The Federal Regulatory and Legislative Committee is waiting patiently for the publication of the debt collection notice of proposed rulemaking. CFPB staff continues to confirm at several conferences that it will be published in Spring, 2019. In the meantime, the committee is activity seeking bipartisan support for RMAI’s data and documentation legislation on Capital Hill. RMAI leadership will be in DC the beginning of May with the focus being the new FTC commissioners, the CFPB leadership, and Capitol Hill.
STATE LEGISLATIVE ACTIVITY
RMAI is actively monitoring over 180 bills that may impact the receivables industry in both positive and negative ways. Here are a few noteworthy bills that have been introduced:
Colorado HB 1189 – The bill changes the amount subject to garnishment from 25% to 20% of the individual’s disposable weekly earnings and changes the wage exemption from 30 to 40 times the state minimum wage. [RMAI has a Colorado lobbyist who is actively finding ways to lessen the proposals impact, given that garnishment is frequently the final option for many and used when all else fails.]
Illinois HB 281 – This bill would adopt comprehensive reforms concerning the litigation of consumer debt, including but not limited to: (1) requiring a “large print” consumer notice with debtor’s rights be included with all summons issued in a debt collection matter; (2) requiring the court clerk to post a debtor’s rights notice in the hallway in front of courtrooms; (3) reducing the time period to revive a judgment; (4) changing the limitations period for the enforcement of certain judgments; (5) altering statutory provisions regarding wage garnishment, the homestead exemption, and personal property exemptions; and (6) providing that consumer debt judgments of $25,000 or less shall draw interest at a rate of 2% per annum. [Current negotiations are looking at a 10 year judgment statute with a 7 year renewal and 5 percent post-judgment interest.]
Indiana HB 1136 – This bill will provide some much needed clarification to new court rules adopted by Indiana that are scheduled to take effect on January 1, 2020. The court rules have been interpreted by many as having the potential of requiring debt buyers to provide point of sale receipts when bringing a legal action. The amendments which have been added to page 18 of the bill, clarify that if a signed contract or other writing evidencing the debtor’s agreement to the debt does not exist, a copy of a document provided to the debtor while the account was active is sufficient; which for a revolving credit account will include a copy of a charge-off statement or the most recent monthly statement recording a purchase transaction, a last payment, or a balance transfer. [RMAI has an Indiana lobbyist who was instrumental in getting the RMAI text added to HB 1136.]
Maine HB 776 – This bill would deem any judgment or decree of any court based upon a consumer obligation “paid and satisfied” at the end of one year unless within that period the judgment creditor has commenced an enforcement action on the judgment or decree. [RMAI is currently analyzing the bill’s likelihood of passage and based on that determining whether a lobbyist needs to be retained.]
Maryland HB 1256/SB 772 – This bill would increase the percent of wages that are exempt from garnishment from 30 times federal minimum wage to 45 times state minimum wage. [Due to the excellent work of a coalition of industry lobbyists, this bill has died.]
Massachusetts HB 205 – This bill would require passive debt buyers to be licensed as debt collectors in Massachusetts. Currently, third party collection agencies and active debt buyers are regulated and licensed by the Massachusetts Division of Banks while passive debt buyers are regulated by the Attorney General’s Office and not required to be licensed. This bill would also exempt debt buying companies from bonding requirements and allow affiliated companies to be licensed under a single license and subject to a single examination [RMAI has been advocating for uniformity and consistency in state licensing laws. Maintaining the Massachusetts bifurcated regulatory scheme does not make sense and adds to industry and consumer confusion. RMAI has retained a Massachusetts lobbyist to assist us in our efforts and anticipate a successful outcome.]
New York AB 6909/SB 4827 – This bill called the “Consumer Credit Fairness Act” would: (1) reduce the statute of limitations from six to three years on consumer credit transactions; (2) “extinguish” the right to collect on consumer debt past the statute of limitations; (3) require the mailing of a notice by the court clerk after filing proof of service of the summons and complaint; (4) require specific data to be included in the complaint; and (5) require the provision of form affidavits. [RMAI has a New York lobbyist and is working closely with a coalition of industry lobbyists to fight this bill.]
