RMAI Update May 2026

The CFPB recently implemented multi-factor authentication (MFA) for new CFPB complaint portal accounts, requiring users to verify their identity through both email and mobile-device authentication (see April 21, 2026, RMAI Member Alert). MFA currently applies only to newly created accounts, not accounts that were established before the MFA rollout last month. RMAI has supported measures such as MFA to help reduce fraudulent and inaccurate complaint submissions, strengthen identity verification, and improve the integrity of complaint data while preserving access for consumers with legitimate concerns.

However, several limitations in the new system have been identified, including the ability for users to verify accounts using telephone numbers different from those originally associated with the profile. As a result, individuals misusing the complaint portal may continue operating through existing accounts without being subject to the enhanced verification measures. In addition, the system does not currently limit complaint volume on a per-account basis, which may allow continued abuse of the platform. While the implementation of MFA is a positive step forward, RMAI will continue working with the CFPB to help address these remaining concerns and strengthen the integrity of the complaint process.

Additionally, the CFPB has also updated the portal to encourage consumers to first dispute credit reporting issues directly with the credit reporting agency and allow 45 days for review before escalating the matter to the CFPB.

The FCC is seeking comments on offshoring call centers to address poor customer service, enhanced data security, and reduce illegal foreign robocalls. The call center offshoring proposal is part of a much larger, coordinated regulatory push by the FCC in 2026. Under the leadership of Chair Brendan Carr, the Commission is aggressively tackling national security vulnerabilities, data sovereignty, and telecom fraud by targeting foreign entities. RMAI will be submitting comments to communicate the interests of RMAI members.

The FCC is also expected to seek comment on proposed updates to “Know Your Customer” requirements. The Further Notice of Proposed Rulemaking (FNPRM) would introduce measures intended to strengthen STIR/SHAKEN as a tool to combat illegal calls. The proposal references enhanced scrutiny of high-volume callers, entities utilizing dialers, callers with low answer rates, and those generating elevated complaint volumes. RMAI will continue monitoring the proposal and evaluating its potential impact on the receivables industry.

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:

Alabama HB 351 [Chaptered] Effective: May 1, 2027 – This law is a comprehensive consumer data privacy proposal.  It excludes financial institutions and personal information governed by the Gramm-Leach-Bliley Act.  It does not contain a private right of act. [This law is consistent with what RMAI seeks in consumer data privacy legislation.]

California SB 1131 – This bill would make the following modifications to the Debt Collection Licensing Law: (1) require DFPI to perform examinations remotely unless specific exceptions requires an on-site examination; (2) allow DFPI to waive or perform a limited examination based on being able to access other independent audits and/or examinations that were recently performed by another state or the federal government or a nonprofit organization approved by the Commissioner; and (3) exempt the Debt Collection Advisory Committee from the public meetings act so DFPI can get advice from industry experts prior to rulemaking (similar to other licensing boards), which reflects the original legislative intent of this committee. [This bill was introduced at the request of RMAI.]

Colorado SB 26-139 – This bill will replace the current artificial intelligence law that was enacted in 2024.  The bill 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.  [The bill has passed both chambers and is waiting to be sent to the Governor. The legislation would go into effect January 1, 2027, if enacted. RMAI is neutral on this legislation.]

Vermont HB 385 – This bill would establish protections and remedies for victims of a debt arising from intimidation, violence, or domestic abuse. The bill 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 legislation 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. [This bill has passed both chambers and is waiting to be sent to the Governor. Through advocacy, testimony, and coordinating with the Vermont Bankers Association, RMAI has been able to obtain several favorable amendments.]

Washington State Supreme Court Holds Hospital’s Notice Requirement Applied to Assignee Collection Agency
Preston v. SB&C, Ltd., No. 104182-9, 2026 Wash. LEXIS 281 (Apr. 30, 2026)

A consumer incurred medical expenses, and the hospital assigned its claim to a collection agency which filed a lawsuit to collect the debt.  Although the consumer’s income likely would have qualified her for charity care, neither the hospital nor the collection agency notified her of the potential eligibility.

