RMAI Update September 2023

Congress returned from their summer break after Labor Day.  Top of mind is the funding of the government.  If Congress cannot pass a budget by the end of the fiscal year (September 30th), they will be forced to pass another Continuing Resolution to avoid a government shutdown.  Also expiring at the end of the fiscal year are several COVID era programs.

RMAI leadership was on Capitol Hill meeting with key members of the House Financial Services Committee and the Senate Banking Committee earlier this week. A full report will be provided in next month’s online newsletter.

On Monday, September 11th, RMAI filed Comments in response to the CFPB’s Request for Information on medical debt payments. Special thanks to several RMAI members for providing the expertise needed to write these Comments.

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 [email protected]. The following bills of concern are a sample of the legislation that RMAI is currently engaging on behalf of the industry:

California AB 1414 – This bill 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 are in opposition to the bill.]

Massachusetts SB 629 – 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, 2024. [RMAI has been opposing this bill since 2014 when it was first introduced. After eight years of negotiations and countless amendments, RMAI and the consumer advocates agreed to amendments that will remove RMAI’s opposition to the bill once the bill is amended. 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”; 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 is developing a coalition to vigorously oppose this bill. RMAI has retained a state lobbyist.]

South Carolina Appellate Court Holds Right to Cure Notice Required for Credit Card Collection
Synchrony Bank v. Campney, No. 6019, 2023 S.C. App. LEXIS 98 (Ct. App. Aug. 23, 2023)

The South Carolina Court of Appeals recently held that a debt buyer must first provide a debtor with a written right to cure notice before accelerating the debt and commencing a collection lawsuit. Because the debt buyer failed to provide the debtor with such a notice, the court found it violated the South Carolina Consumer Protection Code (SCCPC).

The case involved a credit card issued by a bank that was purchased by a debt buyer following the debtor’s default. The debt buyer retained a law firm to sue to collect the credit card debt and the debtor counterclaimed alleging the debt buyer violated the SCCPC by not providing her with a written notice of acceleration and right to cure. In addition, the debtor alleged the debt buyer also violated the federal Fair Debt Collection Practices Act that by violating the SCCPC and because: 1) its lawsuit to collect the credit card as an “account stated claim” was not a lawful collection practice in South Carolina; and 2) even if it was lawful, it did not satisfy the requirements for an account stated claim.

The court first ruled that account stated claims are a lawful basis for collection of “a consumer in a credit card transaction,” citing to authority from across the country. It also held that the debt buyer properly asserted its account stated claim. First, the company offered testimony that under Synchrony Bank’s standard procedures, it mailed out credit statements to the address on the statement. Second, the debtor “testified she believed she had received the billing statements from Synchrony Bank.” And third, the debtor admitted: 1) making prior payments on the account; 2) that the address to which the account statements were sent was an address at which she received mail; and 3) that “she did not provide any evidence she objected to the account balance before charge off and sale to [the debt buyer].”

Next, the Court explained that the SCCPC provides that “in ‘a consumer credit transaction payable in two or more installments,’ a creditor must first provide the consumer a right to cure notice before accelerating the debt after the consumer’s default.” It further found that “consumer credit cards are ‘lender credit cards’ and ‘consumer loans’ pursuant to the SCCPC.”

The court disagreed with the debt buyer’s argument that it was not a “creditor” within the meaning of the SCCPC. “We find [the debt buyer’s] argument that the requirement to issue a notice of right to cure before suing [the debtor] disappeared when [it] bought the debt from Synchrony Bank is without merit.”

Finally, even though the debt buyer violated the SCCPC, the court dismissed the debtor’s tag-along FDCPA claim on the basis that the violation occurred outside the FDCPA’s one-year limitations period and further ruled the debtor’s claim under the SCCPC occurred outside that statute’s two-year limitations period. While the debtor could not recover SCCPC damages, she could still set off the debt under the SDDPC “by any ‘refunds or penalties’ she may be entitled, regardless of ‘time limitations.’”

Notably, the SCCPC is not unique is derived from a combination of the 1968 and 1974 Uniform Consumer Credit Code (UCCC) which has been enacted in ten other states.  Given that the UCCC has been adopted in relatively “uniform” fashion in those other states, there is good reason to consider the whether the reasoning of the Campney decision may have broader implications.

