RMAI Update November 2023

Capitol Hill
Below is a recap of activities on Capitol Hill.  It is important to note that the three pieces of introduced legislation listed below do not have bipartisan support and therefore, RMAI does not believe they have any chance of passage. 

On Thursday, November 2^nd, the Senate Banking Committee held a hearing entitled Ensuring Financial Protection for Servicemembers, Veterans, and Their Families. Senators sought to better understand what was characterized as the predatory lending and financing practices disproportionately targeted at servicemembers and their families, as well as the recourse for such victims. Discussion in this regard centered on the structure of the federal government’s response apparatus — particularly, the Consumer Financial Protection Bureau (CFPB) and its Office of Servicemember Affairs (OSA). Persistent issues discussed included the assessment of incorrect and unwarranted charges and, often concordantly, undue medical debt and its consequences for credit reporting and security clearance. Most senators applauded the CFPB’s work and searched for ways to extend protections. Credit reporting issues and debt collection legislation were also highlighted.

In late October, several Senate Democrats joined Republicans to vote 53-44 on a resolution under the Congressional Review Act (CRA) to overturn the CFPB’s small business data rule. The rule required lenders to collect demographic data from small businesses when they applied for credit, such as whether the firm was owned by women, people of color, or members of the LGBTQ+ community. The rule was opposed by the banking industry and referred to as an intrusion on business owners’ privacy by Sen. John Kennedy (R-LA), who introduced the resolution. The resolution will now need to be voted upon by the House, where it is likely to pass. President Biden has not publicly commented on it, though we expect he may veto the CRA resolution if it passes the House.

On October 20, Sen. Jeff Merkley (D-OR) and Rep. Katie Porter (D-CA) reintroduced The Medical Debt Relief Act (S. 3103/H.R. 6003) to amend the Fair Credit Reporting Act to prohibit the inclusion of medical debt on a consumer report, and for other purposes. According to Sen. Merkley’s press release, “the Medical Debt Relief Act would ban all medical debt from appearing on credit reports and prohibit creditors from considering Americans’ medical debt in their decisions on whether to extend them credit.” The bills are cosponsored by four Senate Democrats and 27 House Democrats, respectively. The full text is available here.

On October 19, Sen. Bill Hagerty (R-TN) and Rep. French Hill (R-AR) reintroduced the Federal Reserve Loss Transparency Act (S. 3095/H.R. 5993), a bill to amend the Consumer Financial Protection Act of 2010 to clarify the funding of the Consumer Financial Protection Bureau. According to Sen. Hagerty’s press release, the legislation “is about restoring transparency and good governance at the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve (the Fed).” The bill will prevent the Fed from transferring money to the CFPB if the Fed incurs an operating loss. The full text of the bill is available here.

On September 22, Rep. Madeleine Dean (D-PA) introduced the Fair Debt Collection Practices for Servicemembers Act (H.R. 5674) to amend the Fair Debt Collection Practices Act in order to provide enhanced protection against harassment of members of the Armed Forces by debt collectors, and for other purposes. Sen. Raphael Warnock (D-GA) introduced companion legislation in the Senate in July 2023 (S. 2396). More information is available in the full text of the bill here.

Biden Administration
On November 7, the CFPB issued a Notice of Proposed Rulemaking (NPRM) entitled Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications. The NPRM would ensure that large nonbank companies who offer services such as digital wallets and payments apps and handle more than 5 million transactions per year are brought under CFPB oversight and adhere to the same rules as large banks, credit unions, and other financial institutions that are regulated by the CFPB. Public comments on the proposal are due by January 8, 2024. More information is available in the press release here, Director Chopra’s remarks here, and the full text of the rulemaking here.

On November 3, President Biden issued the long-awaited Executive Order (EO) on artificial intelligence (AI), entitled Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. The EO itself is available here, and a one-page fact sheet issued by the White House is available here. The document is the longest substantive EO issued by this administration. It has far-reaching implications across many industries and issues, including consumer protection, data privacy, and credit analyses. More information is available in the K&L Gates Policy and Regulatory Alert on the EO here.

