In This Update

On Capitol Hill, House Financial Services Committee Republicans introduced the Consumer Financial Protection Accountability and Reform Act of 2026, a broad CFPB reform package. Among other provisions, the legislation would bring the CFPB under the congressional appropriations process, create a dedicated Inspector General, establish additional cost-benefit and transparency requirements for rulemaking, and place new statutory limits on certain CFPB authorities. The proposal would also clarify that agency guidance is not legally binding, strengthen procedural protections, and make a number of changes intended to limit “regulation by enforcement.” In a series of recent meetings on Capitol Hill, RMAI continued to advocate for a stable CFPB and clear, consistent rules that provide regulated entities with greater certainty and appropriate due process.

The CFPB also announced that it will stop publicly publishing unverified consumer complaint narratives and related data visualizations in its Consumer Complaint Database. The Bureau acknowledged that complaint narratives are inherently one-sided and unverified and do not necessarily indicate a violation of law. The CFPB will continue collecting and monitoring complaints and sharing information with federal and state regulators. This is particularly relevant to RMAI, which has repeatedly raised concerns with CFPB leadership regarding complaint integrity, misuse of the complaint process, and the risks associated with treating unverified allegations as evidence of misconduct.

At the FTC, a federal court temporarily halted a network of 17 related companies accused of operating a credit repair scheme that allegedly collected nearly $200 million from consumers. The FTC alleges the companies impersonated legitimate creditors and debt collectors, disputed legitimate debts, and in some instances filed false identity theft reports without consumers’ knowledge. The action closely aligns with issues RMAI has raised directly with the FTC in meetings this year, including fraudulent disputes, misuse of identity theft affidavits, and problematic credit repair activity.

The FTC is also seeking comment on a proposed policy addressing personalized pricing, particularly the use of consumer data to determine what an individual may be willing to pay for a product or service. While the proposal appears primarily focused on retail-style pricing and does not specifically address traditional receivables activity, RMAI is monitoring the issue for potential implications involving the use of consumer data and AI.

At the FCC, the Commission is considering creation of a public Robocall Mitigation Scorecard for voice service providers. Importantly, the FCC is considering false positives and the erroneous blocking of legitimate calls as part of its evaluation. These issues are consistent with RMAI’s ongoing advocacy surrounding the blocking and labeling of lawful collection communications, and RMAI is reviewing the proposal for potential engagement.

Finally, RMAI has met with the Treasury Department regarding the ongoing transition of certain federal student loan responsibilities. Following RMAI’s initial meeting with Treasury, the Department has provided additional questions, and RMAI has offered recommendations regarding the role of servicers and the value that RMAI certification standards can provide as Treasury develops its approach.

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].

The 2026 State Legislative cycle is winding down. Only a few state legislatures are still in session. All eyes are now turning to the November elections. The results of this election could have a profound impact on the receivables industry as well as how RMAI deploys our lobbying strategies in 2027. Take a look at the upcoming state legislative article in the RMAI Magazine for additional insights on the election.

Here is a sample of bills we are currently monitoring/lobbying:

Michigan HB 6205 – This bill would codify new exemptions from garnishment, including means-tested public assistance, unemployment compensation, federal and state earned income tax credits, disability benefits, and worker’s disability compensation benefits. The bill also sets the following limits on the amount of wages subject to garnishment: (1) for weekly gross wages up to $1,925, only the lesser of 20% of garnishable earnings or the amount exceeding 30 times the federal minimum wage can be garnished and (2) for wages above $1,925 per week, up to 30% of garnishable earnings may be garnished. [These changes aim to provide clearer protections for certain types of income and set more precise limits on wage garnishment, aligning with efforts to safeguard low-income individuals and those receiving public benefits from excessive debt collection.]

Pennsylvania HB 801 – This bill would enact the Uniform Law Commission’s (ULC) Uniform Consumer Debt Default Judgments Act (UCDDJA), which aims to standardize the process for obtaining default judgments in consumer debt collection cases. It applies to unsecured consumer debts, secured consumer debts when seeking a money judgment, and deficiencies remaining after the disposition of secured property. The act mandates specific requirements for complaints in such cases, including detailed information about the consumer, the debt, and the plaintiff’s authority to collect it. [RMAI spent over three years as an observer on the ULC drafting committee to ensure the uniform act, if adopted by a state, worked for RMAI’s members. A portion of the uniform act was modeled on provisions contained in the RMAI Certification Program. RMAI is in support of its adoption. The UCDDJA has been adopted into law in Virginia and Washington.]