Washington HB 1602 – This bill would increase the exemptions a consumer could claim in matters involving “consumer debt” from $500 to $2,500 for bank accounts, savings and loan accounts, stocks, bonds, or other securities. This bill would also effectively exempt $35,000 in wages from garnishment. [RMAI, Encore & PRA have jointly retained a Washington lobbyist; unfortunately, our efforts to counter such a dramatic increase in exemptions are not resonating as we would hope in committee. Our lobbyist is now focusing on a floor vote strategy to stop the bill.]
Washington SB 5034 / HB 1066 – This bill would prohibit debt collectors from serving an individual with a summons and complaint prior to the filing of a lawsuit with the courts. [RMAI supports this bill.]
Consumer Privacy Bills – A number of states are looking to follow California’s lead in the adoption of a comprehensive consumer privacy statute. RMAI is tracking privacy bills in California, Hawaii, Maryland, New Mexico, New York, Rhode Island, and Washington.
If you are interested in obtaining a copy of the RMAI state tracking list, please contact David Reid at email@example.com.
Offering to ‘Resolve’ a Time-Barred Debt Can Violate FDCPA Absent Disclosures
The U.S. Court of Appeals for the Eleventh Circuit recently ruled that an offer to “resolve” a debt without disclosing its time-barred status may be deceptive or misleading under the federal Fair Debt Collection Practices Act (FDCPA) even in the absence of an express threat of litigation.
The letter at issue stated the debt collector wanted to “resolve” the consumer’s account by accepting a reduced amount by a specific date. The consumer filed a lawsuit alleging the letter was false and misleading in violation of 15 U.S.C. § 1692e.
Relying on Freyermuth v. Credit Bureau Services, Inc., 248 F.3d 767 (8th Cir. 2001), Huertas v. Galaxy Asset Management, 641 F.3d 28 (3d Cir. 2011), and Elrich v. Convergent Outsourcing, Inc., the trial court dismissed the complaint with prejudice because the letter “did not contain any language that could be interpreted as initiating or threatening legal action” on a time-barred debt.
The trial court distinguished the case from Daugherty v. Convergent Outsourcing, Inc., 836 F.3d 507 (5th Cir. 2016), Buchanan v. Northland Group., Inc., 776 F.3d 393 (6th Cir. 2015), and McMahon v. LVNV Funding, LLC, 744 F.3d 1010 (7th Cir. 2014), which held that using the word “settle” could imply an impermissible threat of litigation when used with respect to a time-barred debt.
The trial court was of the opinion that “resolve” did not rise to the same level of litigation threat as “settle.”
Violation Can Occur Without Express Threat of Litigation
On appeal, the Court was persuaded by the very decisions from which trial court distinguished the case. Following the reasoning of those cases, the Court concluded that “an express threat of litigation is not required to state a claim for relief under § 1692e so long as one can reasonably infer an implicit threat.”
The Court noted that the deadline for the payment and the notice that there was no obligation to renew the offer heightened the possibility of such an inference. Further, the Court was not convinced that the word “resolve” was “materially distinguishable” from the word “settle.”
Although the defendants argued it would be “untenable” to require debt collectors to “analyze and advise debtors as to the merits of any potential statute of limitations defense,” the Court saw no such burden. Quoting Buchanan, “if a debt collector is unsure about the applicable statute of limitations, it would be easy to include general language about that possibility. . .”
Thus, in reversing the decision of the trial court on this issue, the Court held that any language that could reasonably imply the threat of litigation on time-barred debt violates the FDCPA unless accompanied by a notice that the debt is, in fact, time-barred.
NY Trial Court Dismisses Similar Claim
Another recent case on the issue presents an interesting comparison.
In Hollander v. Alliant Capital Mgmt., LLC, No. 18-CV-02808 (DLI)(VMS), 2019 U.S. Dist. LEXIS 58381 (E.D.N.Y. Mar. 31, 2019), the plaintiff argued that a collection letter violated the FDCPA by failing to disclose that the time-barred debt could not be enforced by legal action and that a partial payment might restart the statute of limitations.