On October 25, the CFPB released its sixth biennial report on the state of the consumer credit card market, known as the 2023 CARD Act report. The report examines trends by card type and credit score tier, as well as market dynamics and industry profitability. Several trends identified in the report include:

• “Credit card company profits remain high;
• APRs continue to rise far above the cost of offering credit;
• Consumers charged $130 billion in interest and fees;
• Consumers were charged $14.5 billion in late fees, returning to pre-pandemic levels and up from $11.3 billion in 2021;
• More borrowers getting caught in debt; and
• Consumers with revolving balances were charged more in interest and fees than they earned in rewards”

More information is available in the press release here and the full report here.

Regulatory Update
On October 19, the CFPB released a Notice of Proposed Rulemaking entitled Required Rulemaking on Personal Financial Data Rights. This proposal would restrict how financial institutions handle consumer data, and makes several suggestions as part of the Biden Administration’s plan to reinforce consumer protection. According to its official summary, the proposal “would require depository and nondepository entities to make available to consumers and authorized third parties certain data relating to consumers’ transactions and accounts; establish obligations for third parties accessing a consumer’s data, including important privacy protections for that data; provide basic standards for data access; and promote fair, open, and inclusive industry standards.” Public comments on the proposal are due by December 29, 2023. The full text of the proposed rule is available here.

On September 22, the CFPB put out a consumer advisory noting that “people have the right to cancel credit repair services.” Specifically, the advisory states, “People working to improve their credit situations can feel trapped. Some companies use this stressful situation to take advantage of consumers by selling a promise of credit repair services. However, these services often charge fees without delivering on their promises.” More information is available here.

On September 21, the CFPB announced that it is beginning the rulemaking process to formally remove medical bills from credit reports. If finalized, the rulemaking would:

• “Remove medical bills from consumers’ credit reports;
• Stop creditors from relying on medical bills for underwriting decisions; and
• Stop coercive collection practices.”

The Rulemaking comes in light of a March CFPB report showing 58% of the debt collections reported on consumer credit reports stemmed from medical bills as of 2021. The Outline of Proposals and Alternatives Under Consideration is available here, and more information is available in the press release here.

On September 19, the CFPB issued guidance on credit denials by lenders using AI. The press release notes that, “today’s guidance explains that even for adverse decisions made by complex algorithms, creditors must provide accurate and specific reasons. Generally, creditors cannot state the reasons for adverse actions by pointing to a broad bucket. For instance, if a creditor decides to lower the limit on a consumer’s credit line based on behavioral spending data, the explanation would likely need to provide more details about the specific negative behaviors that led to the reduction beyond a general reason like ‘purchasing history.’”

On September 14, the CFPB issued a report entitled Tuition Payment Plans in Higher Education, which found that student loan borrowers face risk when entering into college tuition payment plans. Specifically, the press release states, “many plans have inconsistent disclosures and confusing repayment terms, putting students at risk of missing payments, incurring late fees, and accumulating debt. The report also finds that many institutions withhold transcripts from students as a debt collection tool, a potentially illegal practice that can have severe consequences for students trying to begin their careers or finish their education.” More information is available in the press release here and full report here.

RMAI monitors, tracks, and responds to legislative and regulatory activity in all 50 states as the need arises.  Backed by RMAI’s State Legislative Committee and a team of state lobbyists, RMAI educates legislators and regulators about the industry and the negative impacts or unintended consequences a bill would have on businesses and consumers. If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel David Reid at (916) 779-2492 or dreid@rmaintl.org. The following is a sample of the legislative activity over the prior month that has direct impact on the industry:

California AB 1414 [Chapter 688 of the Laws of 2023] Effective: January 1, 2024 – This law provides that in actions for the collection of consumer debt, common counts may not be used. This effectively will force all litigation through a contract theory for litigation. Common counts include book account and account stated, among other claims. For purposes of this section, “consumer debt” means any obligation or alleged obligation, incurred on or after July 1, 2024, of a consumer to pay money arising out of a transaction in which the money, property, insurance, or services that are the subject of the transaction are primarily for personal, family, or household purposes and where the obligation to pay appears on the face of a note or in a written contract. [RMAI and an industry coalition had actively opposed this legislation.]

