% to 10% of net wages; (5) increase property exemptions; (6) require collection attorneys to be licensed as debt collectors; (7) reduce the statute of limitations on judgments; (8) prohibit the renewal of judgments; and (9) prohibit credit reporting of all medical debt in the state. [RMAI is part of an industry coalition which is negotiating with the bill sponsors and the attorney general’s office. The negotiations are ongoing, and progress is being made, including an agreement to remove the SOL provisions and judgment renewal provisions from the bill.]

New York SB 666-A / AB 4088-A – This bill would establish a state-wide debt collector license in New York under the authority of the Department of Financial Services (the same agency that licenses the banking and insurance industries and which for the last 10 years has promulgated rules for debt collectors). [RMAI has been working with the legislature on amendments to various versions of this bill for years and recently was able to get virtually all our requested amendments incorporated into the latest version.]

Oregon SB 1595 – This bill would among other things: (1) phase-in a wage garnishment exemption increase from the current $254 a week to 30x minimum wage (approximately $24,000 annually); (2) increase the auto exemption from $3,000 to $10,000; (3) increase various personal household property exemptions; (4) increase the homestead exemption from $40,000 to $150,000; and (5) increase the statute of limitations for consumers to bring suit against debt collectors from one to three years measured from the point of violation. [RMAI worked with an industry coalition over two legislative sessions to achieve reasonable bill amendments that resulted in a neutral stance on the legislation. The bill as originally introduced would have: (a) protected over $50,000 in income; (b) increased the auto exemption to $15,000; (c) increased the median housing price for single-family dwellings in the county in which the homestead is located; (d) increased the SOL from one to six years measured from discovery instead of violation; and (e) imposed punitive damages upon debt collectors for any violation of the act. The amended bill has passed both houses and is awaiting the Governor’s signature.]

Rhode Island HB 7103, SB 2709, SB 2710 – These bills all propose an expansive definition of “medical debt” which can be interpreted to include purchases of medical services or products on credit cards or home equity lines of credit. The bills in totality would ban the reporting of medical debt to credit bureaus, void all “medical debts” that are reported to a credit bureau, cap the interest on medical debt, and prohibit liens on real property. The bills have the support of the Rhode Island Leukemia and Lymphoma Society. There are no other industry participants that presently have a lobbyist in Rhode Island, so RMAI will be the only voice for the broader industry. [RMAI has retained a Rhode Island lobbyist to advocate for a narrower definition of medical debt in all related bills to exclude all other asset classes.]

Seventh Circuit Finds Lack of Standing in FDCPA Lawsuit: “Put Up or Shut Up”
Brown v. CACH, LLC, No. 23-1308, 2024 U.S. App. LEXIS 4746 (7th Cir. Feb. 29, 2024)

A consumer defaulted on an account and the creditor sold the account to a debt buyer without providing any representation as to the accuracy of the balance.  Following the initiation of collection attempts, the consumer filed a lawsuit against the debt buyer alleging violation of the Fair Debt Collection Practices Act (“FDCPA”), § 1692e, which prohibits using “any false, deceptive, or misleading representation or means in connection with the collection of any debt.”

The consumer did not allege any specific monetary loss or “other tangible detriment” from the collection attempts but claimed “she had ‘interrupted [her] self-employment’ to ‘mull over [her] memories’ and ‘scour [her] records’ about the asserted debt.”  After the consumer failed to provide any additional information regarding her harm, as requested by the judge, the trial court dismissed the complaint for lack of Article III standing and the consumer appealed.

The U.S. Court of Appeals for the Third Circuit noted it was “easy to see how debt collection efforts could reduce a person’s self-employment income,” and provided several possible examples.  Nevertheless, “it isn’t enough to imagine how injury could occur; a plaintiff challenged to produce evidence of injury at the summary judgment stage must do so.”

Affirming the judgement of the trial court, the Court of Appeals stated that “[s]ummary judgment is the ‘put up or shut up’ time in litigation,” concluding that “[i]nterruption of self-employment could cause a loss, but whether it did cause a loss must be established by evidence. Plaintiffs, who declined an opportunity to produce such evidence, cannot carry on with this litigation.”