The decision noted that the Second Circuit Court of Appeals has yet to address the issue of whether “time-barred” debt disclosures are required but dismissed the claim, nonetheless.
Although the FDCPA claim was premised on a debt being collected after the statute of limitations had expired, the court found that the complaint offered no factual allegations to support that conclusion because it: 1) did not state the date the debt was incurred; 2) did not state which statute of limitations applied; and 3) did not specify when the statute of limitations expired.
Therefore, the plaintiff’s claim was an “unadorned legal conclusion.” The complaint filed with the trial court in Holzman in the Southern District of Florida similarly failed to plead those elements.
U.S. Supreme Court Holds FDCPA Has Extremely Limited Applicability to Persons Engaging in Nonjudicial Foreclosure Proceedings
The U.S. Supreme Court handed down this much-anticipated opinion on March 20th, ruling the federal Fair Debt Collection Practices Act (“FDCPA”) does not cover persons engaged in “non-judicial foreclosures” except with respect to a single provision contained in the FDCPA.
A Colorado borrower defaulted on his home loan and the mortgage servicer hired a law firm to pursue a non-judicial foreclosure. The borrower informed the law firm he was disputing the debt and the law firm, without responding to the dispute, proceeded with the non-judicial foreclosure. Colorado, like many western states, has a procedure that allows a lender to foreclose property without the need to file a lawsuit.
The borrower then filed a lawsuit against the mortgage servicer and law firm alleging, among other things, violation of the FDCPA by proceeding with the foreclosure without first providing verification of the debt in response to his dispute as required by 15 U.S.C. § 1692g(b). The mortgage servicer and law firm filed motions to dismiss.
The FDCPA defines a debt collector as persons engaged “in any business the principal purpose of which is the collection of any debts, or who regularly collects or attempts to collect, directly or indirectly, debts.” The Colorado borrower alleged this included the law firm and mortgage servicer.
However, the FDCPA’s definition of a debt collector also states that “[the] term [debt collector] also includes any person . . . in any business the principal purpose of which is the enforcement of security interests” for purposes of section 1692f(6). The law firm believed this provision excluded its efforts undertaken in the nonjudicial foreclosure.
The trial court agreed with the law firm and mortgage servicer and granted their motions to dismiss, determining that the mortgage servicer was not a “debt collector” under the FDCPA because the loan was not in default when it began servicing the loan. The trial court also found the law firm’s nonjudicial foreclosure activities were “outside the scope of the FDCPA.”
The borrower appealed and the U.S. Court of Appeals for the Tenth Circuit affirmed the District Court’s decision, explaining that despite findings to the contrary by three other circuits (the Fourth, Fifth, and Sixth) and the Colorado Supreme Court, a nonjudicial foreclosure is not an attempt to collect money. Therefore, the “mere act of enforcing a security interest through a non-judicial foreclosure proceeding does not fall under the FDCPA.”
The Supreme Court first looked to the language of the FDCPA that provides a “general” definition for “debt collector.” However, that subsection also provides: “For the purpose of section 808(6) [15 U.S.C. § 1692f(6), such term also includes any person who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the enforcement of security interests.” (emphasis added).
Focusing on the italicized terms above, and particularly the word “also,” the Court stated the phrase “strongly suggests that one who does no more than enforce security interests does not fall within the scope of the general definition. Otherwise why add this sentence at all?”
Second, the Court explained that it makes sense to “treat security-interest enforcement differently from ordinary debt collection in order to avoid conflicts with state nonjudicial foreclosure schemes.” As an example, the Court noted state nonjudicial foreclosures procedures include consumer protection provisions, some of which are in conflict with the FDCPA, such as the requirement to publicize the sale.