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”; and (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 met with the bill sponsors and key legislators on October 24^th and 25^th to express our concern.]

Proposed Amendments to the New York City Debt Collection Rule – The New York City Department of Consumer and Worker Protection (DCWP) is proposing amendments to their Debt Collection Rule which would among other things: (1) provide an effective date that would take effect immediately upon adoption; (2) add extensive requirements that dictate how data associated with consumer communications is to be maintained; (3) require specific consumer notices which do not align with state requirements; (4) require maintaining the supporting data and documents when a judgment has been entered; (5) add provisions related to medical debt; and (6) create a date for itemization which is in conflict with state and federal provisions. [RMAI has retained a NYC lobbyist to help us seek amendments that are reasonable and can be operationalized by the industry.]

Seventh Circuit Follows the Eleventh and Tenth Circuits on Hunstein-Type Claim
Nabozny v. Optio Sols. LLC, No. 22-1202, 2023 U.S. App. LEXIS 28045 (7th Cir. Oct. 23, 2023)

A collection agency used a letter vendor to send a letter to a consumer regarding credit card debt.  The consumer responded by filing a lawsuit against the agency alleging that sharing information about her debt with the vendor “violated § 1692c(b) of the FDCPA, which provides that ‘a debt collector may not communicate, in connection with the collection of any debt, with any person other than the consumer’ without the consumer’s consent,” subject to certain exceptions.

The trial court dismissed the consumer’s lawsuit for lack of subject-matter jurisdiction, holding  she lacked Article III standing to sue because she “suffered no concrete injury.”  The consumer appealed.

On appeal, the consumer claimed she suffered a concrete injury because she was harmed by an invasion of her privacy and “suffered a loss of her ability to control her personal financial information,” which she argued was “analogous to the harm caused by a tortious invasion of privacy.”

The U.S. Court of Appeals for the Seventh Circuit disagreed, relying primarily on the Eleventh Circuit’s opinion in Hunstein v. Preferred Collection & Mgmt. Servs., 48 F.4th 1236 (11th Cir. 2022) and the Tenth Circuit’s endorsement of that opinion in Shields v. Prof’l Bureau of Collections of Md., Inc., 55 F.4th 823 (10th Cir. 2022).

The Court also explained that the consumer’s “attempt to analogize her case to this privacy tort falls apart on the threshold element of publicity,” as her complaint was “devoid of any allegations that [the agency] made her private information public.”  The Court further noted that “nothing in the complaint suggests any manner of public disclosure or even that anyone at [the vendor’s company] read or appreciated her information.”

Based on this, the Court affirmed the trial court’s order dismissing the lawsuit.

Ninth Circuit Recognizes Bona Fide Error Defense in Statute of Limitations Lawsuit
Sprayberry v. Portfolio Recovery Assocs., LLC, Nos. 21-36000, 21-36001, 2023 U.S. App. LEXIS 22615 (9th Cir. Aug. 28, 2023)

After a consumer defaulted on several store-branded credit cards, a debt buyer purchased the accounts from the banks that extended the credit and then sent collection letters.  The consumer filed a lawsuit against the debt buyer alleging violation of the Fair Debt Collection Practices Act (“FDCPA”) because the letters failed to disclose the debts were beyond the statute of limitations.  Her position was that the four-year statute of limitations for the sale of goods applied rather than the six-year period for accounts stated.

The debt buyer’s motion for summary judgment was granted based on the trial court’s finding that the debt buyer qualified for the FDCPA’s bona fide error defense, § 1692k(c).  The consumer appealed.

In an unpublished opinion, the U.S. Court of Appeals for the Ninth Circuit began by explaining it “need not consider whether [the consumer’s] debts were time-barred under Oregon law because, even if they were, the district court correctly held that [the debt buyer] is entitled to summary judgment on the bona fide error defense.”  In fact, the Court noted that which statute of limitations applies in this scenario “remains unresolved under Oregon law.”