Washington law requires a hospital “to determine whether a patient is eligible for charity care and, if so, assist them in applying for charity care coverage. RCW 70.170.060(5). This screening must precede collection efforts directed at the patient.”

Additionally, “hospital billing statements and other written communications concerning billing or collection of a hospital bill by a hospital must include the following or a substantially similar statement prominently displayed on the first page of the statement in both English and the second most spoken language in the hospital’s service area: You may qualify for free care or a discount on your hospital bill, whether or not you have insurance. Please contact our financial assistance office at…(website)… and …(phone number)….” RCW 70.170.060(8)(a).

After the collection agency obtained a judgment against the consumer, the consumer filed a lawsuit in state court alleging the agency violations of Washington’s Collection Agency Act (“CAA”), Consumer Protection Act (“CPA”), and the federal Fair Debt Collection Practices Act. She claimed “[t]he agency’s failure to give notice regarding the availability of charity care is unfair and deceptive under the Washington CPA… [and] that SB&C falsely represented the character, amount, and legal status of the debt it sought to collect in violation of the FDCPA.” The agency removed the matter to federal court and, among other things, moved to certify a question to the Supreme Court of Washington, which was granted.

On appeal, the Supreme Court of Washington considered whether “the requirements of RCW 70.170.060(8)(a) apply to a collection agency collecting on a hospital debt, as opposed to a hospital itself?”  It came to the following conclusion:

We answer yes and hold that under the plain language of RCW 70.170.060(8)(a) and the public policy of the charity care act, “other written communications concerning billing” applies to collection agencies collecting on hospital debt. Here, the failure to provide notice of charity care when collecting on hospital debt violates the public policy of the charity care act and may provide evidence of a non-per-se CPA violation.

Here, although there was no per se violation of the statute, the Court explained that “the rule our cases establish is that an unfair or deceptive act or practice under the CPA may be predicated on a per se violation of a statute or an unfair act or practice not regulated by statute but constituting a violation of the public interest.”

The court reviewed the legislative history of the Washington Charity Care Act and found that the purpose of the charity care notice was to serve the public interest. Thus, failure to provide the notice constituted an unfair or deceptive act or practice.

The agency argued that the CPA should not apply since the CAA is specific to collection agencies and has a “redundant” notice requirement, RCW 19.16.250(29)(a), though that notice requirement had not yet been enacted at the time of the events described in the lawsuit.

In response, the Court explained:

Where conduct is beyond the scope of the CAA, that does not mean it is exempt from suit under the broader scope of the CPA… The requirements of the charity care act do not disappear on assignment.  Rather, the assignee “steps into the shoes” of the assignor and the assignment carries with it all applicable statutory rights and liabilities… as the hospital’s assignee, the statutory duty to provide notice of charity care passes to the collection agency.

Eleventh Circuit Affirms Dismissal of Consumer’s Complaint Containing False AI-Generated Citations
Williamson v. TransUnion LLC, No. 25-13045, 2026 U.S. App. LEXIS 12852 (11th Cir. May 4, 2026)

A consumer filed a pro se complaint in federal court alleging several consumer reporting agencies (“CRAs”) violated the federal Fair Credit Reporting Act.  After the CRAs filed their answers, the consumer filed numerous motions and a memorandum of law supporting his motion for summary judgment.

The consumer’s pleadings included citations to nonexistent cases, which the consumer argued were “inconsequential” errors.  The trial court ordered the consumer “to show cause why he should not be sanctioned,” but didn’t impose sanctions at that time.  One month later, the consumer filed additional pleadings that “cited to nonexistent cases, misquoted cases, and misrepresented holdings.”

At the second show cause hearing, the consumer “admitted that some of the cases he cited did not exist, and that he had found them using artificial intelligence,” and that “he did not follow the Local Rules because they were confusing to him as a pro se litigant and he could not locate them.”  While the trial court was considering the arguments made at the hearing, the consumer filed additional “frivolous” documents.  Unsurprisingly, the consumer’s complaint was dismissed with prejudice and the consumer appealed.