Seventh Circuit Reiterates No Article III Standing for Confusion, Sleep Loss, Attorney Retention
Choice v. Kohn Law Firm, No. 21-2288, 2023 U.S. App. LEXIS 21020 (7th Cir. Aug. 11, 2023)

A consumer defaulted on a debt owed to a bank, the debt was sold to a debt buyer, and the debt buyer referred the matter to a collection law firm.  The law firm filed a lawsuit against the consumer in state court and sought judgment for the amount of the debt plus “statutory attorney fees.”

The complaint included an affidavit from an agent of the debt buyer stating that the the debt buyer “was not seeking additional amounts after the charge-off date, including attorney’s fees.”  Because the affidavit contradicted the request for judgment, and because the consumer questioned whether the law allowed statutory attorney fees, the consumer filed suit against the debt buyer and law firm in federal court alleging “injury from the receipt of false, misleading, and deceptive communications” in violation of the federal Fair Debt Collection Practices Act (FDCPA).

The consumer claimed the prayer for statutory attorney fees made him concerned, worried, confused, and caused loss of sleep.  Further, he claimed he was forced to hire an attorney “to help him ascertain the amount of the alleged debt owed, whether attorney fees could be imposed, and in what amount.”  The debt buyer and law firm moved to dismiss for lack of subject matter jurisdiction, and the motions were granted based on lack of Article III standing due to the absence of a concrete harm. The consumer appealed.

The U.S. Court of Appeals for the Seventh Circuit explained that “to establish standing under Article III of the Constitution, a plaintiff must demonstrate (1) that he or she suffered an injury in fact that is concrete, particularized, and actual or imminent, (2) that the injury was caused by the defendant, and (3) that the injury would likely be redressed by the requested judicial relief.”

Citing a number of its previous opinions, the Court reiterated that “decisions to hire an attorney and pay an appearance fee are insufficient to establish standing,” and that “confusion leading one to hire a lawyer is insufficient to establish standing.”

Again, citing its previous opinions, the Court further explained that emotional harms, including loss of sleep, are insufficient to establish standing.

Therefore, the Court upheld the trial court’s judgment dismissing the consumer’s claims.

Seventh Circuit Holds Disabilities Can Sometimes Require Work Schedule Accommodations
EEOC v. Charter Commc’ns, LLC, No. 22-1231, 2023 U.S. App. LEXIS 19528 (7th Cir. July 28, 2023)

An employee working for a company’s call center allegedly had cataracts in both eyes that made it unsafe for him to drive at night.  The employee initially asked for a 30-day change to his schedule that would allow him to start and finish work two hours earlier.  That request was granted, but before the period was over, he asked for a 30-day extension while he tried to find a place to live closer to work.  That request was denied.

The employee filed a complaint with the Equal Employment Opportunity Commission (EEOC) which filed suit against the employer “alleging that the company violated the Americans with Disabilities Act [(ADA)] by failing to accommodate [the employee’s] disability,” citing  42 U.S.C. § 12112(b)(5).

The employer moved for summary judgement which the trial court granted based on its reading of a Seventh Circuit opinion that it believed foreclosed a work schedule accommodation because the employee “did not need any accommodation to perform an essential job function once he arrived at work.”

The U.S. Court of Appeals for the Seventh Circuit began by explaining that “the ADA requires an employer to make ‘reasonable accommodations’ for an employee with a disability, absent undue hardship on the employer’s operations. § 12112(b)(5)(A). The ADA provides a non-exclusive, illustrative list of potential accommodations. That list includes ‘part-time or modified work schedules.’ § 12111(9)(B).”

The Court reviewed cases from the Second and Third Circuits that supported the employee’s position, and from the Sixth and Tenth in favor of the employer’s.  From these, the Court made two general observations:

First, where a disability makes it difficult for an employee to travel to and from work safely, the employee usually controls some key variables, most important where the employee lives, but the employer controls another key variable, the work schedule. . . Second, we repeat that in most cases, an employer has no duty to help an employee with a disability with the method and means of his commute to and from work, assuming the employer does not offer such help to employees without disabilities.

Thus, “deciding whether a work-schedule accommodation of a disability that affects a commute is reasonable depends on a highly fact-specific inquiry that considers the needs of both employer and employee.”  The Court explained that the analysis depends on the many facts, “including the benefits of the accommodation, alternatives to the accommodation, the cost to the employer, and consequences for others.”