Regarding the bona fide error defense, the Court first found there was no genuine dispute that any violation was unintentional based on the testimony of the debt buyer’s legal counsel.  Second, testimony established that the debt buyer had procedures that “were reasonably adapted to avoid a statute of limitations error.”  These included regular compliance training for all employees, legal analysis, and “a ‘systematic approach’ in place to determine whether the law regarding a statute of limitations had changed over time.”

Affirming the order of the trial court, the Ninth Circuit concluded: “Like the district court, we ‘cannot point to any additional research or analysis [the debt buyer] could have performed or any additional resources it could have invested to determine which statute of limitations applied.’”

Third Circuit Analogizes § 1692e Letter Claim to Fraudulent Misrepresentation for Article III Standing
Huber v. Simon’s Agency, Inc., 84 F.4th 132 (3d Cir. 2023)

A consumer incurred medical debts on four occasions, for $178.00, $78.00, $83.50, and $178.00. The debts were assigned to a debt collector that sent a letter to the consumer as each debt was placed.  After the last, the collector sent a letter that provided an “Account Summary” showing an “Amount” of $178.00, and “Various Other Accts Total Balance” of $517.50.

The consumer claimed she “was confused after reading the letter as to how much she owed in total: Was it $695.50 (the sum of the ‘Amount’ and ‘Various Other Accounts Total Balance’) or $517.50 (just the ‘Various Other Accounts Total Balance)?”  Instead of calling the collector for clarification, she filed a putative class action alleging the letter violated the Fair Debt Collection Practices Act, § 1692e, because it was “false, deceptive, or misleading.”

The trial court granted the consumer’s motion for summary judgment, observing that the letter could reasonably be read two ways and therefore violated § 1692e as a matter of law.  After the trial court granted the consumer motion for class certification, the collector “moved for reconsideration on the ground that [the consumer] and the unnamed members of her class had not suffered a concrete injury for purposes of Article III standing.”  The trial court denied the motion “under the auspices of the ‘informational injury doctrine,’” finding that “she was not merely confused or anxious, but also suffered two types of financial consequences as a result of her confusion.”  First, she sought assistance from a financial consultant. Second, she was “unable to pay down her debts or otherwise take appropriate action . . . because of the misinformation in [the] letter.”  The collector appealed.

The U.S. Court of Appeals for the Third Circuit agreed with the trial court that the consumer had Article III standing but disagreed with application of the informational harm doctrine since there was no omission of information.  “Simply put, unclear disclosures do not equate to outright omissions.”  Instead, the Court analogized the claim to the “tort of fraudulent misrepresentation [which requires] a § 1692e claimant must suffer some cognizable harm that flows from that confusion.”  Here, the Court found the financial consequences summarized by the trial court sufficient to establish standing.

Regarding the FDCPA claim, the court determined the letter to be “deceptive for purposes of § 1692e,” explaining that “we would not expect a least sophisticated debtor in [the consumer’s] position to recall the precise figures in the prior letters, much less understand clearly what amount was due.”

Finally, the Court vacated the trial court’s order certifying the class due to “the lack of evidence in the record indicating how many members of [the consumer’s] class are likely to have standing and how burdensome that showing will be for both the District Court and the parties.”  The Court explained that “because the District Court decided that Huber and the unnamed members of her class suffered informational injuries, the Court had no occasion to consider how individualized evidence of unnamed class members’ standing would affect the balance of common versus individual issues for purposes of predominance, or what proportion of the class could be expected to establish standing.”

Thus, the Third Circuit remanded the matter back to the trial court “to decide whether [the] proposed class satisfies Federal Rule of Civil Procedure 23(b)(3) notwithstanding the individualized evidence class members must submit to demonstrate standing and recover damages.”

Donate to the Legislative Fund with Your Membership Renewal
As mentioned previously, membership renewals were first sent out on October 2nd, and what better time than now to donate to RMAI’s Legislative Fund. As you renew your membership, please take note of the suggested voluntary donation on your invoice. Every donation to our Legislative Fund is appreciated and greatly helps us to continue the fight for the receivables management industry, so feel free to donate a different amount than suggested.