Third Circuit Adopts “Kind of Harm” Analysis for Standing in Hunstein-Type Claim
Barclift v. Keystone Credit Servs., LLC, No. 22-1925, 2024 U.S. App. LEXIS 3796 (3d Cir. Feb. 16, 2024)

A collection agency sent a consumer’s personal information to a mailing vendor without the consumer’s permission.  The consumer filed a class action complaint against the collection agency alleging a violation of the Fair Debt Collection Practices Act (“FDCPA”).  Specifically, she alleged violation of 15 U.S.C. § 1692c(b) which “bars debt collectors from communicating with third parties in connection with a debt absent prior consent from the debtor,” subject to certain exceptions.

In her amended complaint, the consumer alleged that the letter vendor “maintains electronic copies of the consumer data it receives from debt collectors for multiple years, during which time its employees can access sensitive information.”  She did not allege that the vendor shared her personal information externally. The trial court dismissed the claim with prejudice for lack of Article III standing and the consumer appealed.

The U.S. Court of Appeals for the Third Circuit began by describing the three elements necessary for Article III standing and focused on the first, whether there is “an injury in fact that is concrete and particularized.”  The Court explained that even “intangible harms can give rise to concrete injuries when they bear ‘a close relationship to harms traditionally recognized as providing a basis for lawsuits in American courts,’” quoting TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021).

The Court observed that following TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021), two types of analysis developed for determining the sufficiency of an intangible harm.  Hunstein v. Preferred Collection & Mgmt. Servs., 48 F.4th 1236 (11th Cir. 2022) (en banc), involved a similar “mailing vendor theory” lawsuit.  In that decision, the majority took an “element-for-element” approach that reasons “an alleged intangible harm is not closely related to a traditional harm if it is ‘missing an element essential to liability’ under the comparator tort.”  The dissent, however, relied on a “kind of harm” analysis that “would require a plaintiff suing on a statutory cause of action to ‘show that his alleged injury is similar in kind to the harm addressed by a common-law cause of action, but not that it is identical in degree.’”

Following the Hunstein decision, the U.S. Court of Appeals for the Tenth Circuit considered a similar case in Shields v. Prof’l Bureau of Collections of Md., Inc., 55 F.4th 823 (10th Cir. 2022), and found a lack of standing using the kind of harm analysis.  Thereafter, in Nabozny v. Optio Sols. LLC, 84 F.4th 731 (7th Cir. 2023), the U.S. Court of Appeals for the Seventh Circuit found a lack of standing in a mailing vendor lawsuit using the element-based approach.

Ultimately, the Third Circuit decided that the kind of harm analysis was “more faithful to TransUnion.”  Applied to this case, the Court found the consumer could not “demonstrate that the injury resulting from [the debt collector’s] communication of her personal information to a third-party mailing vendor bears a close relationship to a harm traditionally recognized by American courts.”  The harm caused by the traditional tort of public disclosure of private information is “the humiliation that accompanies the disclosure of sensitive or scandalizing private information to public scrutiny.”  The consumer’s claims were not of the same character and the Court concluded that “the harm from disclosures that remain functionally internal are not closely related to those stemming from public ones.”

While the Court agreed with the trial court’s order regarding the lack of standing, it modified the order be without prejudice because “dismissals ‘with prejudice’ for  lack of standing are generally improper.”

Third Circuit Holds Pennsylvania Consumer Discount Company Act Inapplicable to Debt Buyers
Petro v. Lundquist Consulting Inc., No. 22-3051, 2024 U.S. App. LEXIS 2831 (3d Cir. Feb. 7, 2024)

A consumer received a loan from a lender licensed under the Pennsylvania Consumer Discount Company Act (“CDCA”), 7 Pa. Stat. Ann. § 6201, et seq.  The consumer defaulted and the debt was charged off and sold to a debt buyer that assigned it to a collection agency.  The collection agency sought only the charges that accrued to the original lender.