Here, the Court opined that “on this record, a jury could find [the modified work schedule] would have been a reasonable accommodation.” The Court also noted the employer had not demonstrated “the accommodation would have imposed an undue hardship,” or “would have imposed unfair burdens on other employees or would have been too costly.”

Reversing the judgment of the trial court and remanding the matter for further proceedings, the Court concluded:

We prescribe no bright-line rules as to when an employee’s disability interferes with essential job attendance or whether particular accommodations are reasonable. Those questions are reserved for analysis under the facts of a particular case. But if a qualified individual’s disability substantially interferes with his ability to get to work and attendance at work is an essential function, an employer may sometimes be required to provide a commute-related accommodation, if reasonable under the circumstances.

Eleventh Circuit Holds Statutory Violation Alone Does Not Confer Standing; Remanded for Entry of Dismissal Without Prejudice
Davis v. Prof’l Parking Mgmt. Corp., No. 22-14026, 2023 U.S. App. LEXIS 17944 (11th Cir. July 14, 2023)

A consumer parked in a private lot and later received a “Parking Charge Notice” from the company that owned the lot.  The consumer did not pay the charge believing that a city ordinance prohibited issuance of private parking tickets.  The matter was referred to a collection agency which sent the consumer a collection letter.

The consumer filed an action in state court against the company and the collection agency alleging the company violated Florida’s Deceptive and Unfair Trade Practices Act, and that both defendants violated the Florida Consumer Collection Practices Act and the federal Fair Debt Collection Practices Act.

The defendants removed the case to federal court where the complaint was dismissed with prejudice based on the consumer’s failure “to allege a concrete injury in fact to establish Article III standing.”

In an unpublished decision, the U.S. Court of Appeals for the Eleventh Circuit explained that “[i]n this case, [the consumer] alleged potentially unlawful conduct, but he failed to allege any harmful conduct. . . our case law is clear that a statutory violation, by itself, does not create an injury.”

Further, the Court noted the consumer did “not provide an analogous traditional harm for these state or federal statutory violations. In fact, we have previously held that ‘the common law furnishes no analogue’ to claims brought under the FDCPA that are nearly identical to the claims [the consumer] brought here.”

Although not included in his complaint, the consumer alleged in his appellate brief that “he ‘wasted time’ by disputing the debt, that he faced additional stress because of the debt, and that his credit score might be impacted by the debt.”  The Court did not consider these claims because the consumer could not “amend his complaint at this late stage through his appellate briefing.”

While the Court affirmed the dismissal for lack standing, it did remand that case with instructions that the trial court reenter its judgment as dismissal without prejudice.  The Court explained that “a dismissal for lack of standing is equivalent to a dismissal for lack of subject matter jurisdiction,” and “if subject-matter jurisdiction does not exist, dismissal must be without prejudice.”

Ninth Circuit Holds Incurring Attorney’s Fees Establishes Standing but Affirms Dismissal of Claims
Nyberg v. Portfolio Recovery Assocs., LLC, No. 17-35315, 2023 U.S. App. LEXIS 17023 (9th Cir. July 6, 2023)

A debt buyer brought a collection action against a consumer in state court to collect credit card debt, and this was followed by the consumer bringing a lawsuit against the debt buyer in federal court for alleged violations of the Fair Debt Collection Practices Act.  The consumer claimed that the debt buyer provided false information and brought an account-stated claim that was legally baseless and time-barred.

The federal trial court granted the debt buyer’s motion for summary judgment and dismissed the claims.  The consumer appealed.

In an unpublished decision, the U.S. Court of Appeals for the Ninth Circuit first addressed the issue of Article III standing, and rather summarily held that the consumer “demonstrated a concrete injury by showing that he incurred attorney’s fees defending against [the debt buyer’s] state-court action.”

Nevertheless, the Court found the trial court properly dismissed the consumer’s claims.  First, the consumer did not “establish that the alleged falsities were material,” and “did not demonstrate that the statement of what he owed ‘affected his ability to make intelligent decisions’ about how to respond to the collection effort.’”

Second, the Court recognized that when the collection lawsuit was filed, Oregon law recognized account stated claims.  Even though the collection complaint failed to plead a necessary element, “that deficiency under Oregon law is not a per se violation of the FDCPA.”