Third, the Court looked to the legislative history which evidenced conflicting proposals regarding the applicability of the entire FDCPA to persons who enforce security interests. “Given these conflicting proposals, the Act’s present language has all the earmarks of a compromise: The prohibitions contained in §1692f(6) will cover security-interest enforcers, while the other ‘debt collector’ provisions of the Act will not.”
Accordingly, the Court concluded with the seemingly narrow holding that “but for §1692f(6), those who engage in only nonjudicial foreclosure proceedings are not debt collectors within the meaning of the Act.”
2nd Cir. Holds FDCPA Does Not Require Itemization of ‘Amount of the Debt’
The U.S. Court of Appeals for the Second Circuit held that a debt collection letter that informed the consumer of the total, present amount of his or her debt satisfied section 1692g of the FDCPA notwithstanding its failure to itemize and specifically describe the “interest, late charges, and other charges that may vary from day to day.” In doing so, the court distinguished its holding in Carlin v. Davidson Fink LLP, explaining that Carlin involved a future estimated “Total Amount Due.” Here, stating the current amount owed as of the date of the letter and providing the safe harbor language adopted in Avila v. Riexinger & Assocs., LLC was sufficient.
SD Fla. Denies FDCPA Class Certification Due to Individual Issues of ‘Actual Damages
The U.S. District Court for the Southern District of Florida recently denied a consumer’s motion for class certification in a putative class action against a debt collector. In so ruling, the Court concluded that the plaintiff’s proposed class, which included members seeking actual damages as well as members seeking only statutory damages, presented individual issues concerning causation as to actual payments made in response to the collection letters at issue, and thus failed to overcome the predominance requirement under Fed. R. Civ. P. 23(b)(3).
The plaintiff stopped making payments on his credit card account and the defendant debt collector sent the plaintiff a letter stating that “[t]he law limits how long you can be sued on a debt. Because of the age of your debt, we will not sue you for it.” However, the letter did not warn the consumer that that partial payment would renew the statute of limitations.
The consumer filed suit in federal court alleging that the failure to explain the effect of a partial payment on the statute of limitations was unconscionable and that the letter was false, misleading, or deceptive in violation of the federal Fair Debt Collection Practices (“FDCPA”) and the Florida Consumer Collection Practices Act (“FCCPA”).
The debt collector’s motion to dismiss the consumer’s complaint was denied, with the Court concluding that the collection letter language could give the least sophisticated consumer the misleading impression that the debt was legally enforceable. The consumer then filed his motion for class certification and appointment of class representative and class counsel.
The debt collector objected to the consumer’s request for certification of the class, in part, on the basis that the consumer’s request for actual damages defeated class certification as predominance under Rule 23(b)(3) were not shown.
The Court concluded that the proposed class, which included members seeking only statutory damages and members seeking actual damages would not “achieve economies of time, effort, and expense” or promote “uniformity of decision as to persons similarly situated, without sacrificing procedural fairness or bringing about other undesirable results.”
Although “individual damage calculations generally do not defeat a finding that common issues predominate” and a class action may be maintained despite the need to provide individual damages, the Court found that the claims of the proposed class members who sought recovery of actual damages presented individual issues, both as to the nature and content of the debt collector’s communications with each member, and liability to the extent the debt collector is entitled to address questions of causation as to each member.
5th Cir. Holds No ‘Detrimental Reliance’ Exception to Unilateral Withdrawal of Acceleration Notice
The U.S. Court of Appeals for the Fifth Circuit recently held that Texas law contains no detrimental reliance exception to a lender’s unilateral right to withdraw an acceleration notice.
A borrower defaulted on a Texas home equity fixed adjustable rate note secured by a Texas home equity security instrument. In 2010, the mortgagee through its then loan servicer sent the borrower notice of its intent to accelerate the note and demanded full payment of the debt. The mortgagee filed suit and obtained an agreed final judgment of foreclosure in 2011. The borrower then vacated the property.
In 2012, the mortgagee’s new loan servicer sent a new notice of default demanding less than the full amount of the debt to cure her default. In 2015, the borrower conveyed her interest in the property to a third party via special warranty deed. In turn, the third party transferred its interest in the property to a corporation.