If you’ve already paid your membership dues but would still like to contribute, you can do so by donating here. We will add your company name to our list of Legislative Fund contributors on a large sign at the 2024 Annual Conference, the RMAI website, and in RMAI publications and invite you to the Legislative Fund Donor Reception at the 2024 Annual Conference. Click here to see a list of current contributors on the right-side bar.

Donate an Item for the Annual Conference Silent Auction
RMAI is ramping up for the 2024 Annual Conference Silent Auction, sponsored by Kino Financial Co., LLC, and is seeking new and continuing auction item donors to help make this event great. More highlights about the auction will be coming throughout the remainder of 2023.

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

Certification Webinar Series – 1.5 education credits
Beginning November 28^th through November 30^th, RMAI’s 2023 Certification Webinar Series will deliver three (3) 30-minute webinars which will focus on preparing you to obtain Receivables Management Business or Receivables Management Vendor certification and undergo the third-party compliance audit. These brief but bountiful webinars will give you the insight you need to either begin or continue your RMAI Receivables Management Certification Program journey.

Register for the entire series at a reduced rate of $150 or register for individual webinars:

• Certification Webinar Series
• #1: Starting or Continuing Your Certification Journey
• #2: Ask an Authorized Audit Provider: Your Burning Questions Answered
• #3: Lessons Learned from the Compliance Audit Process, Sponsored by ARM Compliance Business Solutions

*Sponsored Webinar* Reviving Financial Resilience: TransUnion’s Recovery Model & Legal Strategies Unveiled Webinar – 1 education credit
Registration will open soon for the December 12^th webinar, Reviving Financial Resilience: TransUnion’s Recovery Model and Legal Strategies Unveiled. Presenters from TransUnion and The Bureaus, Inc. will share information regarding recovery scoring and legal strategies and managing potential challenges through practical application.

Navigating Wyoming HB 284: Demystifying the Application Process and Q&A – 1 education credit
Register now for our December 20^th webinar, Navigating Wyoming HB 284: Demystifying the Application Process and Q&A where our presenters will walk you through the process of licensing in Wyoming and answer questions about challenges you may experience.

Recorded Webinars
If you missed our November 14^th webinar, Navigating Success: DEI Case Studies and Personal Insights into Unconscious Bias, sponsored by InDebted, you can register for the recordings on our Online Education webpage which will be available for one (1) year.

Click here for more information on our live and recorded educational webinars. Contact Shannon Parod at sparod@rmaintl.org 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 Vendor (CRV).

CRCP New
Caylon Cannon, Capio
Sarah Chouinard, Cavalry Portfolio Services, LLC
Meghann Cole, Midland Credit Management

CRCP Renewals
Claire Herman, Converging Capital, LLC
Michael Johnson, Jefferson Capital Systems, LLC
Christopher Russell, Plaza Services, LLC
Amanda Schenck, LawGistic Partners
Tina Suppa, First Credit Services, Inc.

CRB New
Dynamic Collectors, Inc.
Law Offices of Steven Cohen, LLC

CRV Renewal
SAM, Inc.

EFFECTIVE MARCH 1, 2024: PRE-CERTIFICATION AUDIT IS REQUIRED FOR DEBT BUYERS, COLLECTION AGENCIES & COLLECTION LAW FIRMS PURSUING CERTIFICATION

As previously announced, effective March 1, 2024, the RMAI Receivables Management Certification Program will require all debt buyer, collection agency, and collection law firm members to undergo a pre-certification audit prior to submitting their application for business certification. Through February 29, 2024, the only audit requirement is a full compliance audit conducted at the mid-way point of the three-year certification.

Avoid the extra expense and time commitment of a pre-certification audit, by certifying your business NOW. Please contact Director of Certification & Education, Shannon Parod at sparod@rmaintl.org to get more information.

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

For questions about certification, contact RMAI at (916) 482-2462 or email cert@rmaintl.org.

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

2024 RMAI Annual Conference | February 5-8, 2024

Please note, the RMAI offices will be closed Thursday, November 23rd, and Friday, November 24th, for the Thanksgiving holiday.

Thank you to our November 1, 2022 through November 8, 2023 Legislative Fund Contributors!

Diamond

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

Midland Credit Management

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Velocity Portfolio Group, Inc.