Finally, the Court held that the collection lawsuit was not time-barred.  Though the credit card agreement was governed by Virginia law, both Oregon and Virginia had “a relevant connection to the dispute and neither party has identified a substantive conflict between Virginia and Oregon laws governing claims for account stated.”  Therefore, applying Oregon’s conflict-of laws rules, the court determined Oregon’s longer statute of limitations applied.

Therefore, the Court affirmed the trial court’s dismissal of the claims.

Donate to the Legislative Fund with Your 2024 Membership Renewal
October 1 through December 31, 2023, RMAI will be sending out 2024 membership renewal invoices. This is always a great time and opportunity to donate to RMAI’s Legislative Fund along with paying your membership dues. RMAI has been at the forefront of many state and federal issues in 2023, and your donations help us to continue our advocacy efforts. Please consider donating any amount.

To read more about RMAI’s advocacy efforts, please refer to the Federal and State update sections of the RMAI Update e-newsletter and the RMAI Insights magazine.

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 – Complimentary Registration for RMAI Members
Register now for our September 20th webinar, Fintech Market Trends, where our presenters from the Fintech Legal Working Group will discuss current trends in fintech lending, performance, regulation, recovery, and debt sales. They will also examine how the fintech space has evolved in the past few years and what the near term may look like as consumer stress continues to increase in the current economy.

Register now for our October 4th webinar, What Drives the Auto Finance Asset Class, where our presenters from the Auto Finance Working Group will update attendees on the auto finance asset market and preview the soon-to-be-released primer paper covering such topics as data and documentation, chain of title, and best practices. They’ll also share their expertise for how best to break into (or stay in) the auto deficiency market.

Register now for our November 14th webinar on Diversity, Equity & Inclusion (DEI) presented by volunteers from the DEI Committee. More details to come. **Please note that this webinar will qualify for the CRCP requirement to earn one (1) credit from identifying and avoiding discriminatory collection practices.

Recorded Webinars
If you missed our August 16th webinar, Bridging the Gaps Between Operations, IT and Compliance or our August 30th webinar, Around the Safeguards in 80 Days,  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.

Congratulations to our new and renewed Certified Receivables Compliance Professionals (CRCP) and new and renewed Certified Receivables Business (CRB).

CRCP New
Mark Cassidy, Resurgent Capital Services
Joshua Deleon, Cavalry Portfolio Services, LLC
Kelsi Hamilton, Dynamic Collectors, Inc.
Zahkia Morgan, Global Solutions Biz, LLC
Kay Myers, Resurgent Capital Services
Dave Ross, Crown Asset Management
Altaf Sayed, Epicenter Technologies

CRCP Renewals
Andy Carlson, Garnet Capital Advisors
Amy Dowdey, Denali Capital, LLC
Leah Ferrell, Branding Arc
Jessica Hearn, Universal Fidelity LP
Mark Naiman, In the Park MDR, LLC/Debtconnection
John Tyler, CKS Financial
Sue Unterberger, Jefferson Capital Systems, LLC
Trudy Weiss-Craig, Unifund CCR LLC
Richard Weissman, O & L Law Group

CRB New
The Axiom Group (Family of Companies)

CRB Renewal
Universal Fidelity, LP

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

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. Currently, the only audit requirement is a full compliance audit which is conducted at the mid-way point of the three-year certification.

Take the opportunity NOW to get your business certified and avoid the extra expense of a pre-certification audit. Please contact Director of Certification & Education, Shannon Parod at [email protected] 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 [email protected].

2024 Annual Conference DEI Scholarship
The Diversity Equity Inclusion (DEI) Annual Conference Scholarship is open to all receivables management professionals employed by Certified Receivables Business and Certified Receivables Vendor members, who have never attended an in-person RMAI event (i.e., Annual Conference, Executive Summit, or Fall Networking) and are viewed as emerging leaders in their organization. DEI Annual Conference Scholarship sponsorships fund the scholarship.

Click here for more information including the required forms to apply and how to sponsor. Applications must be submitted on or before October 13, 2023.

Fall Networking & Baseball
We loved seeing members from around the country at our 2023 Fall Networking & Baseball event in Denver, CO! Attendees joined us for lunch and a pre-game reception, and then to watch the Colorado Rockies play the Chicago Cubs from a Game Suite in Coors Field. With multiple opportunities to network and connect, it was a great day out at the ballpark.

  

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

2024 RMAI Annual Conference | February 5-8, 2024

Thank you to our September 1, 2022 through September 7, 2023 Legislative Fund Contributors!