The consumer filed a lawsuit against the debt collector alleging that the collection efforts violated the Fair Debt Collection Practices Act (“FDCPA”) because the debt collector and debt buyer “could not lawfully collect interest and fees which were authorized under the CDCA,”  since neither was licensed under the CDCA or received prior approval of the purchase from the Pennsylvania Department of Banking and Securities (the “Department”).

Relying on Lutz v. Portfolio Recovery Assocs., LLC, 49 F.4th 323 (3d Cir. 2022), and Zirpoli v. Midland Funding, LLC, 48 F.4th 136 (3d Cir. 2022), the trial court granted the debt collector’s motion for judgment on the pleadings and the consumer appealed.

The U.S. Court of Appeals for the Third Circuit, in an unpublished decision, affirmed the trial court’s order and explained that “[u]nder the CDCA, entities in the ‘business of negotiating or making loans or advances of money on credit’ are required to obtain a license,” and “a licensee may not sell CDCA-authorized contracts to an unlicensed person or entity.”

The Court noted, however, that “entities in the business of purchasing and collecting charged-off consumer debt are not subject to the CDCA’s regulatory scheme. . . ‘it is not reasonable to infer that an entity that purchases charged-off debt would also be in the business of negotiating or bargaining for the initial terms of loans or advances.’”  This interpretation was supported by the Department in its amicus curiae letter in which it “stated unequivocally that ‘the CDCA does not apply in this situation.’”

Another Annual Conference Silent Auction in the Books!
Thank you to all of our 2024 Annual Conference Silent Auction donors, bidders, and winners! We received 60 auction items and raised $18,805 – 100% of the proceeds go directly to RMAI’s Legislative Fund. Thank you for your continued support of our silent auctions!

RMAI’s Advocacy at Work
RMAI is at your service again in 2024! Already we have tied for the record number of lobbyists we have retained in a year to fight legislation that could be detrimental to the receivables management industry. Currently, RMAI has retained lobbyists in California, Colorado, Maine, Michigan, New York, New York City, and Oregon. The Oregon bill, OR S 1595 has made its way to the Governor for signature which, due to RMAI’s advocacy, includes better language than what was proposed. You can find the update on OR S 1595 in the State Legislative section of this newsletter. Your donations help us continue to actively defend your rights. We hope that you will consider donating, in any amount, to RMAI’s Legislative Fund.

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.

Continuing Legal Education (CLE) and Certification Credits at the Annual Conference
At the recent Annual Conference in February, RMAI offered CLE credits for attorneys as well as general general certification credits for individuals looking to become a Certified Receivables Compliance Professional (CRCP). If you attended education while at the conference and have not yet submitted your CLE or certification credit form, please email your completed CLE credit form to [email protected] and your completed certification credit form to [email protected].

Upcoming Webinars
Register for our March 26^th webinar, Navigating Complicated Compliance & Technology in the Process of Service, where our presenters will discuss how technology is shaping the world of process service for both clients and vendors and what those advances mean for your compliance, auditing, and oversight.

Recorded Webinars
Recorded on February 26^th, you can register for Dancing with Debt Settlement. This webinar discusses the use of technical automation and compliance frameworks to manage advisor-driven settlement negotiations and achieve successful, efficient resolutions.

Recorded on February 21^st, you can register for Insights into the Consumer Default Judgement Act which delves into the recently adopted Act, where our presenters will discuss RMAI’s role in the drafting of the Act and, in particular, how the Act aligns with RMAI Receivables Management Certification Program standards.

Stay tuned for more webinars in 2024.