Pennsylvania HB 1731 – This bill would enact the Consumer Debt Collection Fairness Act which would require debt collectors and debt buyers to provide the following documentation in a summons and complaint when initiating legal action: (1) the name of the original creditor; (2) the last four digits of the account number; (3) an itemized statement of the amount owed (including charge-off balance, post-charge-off interest or fees, and payments or credits applied); (4) proof of ownership of the debt (with a chain of title if the debt has been sold); and (5) a copy of the original contract or charge-off statement demonstrating the consumer’s liability. The bill also reduces the statute of limitations from 4 to 3 years. Furthermore, courts are prohibited from entering default judgments in consumer debt cases unless the plaintiff submits an affidavit of facts based on personal knowledge, all required documentation, and proof that the consumer was properly served and notified of their rights. Each lawsuit must also include a separate “Notice of Consumer Rights,” informing the consumer of their right to dispute the debt, request documentation, and seek legal assistance. [RMAI opposes this legislation. RMAI feels that the Uniform Law Commission’s uniform act of default judgments is a much better vehicle for reform. RMAI has retained a lobbyist to advocate our position.]

California Court of Appeal Addresses Fair Debt Buying Practices Act’s “Access” and “Attachment” Requirements
Velocity Investments, LLC v. Nguyen, 2026 WL 2542811 (Cal. Ct. App. 2026)

A debt buyer retained a law firm to file a collection action against a consumer whose debt it had purchased.  The collection complaint included an “Exhibit A” which was described as “a copy of a Billing Statement and/or Loan file provided to [the consumer] while the account was active, demonstrating that the debt was incurred by [the consumer].”  The attachment was an example borrowing agreement that included “several pages of terms and a blank loan agreement and promissory note.”  The collection complaint also referred to an “Exhibit B,” which was said to be “a copy of the Final Billing Statement and/or Transaction History,” but it was not attached.

The consumer filed an answer and a cross-complaint alleging, in part, violation of the of the California Fair Debt Buying Practices Act (“FDBPA”) which “requires a debt buyer: (1) to have access to documentation evidencing a consumer’s agreement to a debt before trying to collect the debt (the access requirement) and (2) to attach that documentation to the collection complaint (the attachment requirement).”

The debt buyer filed an amended complaint additionally including in “Exhibit A” an executed loan agreement and promissory note, and including in “Exhibit B” “a six-page spreadsheet showing the status of an account with the same ending digits described in the original and amended complaint’s allegations.”

The debt buyer moved for summary judgment, which the court granted finding that the debt buyer did not violate the access requirement, did not violate the attachment requirement, and the failure to include additional documentation to the complaint was the result of a bona fide error.  The consumer appealed.

On appeal, the California Court of Appeal, Third District, explained that Cal Civ Code § 1788.52(b) “prohibits a debt buyer from making a written statement to a debtor to collect a consumer debt ‘unless the debt buyer has access to a copy of a contract or other document evidencing the debtor’s agreement to the debt.’”  Affirming the trial court’s ruling on this issue, the Court found that the debt buyer provided sufficient evidence to show it had access to documents demonstrating the debt when the collection complaint was filed.

However, the Court reversed the trial court’s ruling on the attachment issue.  It held that the generic borrower agreement attached to the original complaint failed to evidence the consumer’s agreement because it did not identify him, show that he signed the agreement, or contain essential loan-specific terms.  It disagreed with the trial court’s conclusion that “any error was ultimately corrected” in the amended complaint because, unlike the Rosenthal Fair Debt Collection Practices Act, the FDBPA does not provide any opportunity to cure a violation.

Finally, on the issue of bona fide error, the Court again disagreed with the trial court.  It noted that “[f]ederal cases interpreting this language have held that whether procedures are reasonably adapted is a fact-intensive question often inappropriate for resolution on summary judgment.”  Reviewing the debt buyer’s procedures, the Court found that “a reasonable juror could find these procedures were not reasonably adopted to avoid the error. Multiple questions on reasonableness come to mind. . . These questions lead us to conclude there is a triable issue regarding the complaint preparation procedures.”

Therefore, the Court of Appeal reversed the summary judgment entered in favor of the debt buyer, affirmed summary adjudication on the access requirement, and reversed the summary adjudications of the attachment requirement and derivative causes of action.

Contribute to the Legislative Fund with Your 2027 Renewal
What a year 2026 has been, and we can’t thank all of our members enough for their contributions to our Legislative Fund, which has helped us retain 8 lobbyists and track over 700 bills on your behalf.