Diamond $25,000

Cavalry Investments, LLC

Crown Asset Management, LLC

Financial Recovery Services, Inc.

Resurgent Holdings, LLC

Velocity Portfolio Group, Inc.

Platinum $10,000

Second Round, LP

TRAKAmerica

Gold $7,500

Pressler, Felt and Warshaw, LLP

Rausch Sturm, LLP

Silver $5,000

Andreu, Palma, Lavin & Solis,  PLLC

Corporate Advisory Solutions, LLC

Digital Recognition Network

FMA Alliance, Ltd

Klima, Peters & Daly, P.A.

National Loan Exchange, Inc.

Pharus Funding, LLC

Ragan & Ragan, PC

Velo Law Office

Bronze $2,500

Absolute Resolutions Corp.

Acctcorp International, Inc.

Central Portfolio Control, Inc

DebtNext Software, LLC

Kredit Financial Inc.

RAzOR Capital, LLC

Resurgence Capital, LLC

Tobin & Marohn

Troutman Pepper

Brass $1,000
Action Collection Agencies, Inc.

Actuate Law, LLC

Advancial Federal Credit Union

AKCP LLC

Aldridge Pite Haan, LLP

Arbeit

Arko Consulting LLC

Balbec Capital

Barron & Newburger, P.C.

Beam Software

Bread Financial

Butler & Associates, P.A.

C&R Software

Call Center Services International

Capio

CBK, Inc.

CCMR3

Cedar Holdings International Inc. DBA Cedar Financial

Commercial Credit Group Inc.

Commercial Funding Inc.

Convergence Acquisitions, LLC

Cornerstone Support, LLC

CSS Impact

Dobberstein Law Firm, LLC

Epicenter Technologies Pvt. Ltd.

First Financial Portfolio Services, LLC dba FFAM360 Capital

FLOCK Specialty Finance

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Guglielmo & Associates, PLLC

Halsted Financial Services, LLC

Harvest Strategy Group, Inc.

Hinshaw & Culbertson

Hunt & Henriques, LLP

Huntington Debt Holding LLC

International Debt Buying Consultants, LLC

Invenio Financial, a Phillips & Cohen Associates company

Investment Retrievers, Inc.

January Technologies, Inc.

Jefferson Capital Systems, LLC

Kota Business Solutions LLC

Law Offices of Goldberg & Oriel

Levy & Associates, LLC

Lockhart, Morris & Montgomery, Inc.

Mandarich Law Group LLP

Markoff Law LLC

Metacorp, LLC

Mountain Peak Law Group, PC

National Debt Holdings, LLC

Nelson & Kennard

NRA Group, LLC

Nuvei

PCI Group Inc.

Phin Solutions, LLC

Portnoy Schneck, LLC

Premier Forty Financial, LLC

Quall Cardot, LLP

Quantum3 Group, LLC

RevSpring

Robinson Hoover & Fudge, PLLC

Scott & Associates, PC

Sequium Asset Solutions, LLC

SimpleCertifiedMail.com

Skit.ai

Slovin & Associates

Stenger & Stenger P.C.

Stone, Higgs & Drexler

Suttell & Hammer

The Cadle Company

TrueAccord

US Mortgage Resolution, LLC

USASF Servicing, LLC

Venable LLP

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

Coastal Law Firm, APLC

Converging Capital, LLC

Convoke, Inc.

Credit Corp Solutions Inc.

Credit Management Corporation

D1AL

HS Financial Group, LLC

InDebted

Kino Financial Co., LLC

Kirschenbaum & Phillips, P.C.

Law Offices of Steven Cohen LLC

London & London

Martin Lyons Watts Morgan PLLC

MauriceWutscher LLP

Miller and Steeno, P.C.

Moss & Barnett, P.A.

National Recovery Solutions, LLC

POM Recoveries, Inc.

Portfolio Recovery Associates, LLC

Poser Investments, Inc.

ProVest LLC

Receivables Management Association International

Resource Management Services, Inc.

SAM – Solutions for Account Management

Sandia Resolution Company, LLC

SCJ Commercial Financial Services

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stone Creek Financial Inc.

The Oakes Law Firm, LLC

Troy Capital, LLC

United Acquisitions, LLC

Vargo & Janson, P.C.

Venandi Systems, LLC

WebRecon LLC

Womble Bond Dickinson