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

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

CRCP NEW
JulieAnne Castoire, Recovery Exchange, LLC
Chris Conway, Premium Asset Recovery Corporation (PARC)
Stephen Greco, Vertican Technologies, Inc
Seth Kelch, Consumer Adjustment Company, Inc. (CACI)
Rocky Landoll, Judgment Exchange
Kenneth Lewis, Andreu, Palma, Lavin & Solis, PLLC
Lindsay Love, National Credit Adjusters
Paul Montero, Exelero Corp.
Kala Parks, EverChain
Sachit Rajan, Charter Mercantile Pty. Ltd
Elizabeth Schaefer, Grassy Sprain Group, Inc.
Hunter Seide, HS Financial Group
Tayrin Tapia, Recovery Management Solutions
Kyle VonAllmen, Starmark Financial, LLC
Marlon Wilson, Credit Service of Logan

CRCP RENEWALS
Joe Adams, Hampton Pryor Group, Inc.
Ryan Banda, Denali Capital, LLC
Michael J. Adams, Integras Capital Recovery
Brian Becker, Scott & Associates, PC
Mike Boyle, C&E Acquisitions/ Diverse Funding Associates/DNF Associates
Michael Druckman, Pharus Funding
Patricia Druckman, Pharus Funding
Tim Elizarraraz, Scott & Associates, PC
Miles Fisher, Genesis Recovery Services, Inc.
Gretchen Frascella, US Mortgage Resolution LLC
Amanda Gazos, Bayview Solutions
Brian Glass, Halsted Financial Services, LLC
Kristin LoVallo, Orion Capital Solutions
David Maczka, C&E Acquisitions/ Diverse Funding Associates/DNF Associates
Kerstin McFarlane, River Heights Capital
Lee Morris, Capio
Andrea Rose, United Holding Group, LLC
Leo Stawiarski, Jr, LCS Financial
Jan Stieger, RMAI
Anne Thomas, Cavalry Portfolio Services
Jonathan Thompson, Transworld Systems, Inc.
Linh Tran, Quantumn3 Group
Franci Wayland, PRA Group
Sara Woggerman, ARM Compliance Business Solutions, LLC

CRB NEW
Abrahamsen Gindin, LLC
Credit Service of Logan
First Credit Services, Inc.
Grassy Sprain Group, Inc.
US Mortgage Resolution, LLC

CRB RENEWALS
Credit Corp Solutions
River Heights Capital
United Holding Group

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

Start the Process for Earning Certification for Your Business
The requirement for a pre-certification is officially in effect as of March 1, 2024. This requirement from the RMAI Receivables Management Certification Program now requires debt buyers, collection agencies, and collection law firms to undergo a pre-certification audit prior to submitting their application for business certification. Below are resources to begin the process to certification.

Authorized Audit Providers – Contact one of more of RMAI’s Authorized Audit Providers to get quotes on your pre-certification audit and full compliance audit, which will be required after your company has become certified.

7 Steps to Earn the Certified Receivables Business (CRB) Designation – for debt buyers, collection agencies, and collection law firms.

7 Steps to Earn the Certified Receivables Vendor (CRV) Designation – for brokers, process servers, defense law firms, and all other vendor organizations.
*This designation already requires a pre-certification audit.

For more information or to discuss the certification process in more detail, please contact Shannon Parod at [email protected] to set up a call.

Submit Your Application for Individual Certification
If you recently attended the Annual Conference in Las Vegas in February and completed education credits, you may be ready to become a Certified Receivables Compliance Professional (CRCP).

Requirements for CRCP Certification

• 24 credits of education (look back period is two (2) years)
  • Complete three (3) required courses
  • Chief Compliance Officers of a certified business must obtain at least 12 credits from in-person education.
  • All other employees of a certified or non-certified business can take all education online.
• Submit your application and proof of education credits
  • Email your application to [email protected]

View educational requirements for certified individuals.

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

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

2024 RMAI Executive Summit | August 6-8, 2024

Sponsor sales are open; contact Sylvia Done at [email protected] or call (916) 482-2462.

Registration will open April 1, 2024.

Thank you to our March 1, 2023 through March 12, 2024 Legislative Fund Contributors!

DIAMOND

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Velocity Portfolio Group, Inc.

TITANIUM

Blitt and Gaines, P.C.