The mortgagee’s servicer re-initiated the prior foreclosure proceeding. In response, the corporation filed a state court action against the mortgagee and its servicer alleging that the lien on the property was void because the foreclosure was not filed within the four-year statute of limitation.
The mortgagee and the servicer removed the case to federal court on diversity grounds. The corporation amended its complaint to allege that the borrower’s detrimental reliance on the acceleration notice barred the mortgagee and the servicer from abandoning the 2012 acceleration. The parties filed cross-motions for summary judgment and the trial court found the corporation could not show that it detrimentally relied on the acceleration notice and entered summary judgment in favor of the mortgagee and its servicer.
On appeal, the Fifth Circuit noted that under Texas law, “[a] person must bring suit for . . . the foreclosure of a real property lien not later than four years after the day the cause of action accrues” or the lien becomes void. Tex. Civ. Prac. & Rem. Code Ann. § 16.035(a); § 16.035(d). Further, if the note contains an optional acceleration clause, then “the action accrues only when the holder actually exercises its option to accelerate.”
The lender may abandon the acceleration “either by the lender’s unilateral actions or by agreement, thereby suspending the limitations period until the lender exercises its option to re-accelerate the note.” Requesting payment of less than the full debt owed after accelerating the full amount owed is “an unequivocal expression of the bank’s intent to abandon or waive its initial acceleration.
In 2015, the Texas legislature passed Texas Civil Practice and Remedies Code § 16.038, subsection (a) of which provides that: “If the maturity date of a series of notes or obligations or a note or obligation payable in installments is accelerated, and the accelerated maturity date is rescinded or waived . . . before the limitations period expires, the acceleration is deemed rescinded and waived and the note, obligation, or series of notes or obligations shall be governed . . . as if no acceleration had occurred.”
This statute provides no exceptions to a lender’s right to unilaterally withdraw the acceleration. Accordingly, the Fifth Circuit held that “detrimental reliance is not an exception to the lender’s right to unilaterally withdraw an acceleration notice under Texas law” and affirmed the trial court’s order granting the mortgagee’s motion for summary judgment.
7th Cir. Holds Erroneously Recorded Satisfaction May Be Unilaterally Cancelled and Withdrawn
Trinity 83 Dev., LLC v. ColFin Midwest Funding, LLC, No. 18-2117, 2019 U.S. App. LEXIS 6370 (7th Cir. Mar. 1, 2019)
The U.S. Court of Appeals for the Seventh Circuit recently held that a mortgagee could unilaterally cancel an erroneously recorded satisfaction of the loan where the borrower had not yet detrimentally relied on the erroneous satisfaction.
A company took out a loan from a bank secured by a mortgage. The bank sold the loan to a debt buyer. The debt buyer used a debt collector to collect payments. The debt collector inadvertently recorded a satisfaction of the debt releasing the mortgage before the company paid off the loan. The debt buyer realized the mistake and recorded a document cancelling the satisfaction before the company relied on it to its detriment.
After the debt buyer recorded the document cancelling the satisfaction, the company defaulted on the loan and the debt buyer commenced a foreclosure action in Illinois state court. The company then filed for bankruptcy in federal court which stayed the foreclosure action.
The company filed an adversary proceeding against the debt buyer alleging that the release and satisfaction of the mortgage extinguished both the loan and the mortgage. The bankruptcy court rejected this argument, finding that the debt buyer could unilaterally correct a unilateral error. The trial court agreed with the bankruptcy court, and the appeal followed.
In affirming the lower court’s decision, the Seventh Circuit began by noting that the company obtained no rights from the mistaken satisfaction because it was “unilateral and without consideration.” Thus, “it was not a contract.” Because the company did not rely upon the satisfaction to its detriment, the company could unilaterally rescind it under Illinois law which treats “a mistaken release of a mortgage as ineffective between the mortgagor and mortgagee.”
