RMAI Update May 2024

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, Connecticut, Maine, Michigan, New York, New York City, Oregon, and Rhode Island. RMAI has also provided a financial contribution to a Nevada coalition fighting two ballot initiatives and the North Carolina Creditors Bar who is fighting a medical debt bill. 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 SB 1061 – This bill would prohibit 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, products, or devices, unless that plan allows for deferred interest purchases of a medical service, product, or device. A similar exemption is provided for loans secured by real property. [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. RMAI is concerned that the current exemption for credit cards and real property are not broad enough.]

Connecticut SB 395 [Chapter 6] Effective: July 1, 2024 – The law prohibits any health care provider or any collection entity doing business in this state from reporting any portion of a medical debt to a credit rating agency for use in a credit report. A health care provider doing business in this state shall include in any contract entered into with a collection entity on and after July 1, 2024, for the purchase or collection of medical debt, a provision that prohibits the reporting of any portion of such medical debt to a credit rating agency. “Medical debt” means an obligation or alleged obligation of a consumer to pay any amount related to the receipt by the consumer of health care goods or health care services. “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 charges related to health care goods or health care services. [RMAI attempted to obtain a narrower definition of “medical debt,” as well as a broader exemption that included home equity loans, secured loans, and general-purpose lines of credit issued by banks. Unfortunately, the sponsor was not open to compromise.]

Maine LD 2115 [Chapter 663] Effective: August 9, 2024 – This law amends the Maine Fair Debt Collection Practices Act to prohibit debt collectors from charging interest and fees on medical debt as well as any false, deceptive, or misleading representation or implication that interest and fees will accumulate on the debt principal when the debt collector knows the debt is medical debt. The law also prohibits debt collectors from pursuing litigation to compel payment of a medical debt without first sending a consumer notice indicating that litigation will not be pursued when the debt collector knows the consumer’s income is at or lower than 300 percent of the federal poverty guidelines, as defined by the federal Office of Management and Budget. The debt collector must allow the consumer at least 30 days to provide such proof. The law defines “medical debt” as “debt arising from health care services, including dental services, or health care goods, including products, devices, durable medical equipment and prescription drugs.” Exempted from this definition: (1) general-purpose credit cards, (2) home equity loans, (3) general-purpose lines of credit, (4) secured debt, and (5) veterinary debt. However, there is an exception that will pull into the definition of “medical debt” credit cards that were issued solely for the payment of health care services. [RMAI through lobbying efforts was able to delete a provision that required hospitals to offer consumers the opportunity to purchase their account for the same price that the hospital was seeking to sell their account to a debt buyer. RMAI also drafted and successfully inserted the exemption language for medical debt.]

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 recently received several amendments proposed by the sponsor which are currently under review.]

New York AB 4088-B – 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). This bill would exempt law firms from maintaining a license as a debt collector. A similar bill has been introduced in the Senate. [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.]

New York SB 8307, Part O, Section 3 [Chapter 57] Effective: October 20, 2024 – The following provisions were enacted in the State Budget:

• Requires general hospitals to have policies and procedures that prohibits the sale of medical debt accumulated related to indigent care to a third party, unless the third party explicitly purchases such medical debt in order to relieve the debt of the patient. Such policies and procedures shall prohibit a hospital from commencing a legal action related to the recovery of medical debt or unpaid bills against patients with incomes below four hundred percent of the federal poverty level.
• Prohibits a hospital or health care provider from requiring credit card preauthorization or requiring the patient to have a credit card on file prior to providing emergency or medically necessary medical services to such patient.
• Requires hospitals and health care providers to notify all patients about the risks of paying for medical services with a credit card. Such notification shall highlight the fact that by using a credit card to pay for medical services, the patient is forgoing state and federal protections that regard medical debt.

[RMAI requested alternative language which did not ban the sale of medical debt due to the association’s longstanding policy against such provisions. While the provision remained, it was narrowed to indigent care at general hospitals so it will have a small footprint within a single asset class.]

Oregon SB 1595 [Chapter 100] Effective: April 4, 2024; however, changes to writs of garnishment and writs of execution apply to those issued on or after January 1, 2025 – This law, among other things: (1) phases-in a wage garnishment exemption increase from the current $254 a week to 30x minimum wage (approximately $24,000 annually); (2) increases the auto exemption from $3,000 to $10,000; (3) increases various personal household property exemptions; (4) increases the homestead exemption from $40,000 to $150,000; and (5) increases 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.]

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.]

Arizona Update

On April 30, 2024, the Arizona Court of Appeals affirmed the constitutionality of the “Predatory Debt Collection Act” (Proposition 209 from 2022) in the case Arizona Creditors Bar Association v. State of Arizona.