With that in mind, your 2027 renewal invoices are being distributed on October 1st, 2026, and will continue through the end of the year. This is a perfect time to contribute to RMAI’s Legislative Fund to keep RMAI going into 2027. Please take note of the voluntary donation listed on your invoice; however, we appreciate any donation while you renew your membership dues. We hope to make 2027 another great year for state and federal advocacy, and your donations help those efforts. Please consider donating to RMAI’s Legislative Fund with your renewal this year.

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 Webinar

Register for our September 15th webinar, UDAAP by Analogy – Using Other Federal and State Statutes to Define and Enforce UDAAPs.  Our presenters, Stefanie Jackman with Troutman Pepper Locke, Jo Ann Needleman with Clark Hill, and Manny Newburger with Barron & Newburger, P.C., will provide an in-depth examination of UDAAP, exploring how both federal and state laws define unfair, deceptive, and misleading practices. We’ll also examine statutes such as FDCPA Section 15 U.S.C. § 1692d, which state regulators frequently rely on when pursuing state-level UDAAP actions—even against businesses that may not traditionally fall within the statute’s scope.

Recorded Webinars

Recorded on September 3, 2026, you can register for Defeat Credit Repair Schemes in 2026. Our presenters, Stephanie Rhay with iQor, and John Rossman with Rossman Kirk, PLLC,  discussed how to identify potentially frivolous, irrelevant, duplicative, or unsupported disputes and develop appropriate response strategies.

Recorded on August 18, 2026 you can register for AMA: Enforcement Trends, Litigation Risk, Recent Legislation and a Last Call for NYC Readiness.  Our presenter, Don Maurice with Maurice Wutscher LLP, covered current work and emerging issues. Don covered key enforcement trends at the federal and state levels, evolving litigation risks, and recent legislative and regulatory activities covering junk fees, coerced debt and the use of AI in consumer financial products and services. He also answered questions from attendees.

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 and renewed Certified Receivables Businesses (CRB)!

CRCP New
Parambir Bajwa, RMAI
Jack Coggins, Pro Asset
Dena DeForest, InDebted USA
Sarena Gaylor, Couch Lambert
James Oh, Javitch Block

CRCP Renewals
Rozanne Andersen, Retired
Veronica Bracamonte, Guglielmo & Associates
Edward Celenza, Crown Asset Management
Addison Crawford, Midland Credit Management
Anne Gonzales, Crown Asset Management
Elizabeth Haug, Poser Investments
Mark Ravanesi, TrueAccord
Stephanie Schenking, NCB Management
Megan Tiani, Hilco Global
Shanon VanHuss, Harvest Strategy Group
Robert Winters, Crown Asset Management

CRB New
Parambir Bajwa, RMAI
Jack Coggins, Pro Asset
Dena DeForest, InDebted USA
Sarena Gaylor, Couch Lambert
James Oh, Javitch Block

CRB Renewal
Southwood Financial

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

Resources for Individual and Business or Vendor Certification
RMAI has developed certification resources for our members who are going through the individual or business/vendor certification and aren’t sure where to start or aren’t sure how long the process takes. These easy to follow resources will help you feel less intimidated and more confident in how to obtain certification at any level.

Individual Certification

Business/Vendor Certification

View our full list of certification resources.

Renew Your Membership and Help Us Grow
It’s that time of year! Renewal invoices will be sent out next month. As renewal invoices are distributed, our Q4 offer will also take effect, making it a great time to refer a peer to join RMAI. If you know someone who would make a great member, let them know that new members joining October 1st – December 31st will receive membership through the end of 2027. Offer to be a reference for them and direct them to our online application to take the first step towards membership. RMAI thanks you for your membership and your continued support, and we look forward to another amazing year with you!

Add a Representative to your Membership Renewal | $100/year
Do you have an employee or coworker who is interested in joining a committee or is pursuing or already earned individual certification? If so, you can enroll them as an Additional Membership Representative on your company’s membership renewal! Simply contact Nicole Canon when you receive your invoice to request that change. In addition to receiving information critical to certified individuals, Additional Membership Representatives also receive access to the following members-only communications and privileges:

  • Member Directory
  • Member Alerts
  • RMAI Insights (Fall print and digital magazine)
  • RMAI Digital Dispatch (Spring digital publication)
  • RMAI Update (monthly e-newsletter)
  • And more!

Welcome, New Members

Debt Pursuit Group, LLC | TX
Jenkins Court Receivers, LLC | TX
Teton Valley Capital, LLC | WY
Tinker FCU | OK
Keith Wier, PLLC | TX
Monterey Financial Services, LLC | CA
Avtal, Inc | TX

For a complete list of RMAI members (including contact information), login to check out the Member Directory.