Titanium

EverChain

Second Round, LP

TRAKAmerica

Platinum

Blitt and Gaines, P.C.

Cascade365 Family of Companies

Garnet Capital Advisors, LLC

InvestiNet, LLC

T & I Enterprises, LLC

Unifund CCR LLC

Gold

Rausch Sturm, LLP

Silver

Andreu, Palma, Lavin & Solis,  PLLC

FMA Alliance, Ltd

Klima, Peters & Daly, P.A.

National Loan Exchange, Inc.

Provana, LLC

Ragan & Ragan, PC

Velo Law Office

Bronze

Acctcorp International, Inc.

Central Portfolio Control, Inc

DebtNext Software, LLC

Invenio Financial, a Phillips & Cohen Associates company

Kredit Financial Inc.

Resurgence Capital, LLC

Tobin & Marohn

Troutman Pepper

Brass

Actuate Law, LLC

Advancial Federal Credit Union

AKCP LLC

Aldridge Pite Haan, LLP

Arbeit

Arko Consulting LLC

Balbec Capital

Barron & Newburger, P.C.

Basham & Scott, LLC

Beam Software

Bread Financial

C & E Acquisition Group, LLC

C&R Software

Capio

CBE Companies

CBK, Inc.

Collection Attorneys USA LLC

Commercial Credit Group Inc.

Commercial Funding Inc.

CompuMail Information Systems

ConServe

Convergence Acquisitions, LLC

Cornerstone Licensing Services

CSS Impact

D & A Services, LLC

Digital Recognition Network

Epicenter Technologies Pvt. Ltd.

First Financial Portfolio Services, LLC dba FFAM360 Capital

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

George Brown Associates, Inc.

Glass Mountain Capital, LLC

Gordon, Aylworth & Tami, P.C.

Halsted Financial Services, LLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Huntington Debt Holding LLC

Imagined.Cloud LLC

InDebted

International Debt Buying Consultants, LLC

January Technologies, Inc.

Kino Financial Co., LLC

Kota Business Solutions LLC

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

Law Offices of Steven Cohen LLC

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Mandarich Law Group LLP

Markoff Law LLC

Mountain Peak Law Group, PC

Murray Law Firm, P.C.

National Debt Holdings, LLC

NCB Management Services, Inc.

Nelson & Kennard

NRA Group, LLC

Nuvei

PCI Group Inc.

Phin Solutions, LLC

Plaza Services

Premier Forty Financial, LLC

Pressler, Felt and Warshaw, LLP

Prodigal

Quall Cardot, LLP

Quantum3 Group, LLC

Repay Realtime Electronic Payments

Resource Management Services, Inc.

RevSpring

Robinson Hoover & Fudge, PLLC

SAM – Solutions for Account Management

Scott & Associates, PC

Security Credit Services, LLC

Sequium Asset Solutions, LLC

Skit.ai

Slovin & Associates

SMS Financial, LLC

Stone, Higgs & Drexler

Suttell & Hammer

TEC Services Group, Inc.

The Bureaus, Inc.

The Cadle Company

Troy Capital, LLC

TrueAccord

Universal Fidelity LP

USASF Servicing, LLC

VeriFacts, LLC.

Vertican Technologies, Inc.

VoApps, Inc.

Other

Alliance Credit Services, Inc.

ARM Compliance Business Solutions LLC

Atlas Acquisitions

Bedard Law Group, P.C.

CMS Services

Connect International

Converging Capital, LLC

Convoke, Inc.

Credit Corp Solutions Inc.

Credit Management Corporation

D1AL

Dynamic Collectors, Inc.

Equifax, Inc.

HS Financial Group, LLC

Law Offices of Goldberg & Oriel

London & London

Martin Golden Lyons Watts Morgan PLLC

MauriceWutscher LLP

Miller and Steeno, P.C.

Moss & Barnett, P.A.

POM Recoveries, Inc.

ProVest LLC

Receivables Management Association International

Sandia Resolution Company, LLC

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Venable LLP

Venandi Systems, LLC

WebRecon LLC

Womble Bond Dickinson