Prop 209 was a ballot initiative approved by voters in November 2022 that: (1) decreased the portion of a debtor’s weekly disposable earnings that is subject to debt collection actions to the lesser of 10% of disposable earnings, or 60 times the highest applicable federal, state or local minimum wage; (2) increased the homestead exemption from $150,000 to $400,000; (3) increased the exemption on household furniture, furnishings, goods and appliances increased from $6,000 to $15,000; (4) increased the exemption on the debtor’s equity in one motor vehicle increased from $6,000 to $15,000, or if the debtor or debtor’s dependent has a physical disability, from $12,000 to $25,000; and (5) capped the interest rate on medical debt to the lesser of 3% or the annual rate equal to the weekly average one-year constant maturity treasury yield, as published by the Federal Reserve Board.

Soon after the Act’s implementation, Arizona courts began reaching different conclusions due to confusing language within the Savings Clause (i.e. a clause in a statute which exempts something from the statute’s operation) as to what interest rates would apply based on differing factual scenarios. This was the issue that was raised in contesting the Act.

In ruling, the Court of Appeals did recognize that “there will undoubtedly be difficult questions about prospective application of the Act, including those involving wage garnishment proceedings.” But in answering these questions, courts will need to apply the framework set forth in the Saving Clause and “allow courts to work through the meaning and application of the Saving Clause in the context of as-applied disputes involving concrete factual scenarios.”

Regardless of the outcome, RMAI would like to commend the Arizona Creditors Bar Association for their efforts in spearheading opposition to Prop 209 and then fighting the Act within the courts. While it was not the result the industry had hoped for, it was certainly not due to lack of effort. RMAI was a financial contributor to the efforts of the Arizona Creditors Bar Association.

Ninth Circuit Finds Arbitration Clause in Credit Card Agreement Enforceable by Debt Buyer
Charles v. Portfolio Recovery Assocs., LLC, No. 22-35613, 2024 U.S. App. LEXIS 9624 (9th Cir. Apr. 18, 2024)

A consumer’s credit card account was sold to a debt buyer that instituted a collection action to recover the outstanding balance.  In response, the consumer filed a putative class action alleging violations of the Fair Debt Collection Practices Act.  The debt buyer then “moved to compel arbitration and stay the proceedings, relying on an arbitration clause contained in [the consumer’s] credit card agreement.”  The trial court granted the motion, the matter was arbitrated, and the action was dismissed without prejudice.  The consumer appealed.

The consumer first argued that for the arbitration agreement to be enforceable, mutual assent to the agreement must be in writing, i.e., signed by the parties.  The U.S. Court of Appeals for the Ninth Circuit, in an unpublished opinion, disagreed.  Referring to the applicable choice of law, the Court noted that “Ohio courts have held that a credit card agreement is enforceable ‘whereby the issuance and use of a credit card creates a legally binding agreement,’” and that the consumer’s “use of his credit card and account constitute[d] assent to the credit card agreement, including the arbitration clause contained within it.”

The consumer also argued that the debt buyer purchased only his debt, not the contract rights.  Again, the Court disagreed because the sale agreement transferred to the debt buyer “all rights, title, and interest” in the consumer’s account.

Finally, the consumer asserted that the alleged FDCPA violations fell outside the scope of the arbitration clause.  The Court easily resolved this in favor of the debt buyer because the clause broadly covered “’any claim, dispute, or controversy’ that ‘arises from or relates to’ [the consumer’s] credit card agreement or his account and the credit issued thereunder.”

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

Third Circuit Holds (Again) that Confusion Alone is Insufficient for Article III Standing
Osorio v. Transworld Sys., No. 22-2013, 2024 U.S. App. LEXIS 10171 (3d Cir. Apr. 26, 2024)

A consumer received a collection letter that she alleged failed to specifically state whether the creditor referenced was the current creditor or the original creditor.  As a result, she claimed the letter “created confusion,” and left her “uncertain as to whom the debt was owed.”  She then filed a putative class action against debt collector for violations of the Fair Debt Collection Practices Act.  The action was dismissed for failure to state a claim, and the consumer appealed.

In a non-precedential opinion, the U.S. Court of Appeals for the Third Circuit had little difficulty determining that the consumer lacked Article III Standing.  The Court relied largely on its decision in Huber v. Simon’s Agency, Inc., 84 F.4th 132 (3d Cir. 2023), in which it “analyzed the plaintiff’s alleged injury under this rubric where the statutorily required information was included in the debt collector’s notice but in a manner the plaintiff allegedly found confusing.”

In that case the Court “explained that, although a purported FDCPA violation could easily lead to the type of injury recognized by the common-law tort of fraudulent misrepresentation, a debtor’s ‘confusion, without more,’ is not enough.”