2026 RMAI Executive Summit | August 4-6, 2026

2027 Annual Conference | February 8-11, 2027

Contribute Now

RMAI LEGISLATIVE FUND CONTRIBUTORS SEPTEMBER 1, 2025 – SEPTEMBER 11, 2026

DIAMOND ($50,000+)

Crown Asset Management, LLC

PRA Group, Inc.

Resurgent Holdings, LLC

TITANIUM ($25,000+)

Absolute Resolutions Corp.

Cavalry Portfolio Services, LLC

Jefferson Capital Systems, LLC

Midland Credit Management

Second Round, LP

TRAKAmerica

PLATINUM ($10,000+)

Blitt and Gaines, P.C.

Cascade365 Family of Companies

Financial Recovery Services, Inc.

First Financial Asset Management, Inc. (FFAM 360)

Garnet Capital Advisors, LLC

Halsted Financial Services, LLC

InvestiNet, LLC

Pharus Funding, LLC

Plaza Services

Rausch Sturm, LLP

Stenger & Stenger P.C.

T & I Enterprises, LLC

TrueAccord

GOLD ($5,000+)

Andreu, Palma, Lavin & Solis,  PLLC

D & A Services, LLC

Klima, Peters & Daly, P.A.

National Credit Adjusters, LLC

Pressler, Felt and Warshaw, LLP

Provana, LLC

Security Credit Services, LLC

Tromberg, Miller, Morris & Partners, PLLC

Velo Law Office

SILVER ($2,500+)

Central Portfolio Control, Inc

Corporate Advisory Solutions, LLC

Kino Financial Co., LLC

Mountain Peak Law Group, PC

Stillman Law Office

Troutman Pepper Locke

Troy Capital, LLC

CONTRIBUTORS

Advancial Federal Credit Union

Aldridge Pite Haan, LLP

American Coradius International LLC

Arko Consulting LLC

ARM Compliance Business Solutions LLC

ARS National Services, Inc.

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.

Cohen & Cohen Law, LLC

Collection Attorneys USA LLC

CompuMail Information Systems

Connect International

ConServe

Consuegra & Duffy, PLLC

Converging Capital, LLC

Convoke, Inc.

Cornerstone Licensing Services

Cozen O’Connor

Credit Brokers LLC

Credit Control, LLC

Credit Management Corporation

D1AL

David Reid

Debt Sales Partners

Exelero Corp.

FDR Alliance LLC

First National Collection Bureau

Floatbot, Inc

FLOCK Specialty Finance

FMA Alliance, Ltd

FMS, Inc.

ForgiveCo PBC Inc

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Grassy Sprain Group, Inc

Guglielmo & Associates, PLLC

Healthcare Finance Direct, LLC

Hilco Receivables, LLC

Indiana Receivables, Inc.

Invenio Financial, a Phillips & Cohen Associates company

JT Lawson, LLC

Kompato AI Inc.

Landmark Strategy Group, LLC

Latitude Software

LexisNexis Risk Solutions

Mandarich Law Group LLP

Markoff Law LLC

National Enterprise Systems, Inc.

National Loan Exchange, Inc.

National Recovery Associates, Inc.

National Recovery Solutions, LLC

NCB Management Services, Inc.

NICE

Nutun CX (PTY) LTD

Nuvei Technologies Inc.

Orbita Capital Group, LLC

Overtime.ai

PCI Group Inc.

Phin Solutions, LLC

Poser Investments, Inc.

Premier Bankcard

Premium Asset Recovery Corp (PARC)

Primeritus Financial Services, Inc.

Pro Forma Inc

Quality Acceptance

Quantum3 Group, LLC

RevSpring

Risk Strategies

Robinson Hoover & Fudge, PLLC

Roosen, Varchetti & Olivier, PLLC

Rossman Kirk, PLLC

SAM – Solutions for Account Management, Inc.

SCJ Commercial Financial Services

Scott & Associates, PC

Shepherd Outsourcing, LLC

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solvo Solutions, LLC

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Suttell & Hammer

The Cadle Company

The Forwarders List of Attorneys

The Law Offices of Ronald S. Canter, LLC

The Moore Law Group

The Oakes Law Firm, LLC

The Receivers Office

Tobin & Marohn

Vargo & Janson, P.C.

Velocity Portfolio Group, Inc.

VeriFacts, LLC.

Womble Bond Dickinson

World Credit Recovery LLC

Yrefy, LLC