EverChain

Second Round, LP

TRAKAmerica

PLATINUM

Cascade365 Family of Companies

InvestiNet, LLC

T & I Enterprises, LLC

Unifund CCR LLC

GOLD

Rausch Sturm, LLP

SILVER

Andreu, Palma, Lavin & Solis,  PLLC

DebtNext Software, LLC

FMA Alliance, Ltd

Klima, Peters & Daly, P.A.

National Credit Adjusters, LLC

Provana, LLC

Ragan & Ragan, PC

Velo Law Office

BRONZE

First Financial Portfolio Services, LLC dba FFAM360 Capital

BRASS

AACANet, Inc.

Acctcorp International, Inc.

Advancial Federal Credit Union

ARM Compliance Business Solutions LLC

Automated Collection Services Inc

Balbec Capital

Basham & Scott, LLC

Bayview Solutions, LLC

C & E Acquisition Group, LLC

Call Center Services International

CBE Companies

Central Portfolio Control, Inc

Collection Attorneys USA LLC

CompuMail Information Systems

ConServe

Cornerstone Licensing Services

Corporate Advisory Solutions, LLC

Credit Control, LLC

D & A Services, LLC

Debt Recovery Solutions, LLC

Dynamic Recovery Solutions

Exelero Corp.

FDR Alliance LLC

General Collection Co.

Genesis Recovery Services

George Brown Associates, Inc.

Glass Mountain Capital, LLC

Gordon, Aylworth & Tami, P.C.

Grassy Sprain Group, Inc

Halsted Financial Services, LLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Huntington Debt Holding LLC

Imagined.Cloud LLC

InDebted

Invenio Financial, a Phillips & Cohen Associates company

Investment Retrievers, Inc.

January Technologies, Inc.

Jefferson Capital Systems, LLC

Kino Financial Co., LLC

Lateral Technology

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

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Markoff Law LLC

Moss & Barnett, P.A.

Mountain Peak Law Group, PC

Murray Law Firm, P.C.

National Debt Holdings, LLC

NCB Management Services, Inc.

Nelson & Kennard

PCI Group Inc.

Pharus Funding, LLC

Plaza Services

Pressler, Felt and Warshaw, LLP

Prodigal

Quall Cardot, LLP

Quantum3 Group, LLC

Repay Realtime Electronic Payments

Resource Management Services, Inc.

Revenue Assistance Corporation dba Revenue Group

RevSpring

Robinson Hoover & Fudge, PLLC

SAM – Solutions for Account Management

Security Credit Services, LLC

Slovin & Associates

SMS Financial, LLC

Stillman Law Office

Stone, Higgs & Drexler

Superlative RM

Suttell & Hammer

TEC Services Group, Inc.

The Bureaus, Inc.

The Cadle Company

Tobin & Marohn

TriVerity, Inc.

Tromberg, Morris & Poulin, PLLC

Troy Capital, LLC

TrueAccord

Universal Fidelity LP

Vertican Technologies, Inc.

VoApps, Inc.

OTHER

Alliance Credit Services, Inc.

Barron & Newburger, P.C.

Burr & Forman LLP

CMS Services

Cohen & Cohen Law, LLC

Comtronic Systems, LLC

Connect International

Consuegra & Duffy, PLLC

Converging Capital, LLC

Convoke, Inc.

Dynamic Collectors, Inc.

Equabli, Inc

Equifax, Inc.

Gaskell & Giovannini, LLC

HS Financial Group, LLC

Martin Golden Lyons Watts Morgan PLLC

Miller and Steeno, P.C.

National Recovery Associates, Inc.

National Recovery Solutions, LLC

Orbita Capital Group, LLC

Palinode, LLC

POM Recoveries, Inc.

Poser Investments, Inc.

Receivables Management Association International

Roosen, Varchetti & Olivier, PLLC

Sandia Resolution Company, LLC

SCJ Commercial Financial Services

Smith Debnam Narron Drake Saintsing & Myers, LLP

Sonnek & Goldblatt, Ltd.

The Oakes Law Firm, LLC

Vargo & Janson, P.C.

WebRecon LLC

Womble Bond Dickinson