The U.S. Court of Appeals for the Eleventh Circuit, in an unpublished opinion, affirmed the trial court’s ruling, explaining that “[t]he record supports the district court’s finding that [the consumer’s] misconduct, which included repeated ignorance of court orders warning him against citing to nonexistent cases, misquoting cases, and misstating their holdings to make them support his position in countless vexatious filings, was willful, and that lesser sanctions would have been inadequate to address this misconduct.”

RMAI Continues Its Advocacy
RMAI actively monitors legislation across the country to protect your best interests. Recently, RMAI has opposed California AB 2746, (which was successfully stopped due to RMAI testimony). RMAI is currently fighting for a favorable outcome in other state proposed legislation including Colorado SB 26-138, NY S. 4271, and California SB 1131. Your donations make a difference and enable RMAI to continue these important advocacy efforts.

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. Click here to see a list of current contributors on the right-side bar.

Upcoming Webinars

Register for our June 2^nd webinar, Call Model Reset: Adapting to Real Conversations. Our presenters will walk through a sample call model structure, and show how it can be taught in a way to align better with agent skillsets, consumer expectations, and current regulations.

Recorded Webinars

Recorded on May 14, 2026, you can register for Ask Me Anything: Consumer Financial Law with Don Maurice. Don Maurice answered questions submitted by attendees on a wide range of topics, including: Federal & State Regulations, Litigation Trends, Enforcement Priorities, Compliance Challenges and Ethics & Legislation.

Recorded on April 28, 2026, you can register for State Oversight in an Era of Federal Deregulation. Our presenters unpacked how states are asserting their authority, what debt buyers and collectors should expect from those efforts, and the practical strategies companies can adopt to stay ahead.

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

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

CRCP New
Georgi Kortava, Central Portfolio Control
Susan Lawlor, Southwood Financial
Troy Marquis, Central Portfolio Control
David Naylor, Sphinx Consultants
Dominick Nuzzo, Top Line Collectors
Tyler Peterson, Unifin
Luis Real, Collection Attorney Professional Placement Services/Galaxy Capital Acquisitions
Berkley Robinson, Sphinx Consultants
Luke Stuckey, Ragan & Ragan
Jackson Walker, Resurgent Capital Services

CRCP Renewals
Julie Brown, FH Cann & Associates
Haley Courville, Velocity Portfolio Group, Inc.
Shari Fuller, Crown Asset Management, LLC
Shelly Gensmer-Cleek, Unifund CCR LLC
Tracey Gibson, Viking Client Services
Elexis Harris, Shepherd Outsourcing
Cynthia Jeffrey, Keith D. Weiner & Associates Co., L.P.A.
Todd Lansky, Resurgence Capital
Rebekah Luebcke, Invenio Financial, a Phillips Cohen Associates Company
Nick Michael, CBE Group
Angela Reed-Becker, Denali Capital
Linda Varner, Crown Asset Management

CRB New
FMA Alliance
National Enterprise Systems
Radius Global Solutions

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

For information on earning your CRCP, CRB or CRV certification, contact Shannon Parod-Tsui @ [email protected] or call 916-482-2590.

View our full list of certification resources.

Executive Summit Early Registration Ends Soon
Don’t miss the deadline to receive the Early Member Rate when you register for the 2026 Executive Summit – June 11^th, 2026 is the last day to register to take advantage of the best deal of the summer! Network with your industry peers while you enjoy the beauty of the Skamania Lodge in Stevenson, Washington. Don’t forget, you can earn credits for both the Certified Receivables Compliance Professional (CRCP) designation and Continuing Legal Education (CLE) at this event.  Register today to make sure you don’t miss out!

Check Out RMAI’s Resource Library
Remember that the RMAI Resource Library is here for you! Whether you’re looking for certification, compliance, or membership resources, or even White Papers and advertising guidelines, all the information you’ll need is available in our easy to navigate Resource Library.

Welcome, New Members

• Moveo AI | NY
• Transatlantic Translations LLC | NY
• RevNow LLC | Fl
• Global Lending Services LLC | SC
• Aristocrat Process Serving | KS
• MOBBtek Capital LLC | CA
• Hawes Group | OR

For a complete list of RMAI members, login to check out the Member Directory.