Here, the consumer alleged only confusion, and the Third Circuit vacated the trial court’s order, which dismissed the complaint for failure to state a claim and instructed it to instead dismiss the complaint for lack of Article III standing.

Eleventh Circuit Holds FCRA Claim Requires Disputed Information be Objectively and Readily Verifiable
Holden v. Holiday Inn Club Vacations Inc., Nos. 22-11014, 22-11734, 2024 U.S. App. LEXIS 9986 (11th Cir. Apr. 24, 2024)

Several consumers purchased timeshares, financed through a timeshare company, and each stopped making payments.  They interpreted their respective timeshare agreements to automatically cancel in that scenario.  The timeshare company disagreed and reported the debts to a credit reporting agency (“CRA”), after which the consumers individually filed lawsuits against the company alleging inaccurate reporting and failure to reasonably investigate their disputes in violation of the Fair Credit Reporting Act, 15 U.S.C. § 1681s-2.

The trial court in each case granted summary judgment for the company “finding the alleged inaccuracies were legal disputes and therefore not actionable under § 1681s-2.”  The consumers appealed and the cases were consolidated.

On appeal, the U.S. Court of Appeals for the Eleventh Circuit explained that “Consumers have no private right of action against furnishers for reporting inaccurate information to [consumer reporting agencies] regarding consumer accounts. Instead, the only private right of action consumers have against furnishers is for a violation of § 1681s-2(b).”

The Court further explained that pursuant to that section, “[w]hen a furnisher is notified of such a dispute, the furnisher must (1) conduct an investigation with respect to the disputed information; (2) review all relevant information provided by the consumer reporting agency; and (3) report the results of the investigation to the consumer reporting agency. . . If the furnisher finds, following an investigation, that an item of information disputed by a consumer is incomplete, inaccurate, or cannot be verified, the furnisher must either modify, delete, or permanently block reporting of that information.”

However, the court added that “when evaluating whether a report is accurate under the FCRA, we look to the objectively reasonable interpretations of the report.  Putting this altogether, a report must be factually incorrect, objectively likely to mislead its intended user, or both to violate the maximal accuracy standard of the FCRA.”

Here, the problem was that Florida state courts had reached “conflicting conclusions about whether [similar timeshare] default provisions excused a consumer’s obligation to keep paying.”  That being the case, the consumers’ “alleged inaccurate information [was] not objectively and readily verifiable because it stems from a contractual dispute without a straightforward answer.”

While the Court declined to adopt “a bright-line rule that only purely factual or transcription errors are actionable under the FCRA,” it concluded, that “in determining whether a claimed inaccuracy is potentially actionable under § 1681s-2, a court must determine, inter alia, whether the information in dispute is objectively and readily verifiable.”  Thus, the decision of the trial court was affirmed.

RMAI Continues Its Advocacy
RMAI is continuing its work on the legislative front, with medical debt being the biggest issue affecting the receivables management industry. States proposing legislation include California SB 1061, Connecticut SB 395, Illinois SB 2933, Massachusetts HB 4274, and Minnesota SF 4065. We need your help to continue to fight this legislation, and your donations are greatly appreciated.

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 Webinars
Register for our May 22^nd webinar, sponsored by QBE, Your Digital Collections Questions Answered.  Our presenters will come together to answer your email, text, and other digital collection questions.

Register for our May 29^th Transunion Sponsored Webinar: Strategies for Effectively Evaluating, Pricing, Winning and Profiting from Potential Portfolios. Our presenters will focus on new methods, data elements and strategies around using data to better predict potential liquidity of a portfolio and more, in this comprehensive review on best practices in our constantly evolving industry.

Register for our June 11^th webinar, New Guidance on Credit Reporting and Reasonable Investigations.  Our presenters will discuss emerging trends, compliance strategies, and the CFPB’s evolving expectations for credit furnishers.

Register for our June 25^th webinar, sponsored by Transunion, Navigating Advocacy: Unveiling Key Resources and Myths in 3^rd Party Collections.  Members of RMAI’s Industry Research Working Group unveil their top reference materials and talking points crucial for advocating for the 3^rd Party Collections Industry.

Recorded Webinars
Recorded on March 26^th, you can register for Navigating Complicated Compliance & Technology in the Service of Process.  In this webinar, you will learn 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 on April 23^rd, you can register for Due Diligence Tips – Acquiring and/or Financing a Debt Buyer in Today’s Market.  In this webinar, our presenters will discuss key areas of due diligence to focus on acquiring and/or financing a consumer debt buying business in today’s market.

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 renewed Certified Receivables Business (CRB)!