The company argued that the mortgage supported its position that the debt buyer irrevocably waived its rights under the mortgage by recording the signed satisfaction. To make this argument the company relied on the mortgage clause stating that the “Lender shall not be deemed to have waived any rights under this Mortgage unless such waiver is given in writing and signed by Lender.”
The Seventh Circuit had little trouble rejecting this reading of the mortgage because to say “only A can accomplish B” does not say that “every A accomplishes B.” Instead, the “no-waiver clause negates oral waivers and waivers implied from conduct.”
For example, the Appellate Court noted, when the lender accepts a late payment, it does not waive the payment deadline. As such, the mortgage “language does not mean that mistaken unilateral writings are beyond recall.”
Need re-certification credits? Working toward becoming a Certified Receivables Compliance Professional (CRCP)? Want the latest information in the Chief Compliance Officer world? RMAI has all this and more with live monthly and pre-recorded webinars.
- How to Get A Clean Bill of Health in Healthcare Debt Buying and Collection – Tuesday, April 30, 2019
RECORDED WEBINARS: Did you miss a live webinar? All recorded monthly webinars are FREE to our members. Special series and select required courses for certification are paid at member rate.
CURRENT ISSUES IN DEBT BUYING (RE-CERTIFICATION ONLY): In addition to the two (2) hour education session at the Annual Conference and Executive Summit, RMAI has identified the following recorded webinars which qualify for one (1) credit out of the four (4) credits of Current Issues in Debt Buying required for re-certification. Click to register.
- Cease-and-Desist Demands, Response Techniques and Best Practices
- 5 Proven Steps to Avoid Litigation or Minimize Cost of Litigation
- CCO: Bridging the Gap: Compliant Communications with Millennials & iGens
- Industry Hot Topics – A Year in Review
- Demand Letters and Disclosure Requirements
- Surveying the TCPA Litigation Landscape After Marks
Need “live/in person” continuing education credits for certification? Members who are seeking to earn live credits in order to obtain RMAI’s Certified Receivables Compliance Professional (CRCP) designation can do so at the upcoming Executive Summit, July 30 – August 1, 2019 at the Hilton Sedona Resort at Bell Rock in Sedona, AZ. You can also contact one of our Authorized Education Providers who may have a live seminar in your area. Be sure to check out the certification tab on our website.
Congratulations to our new and renewed companies and individuals!
Sandia Resolutions Company, LLC
Trace Dillon, USASF Servicing, LLC
William Marohn, Tobin & Marohn
John Myers, Caine & Weiner
Tessie Saich, Investment Retrievers
Chris Straiter, Sentry Credit, Inc.
Dale Dobberpuhl, Premier Bankcard
Heather Kochamba, Galaxy Capital Acquisitions, LLC
Lauren Savage, Frontline Asset Strategies, LLC
For help with certification, contact Michelle Wren at (916) 482-2462 or firstname.lastname@example.org
Welcome new RMAI members!
The RMAI membership continues to grow. Welcome to our newest members:
|Admerex Solutions, Inc.||Associate Collection Agency||Philippines|
|Advanced Recovery Services, LLC||Associate Collection Agency||UT|
|Enhanced Resource Centers||Associate Collection Agency||FL|
|GreenSquare Company||Associate Debt Buyer||NY|
|HarrisLoftus, PLLC||Associate Law Firm||VA|
|Kino Financial Co., LLC||Associate Debt Buyer||AZ|
|Scott & Associates, PC||Associate Law Firm||TX|
|United Acquisitions, LLC||Associate Debt Buyer||CA|
|William H. Brosha, PLLC||Associate Law Firm||AZ|
|Windham Professionals, Inc.||Associate Collection Agency||TN|
Read more about these members and other members on the Member Search page
RMAI is planning a new in-person event to bring members and non-members together for an evening of fun, food and networking. Meet and mingle with other industry professionals all while watching an exciting major league baseball game between the Chicago Cubs and Cincinnati Reds. Registration will soon be available. Interested in being a sponsor? Read all about it here.
HR Spotlight Brought to You by the RMAI & Insperity Partnership:
5 trusty tips for hiring candidates you can’t afford
Thank you to our April 2018 – April 15, 2019 legislative fund contributors!