2026 RMAI Executive Summit | August 4-6, 2026

LEGISLATIVE FUND CONTRIBUTORS MAY 5, 2025 – MAY 11, 2026

DIAMOND

Absolute Resolutions Corp.

Cavalry Investments, LLC

Midland Credit Management

PRA Group, Inc.

Resurgent Holdings, LLC

Velocity Portfolio Group, Inc.

TITANIUM

Financial Recovery Services, Inc.

Stenger & Stenger P.C.

TRAKAmerica

PLATINUM

Cascade365 Family of Companies

Garnet Capital Advisors, LLC

Halsted Financial Services, LLC

Pharus Funding, LLC

Plaza Services

Rausch Sturm, LLP

T & I Enterprises, LLC

TrueAccord

SILVER

D & A Services, LLC

DebtNext Software, LLC

InvestiNet, LLC

Jefferson Capital Systems, LLC

National Credit Adjusters, LLC

Pressler, Felt and Warshaw, LLP

Security Credit Services, LLC

Velo Law Office

BRONZE

Central Portfolio Control, Inc

Couch Lambert

Mountain Peak Law Group, PC

Stillman Law Office

Tromberg, Miller, Morris & Partners, PLLC

Troy Capital, LLC

BRASS

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

CBE Companies

CNG/Axcess Financial Services, Inc.

Collection Attorneys USA LLC

CompuMail Information Systems

Connect International

ConServe

Cornerstone Licensing Services

Cozen O’Connor

Credit Brokers LLC

Credit Control, LLC

Crown Asset Management, LLC

Exelero Corp.

FDR Alliance LLC

Floatbot, Inc

FLOCK Specialty Finance

FMA Alliance, Ltd

FMS, Inc.

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Grassy Sprain Group, Inc

Guglielmo & Associates, PLLC

Invenio Financial, a Phillips & Cohen Associates company

Kino Financial Co., LLC

Klima, Peters & Daly, P.A.

Landmark Strategy Group, LLC

Latitude Software

LexisNexis Risk Solutions

Mandarich Law Group LLP

Markoff Law LLC

MauriceWutscher LLP

National Enterprise Systems, Inc.

National Loan Exchange, Inc.

National Recovery Associates, Inc.

NCB Management Services, Inc.

NICE

Nutun CX (PTY) LTD

Nuvei Technologies Inc.

Orbita Capital Group, LLC

PCI Group Inc.

Phin Solutions, LLC

Premier Bankcard

Premium Asset Recovery Corp (PARC)

Primeritus Financial Services, Inc.

Quality Acceptance

RevSpring

Risk Strategies

Robinson Hoover & Fudge, PLLC

Roosen, Varchetti & Olivier, PLLC

SAM – Solutions for Account Management, Inc.

Scott & Associates, PC

Shepherd Outsourcing, LLC

Stone, Higgs & Drexler

Suttell & Hammer

The Cadle Company

The Forwarders List of Attorneys

The Moore Law Group

The Oakes Law Firm, LLC

Tobin & Marohn

Troutman Pepper Locke

VeriFacts, LLC.

Vertican Technologies, Inc.

Womble Bond Dickinson

World Credit Recovery LLC

Yrefy, LLC

OTHER

Bedard Law Group, P.C.

Cohen & Cohen Law, LLC

Consuegra & Duffy, PLLC

Converging Capital, LLC

Convoke, Inc.

Credit Management Corporation

D1AL

Debt Sales Partners

First National Collection Bureau

ForgiveCo PBC Inc

Frost Echols LLC

Hilco Receivables, LLC

Indiana Receivables, Inc.

Kaufman Dolowich

Kompato AI Inc.

National Recovery Solutions, LLC

Poser Investments, Inc.

Pro Forma Inc

Rossman Kirk, PLLC

SCJ Commercial Financial Services

Smith Debnam Narron Drake Saintsing & Myers, LLP

Sonnek & Goldblatt, Ltd.

Superlative RM

The Law Offices of Ronald S. Canter, LLC

UHG I LLC

Vargo & Janson, P.C.