CRCP New
Nicholas Capezza, Bayview Solutions
Claire Taulbee, Cavalry Portfolio Services
Linda Varner, Crown Asset Management
Terry Young, George Brown Associates

CRCP Renewals
Julie Brown, F.H. Caan & Associates
Debra Ciskey, ARM Compliance Business Solutions
Jennifer Cristao, 640 Financial Group
Jenny DeHoyos, Capio
Crystal Duplay, Levy & Associates
Nicole Gelinas, Cohen & Cohen Law
Jeffrey Hasenmiller, D&A Services
Cynthia Jeffrey, Keith Weiner & Associates
Adam Katz, NMRC
Jill Katz, NMRC
Tom Ludwig, National Loan Exchange
Rebekah Luebcke, Crown Asset Management
Dan McCusker, FFAM360
Brittan Robinson, Stone, Higgs & Drexler
Andrew Roskam, AcctCorp International
David Warshaw, Pressler, Felt & Warshaw
Brian Williams, Crown Asset Management

CRB Renewals
Dyck O’Neal
Hilco Receivables
LCS Capital

REMINDER FOR ASSOCIATE DEBT BUYERS: SCHEDULE YOUR PRE-CERTIFICATION AUDIT NOW TO MEET THE JANUARY 1, 2025, DEADLINE TO BECOME CERTIFIED

We are fast approaching the half-way point of 2024 and want to remind all our Associate Debt Buyer Members, who joined prior to 2024, to schedule their pre-certification audit, which is a requirement to apply for certification. Contact one or more of RMAI’s Authorized Audit Providers to get quotes on both your pre-certification audit as well as the full compliance audit, which will be required after a year and half of your company becoming certified.

RMAI and the Board are here to assist you throughout the certification process. Whether you have questions or need guidance, we have resources to help which can be accessed by visiting RMAI’s Certification Program & Education webpage.

Certification Resources
CRB Timeline
7 Steps to Certification – Business
CRCP Timeline
7 Steps to Certification – Individual
Sample Policies and Procedures for Debt Buyers
Recorded Webinar – Starting or Continuing Your Certification Journey

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

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

For questions about certification, contact Shannon Parod direct at 916-482-2590 or email [email protected].

Refer a Friend!

Executive Summit Early Registration Ends Soon
Don’t miss the deadline to receive the Early Member Rate when you register for the 2024 Executive Summit before June 11^th, 2024. Network with your industry peers while you enjoy the lovely Hyatt Regency Tamaya in Santa Ana Pueblo, New Mexico. The opportunities for sponsorship at Executive Summit are a great way to maximize your membership! You can contact Sylvia Done for more information about becoming a sponsor today. This year’s Executive Summit will offer credits for both the Certified Receivables Compliance Professional (CRCP) designation and Continuing Legal Education (CLE), you’re not going to want to miss it. Register now.

2024 RMAI Executive Summit | August 6-8, 2024

Please note, the RMAI office will be closed May 27, in observance of Memorial Day.

Thank you to our May 1, 2023 through May 13, 2024 Legislative Fund Contributors!

Diamond

Cavalry Investments, LLC

Crown Asset Management, LLC

Portfolio Recovery Associates, LLC

Titanium

EverChain

Platinum

Cascade365 Family of Companies

InvestiNet, LLC

Unifund CCR LLC

Gold

Klima, Peters & Daly, P.A.

National Credit Adjusters, LLC

Velo Law Office

Bronze

Blitt and Gaines, P.C.

First Financial Portfolio Services, LLC dba FFAM360 Capital

Security Credit Services, LLC

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

DebtNext Software, LLC

Exelero Corp.

FDR Alliance LLC

Financial Recovery Services, Inc.

FMA Alliance, Ltd

General Collection Co.

Genesis Recovery Services

Glass Mountain Capital, LLC

Grassy Sprain Group, Inc

Halsted Financial Services, LLC

Harvest Strategy Group, Inc.

Huntington Debt Holding LLC

Imagined.Cloud LLC

InDebted

Invenio Financial, a Phillips & Cohen Associates company

Investment Retrievers, Inc.

Jefferson Capital Systems, LLC

Kino Financial Co., LLC

Lateral Technology

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

Lockhart, Morris & Montgomery, Inc.

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

Shepherd Outsourcing, 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 & Partners, PLLC

Troy Capital, LLC

TrueAccord

Universal Fidelity LP

Velocity Portfolio Group, Inc.

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.

Equabli, Inc

Equifax, Inc.

Gaskell & Giovannini, LLC

Hinshaw & Culbertson

HS Financial Group, LLC

Martin Golden Lyons Watts Morgan PLLC

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

Sonnek & Goldblatt, Ltd.

The Oakes Law Firm, LLC

Vargo & Janson, P.C.

WebRecon LLC

Womble Bond Dickinson