Certified Debt Buyer
Cavalry Portfolio Services, LLC
Associate Collection Agency
Financial Recovery Services, Inc.
Certified Debt Buyer
Encore Capital Group
Certified Debt Buyer
Crown Asset Management, LLC
Certified Debt Buyer
Jefferson Capital Systems, LLC
Plaza Services, LLC
Second Round, LP
Velocity Portfolio Group
Digital Recognition Network
Certified Debt Buyer
Absolute Resolutions Corp
Resurgence Capital, LLC
Security Credit Services, LLC
The Bureaus, Inc.
Associate Collection Agency
Glass Mountain Capital
National Loan Exchange NLEX
Certified Debt Buyer
First Financial Asset Management, Inc. FFAM360
Gemini Capital Group, LLC
HS Financial Group
Indiana Receivables, Inc.
The Cadle Company
Certified Law Firm
Peroutka, Miller, Klima & Peters, P.A.
Certified Collection Agency
Resurgent Capital Services
Associate Law Firm
Andreu, Palma, Lavin & Solis, PLLC
Malone and Martin, PLLC
Stenger & Stenger P.C.
Associate Collection Agency
Credit Control, LLC
RNN Group, Inc.
— In Memory of Trish Baxter
Kino Financial Co., LLC
Certified Debt Buyer
Acctcorp International, Inc.
Capio Partners, LLC
Collins Asset Group LLC
Credit Management Corporation
Dynamic Recovery Solutions
Federal Pacific Credit Company
Galaxy Capital Acquisitions, LLC
Icon Equities, LLC
Investment Retrievers, Inc.
Mid Atlantic Portfolios, LLC
NCB Management Services, Inc.
PCA Acquisitions V, LLC
Pharus Funding, LLC
Portfolio Group Investors, LLC
Portfolio Recovery Associates, LLC
Poser Investments, Inc.
Troy Capital, LLC
Unifund CCR LLC
West Bay Recovery, Inc.
Certified Law Firm
Reynolds Sims & Associates, P.C.
Law Offices of Steven Cohen, LLC
Certified Collection Agency
Full Circle Financial Services, LLC
Halsted Financial Services, LLC
Associate Debt Buyer
Alliance Credit Services, Inc.
Genesis Recovery Services
International Debt Buying Consultants, LLC
National Recovery Solutions, LLC
Phoenix Asset Group, LLC
Sandia Resolution Company, LLC
Western States Financial Management, LLC
Associate Law Firm
Brownstein Hyatt Farber Schreck, LLP
Butler & Associates, P.A.
Delev & Associates, LLC
Hudson Cook, LLP
Hunt & Henriques
Kirschenbaum & Phillips, PC
London & London
Maurice Wutscher LLP
Mullooly, Jeffrey, Rooney & Flynn, LLP
Pressler, Felt and Warshaw, LLP
Rausch, Sturm, Isreal, Enerson & Hornik, LLC
Simmonds & Narita LLP
Slovin & Associates
Sonnek & Goldblatt, Ltd.
Spencer Fane LLP
The Law Offices of Ronald S. Canter, LLC
Tobin & Marohn
Vargo & Janson, P.C.
Winn Law Group, APC
Associate Collection Agency
Capital Collection Management, LLC
Noble Financial Solutions, Inc.
Radius Global Solutions
Tate & Kirlin Associates, Inc.
Viking Client Services, Inc.
Accelerated Data Systems
CenterPoint Legal Solutions, LLC
Clear Payment Solutions
Comtronic Systems, LLC
Diversified Consultants, Inc.
FLOCK Specialty Finance
Harvest Strategy Group, Inc.
Metronome Financial, LLC
MRS BPO, LLC
Ontario Systems, LLC
Payment Brokers Group, LLC
PCI Group Inc.
Resource Management Services, Inc.
SAM, Inc. – Solutions for Account Management
Vertican Technologies, Inc.
Capital Solutions Bancorp, LC