OCC and FDIC Issue NPRMs to Fix Madden and Clarify the Validity of the ‘Valid When Made’ Doctrine
The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) both recently issued proposed rules to “fix” the potential problems arising from the ruling in Madden v. Midland Funding, LLC, 786 F.3d 246 (2nd Cir. 2015), which called into question the “valid when made” doctrine.
In addition, the FDIC’s proposal would make clear that the permissible interest on a loan would be determined at the time the loan is made, regardless of subsequent events such as changes in state law or the sale or assignment of the loan.
The OCC’s Notice of Proposed Rulemaking is available at: Link to OCC’s NPRM.
The FDIC’s Notice of Proposed Rulemaking is available at: Link to FDIC’s NPRM.
Federal law allows national banks and federal savings associations to charge interest at the “most favored lender” rate — i.e., the maximum rate permitted to any state-chartered or licensed lending institution in the state where the bank is located — and authorizes national banks and federal savings associations to make, purchase, and sell loans.
FDIC-insured state banks have parallel rights under other federal law.
However, as we reported in our prior update, the U.S. Court of Appeals for the Second Circuit in Madden essentially held that loans that are completely legal when made by a national bank subsequently become illegal if the national bank sells or assigns them to a non-national bank purchaser or assignee.
According to the Second Circuit, the federal banking laws only preempt state usury laws as long as the loan remains in the hands of a national bank, but not if the loan is subsequently sold or assigned to an entity that is not a national bank or a person collecting interest for a national bank.
This meant that the loan purchaser defendant in the Madden case, which was not a national bank, violated the federal Fair Debt Collection Practices Act by charging illegal interest on the loans it purchased from national banks.
The Supreme Court of the United States subsequently denied the defendant’s petition for a writ of certiorari in June of 2016. This essentially allowed the Madden ruling to stay in effect.
The OCC states that its proposed rule “would clarify that when a bank sells, assigns, or otherwise transfers a loan, interest permissible prior to the transfer continues to be permissible following the transfer.”
Likewise, the FDIC’s proposed rule “would provide that State banks are authorized to charge interest at the rate permitted by the State in which the State bank is located, or one percent in excess of the ninety-day commercial paper rate, whichever is greater.”
The FDIC’s proposed rule would also “provide that whether interest on a loan is permissible [federal law] would be determined at the time the loan is made, and interest on a loan permissible under section 27 would not be affected by subsequent events, such as a change in State law, a change in the relevant commercial paper rate, or the sale, assignment, or other transfer of the loan.”
Comments are due January 21st, and RMAI will be issuing comments on this important rule.
RMAI is actively monitoring over 200 bills that may impact the receivables industry in both positive and negative ways. Here are a few noteworthy bills that have been introduced:
Massachusetts HB 3949 – 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 [This bill was unanimously reported out of the Joint Committee on Consumer Protection & Professional Licensure on 7/1/19. 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-B/SB 4827-B – 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. The coalition participated in a roundtable discussion with the Senate sponsor and consumer groups on November 26th in New York City in an attempt to find some common ground. The meeting went better than the industry anticipated but there remains a lot of work to be done to find common ground.]
Ohio HB 251 – This bill would decrease the statute of limitations from 8 years to 6 years on a written contract and 4 years on an oral contract. [RMAI and a coalition of RMAI members were able to prevent an amendment to the bill that would further reduce the SOL to 3 years. In addition, language was added to end the Ohio borrowing statute in certain circumstances. The bill has been passed by the House and is now being considered in the Senate.]
If you are interested in obtaining a copy of the RMAI state tracking list, please contact David Reid at firstname.lastname@example.org.
7th Cir. Reverses Dismissal of FDCPA Claim Involving Statement That 1099C Form May Be Filed
The defendant sent dunning letters to the debtor that offered various settlement options, all of which would have saved the debtor less than $600 off the amount owed. One letter stated that settling a debt for less than the total amount owed “may have tax consequences” and the creditor “may file a 1099C form.”
The debtor sued, alleging the “1099C clause” violated sections 1692e and 1692f of the FDCPA. Section 1692e prohibits debt collectors from using “false, deceptive, or misleading misrepresentation[s] or means in connection with the collection of a debt,” and under section 1692f, “a debt collector may not use unfair or unconscionable means to collect or attempt to collect any debt.” The trial court granted the debt collector’s motion to dismiss.
On appeal, the Seventh Circuit noted that it had recently decided Dunbar v. Kohn Law Firm, S.C., 896 F.3d 762 (7th Cir. 2018), in which the debt collector sent a letter that stated “NOTICE: This settlement may have tax consequences.” In that case the Court found that the clause did not violate the FDCPA because it “is literally true and not misleading under the objective ‘unsophisticated consumer test.’”
However, the Seventh Circuit ruled that the 1099C clause here was a different matter because whether a 1099C form will be filed “is information within the knowledge of the creditor. . . Only the debtor knows whether, given her financial situation as a whole, she will have to pay taxes on the forgiven debt. The creditor, however, knows whether it will have to file a 1099C form or not … [because] [t]he Internal Revenue Service requires a creditor to file a 1099C form if it has forgiven at least $600 in principal.”
Because, on a motion to dismiss, the Court “must accept as true all well-pleaded allegations and draw all reasonable inferences in favor of the plaintiff” and because as to the 1099C clause it was clear to the Seventh Circuit that the creditor would never file a 1099C form because the amount in each offer was less than $600, the Seventh Circuit concluded that the plaintiff “plausibly alleged” that the “statement that [the creditor] might file a 1099C form is misleading” and reversed and remanded the case to the trial court for further proceedings.
9th Cir. Holds FCRA ‘Permissible Purpose’ Plaintiff Had Standing, Establishes Elements for Such Claims
In a case of first impression in that circuit, the U.S. Court of Appeals for the Ninth Circuit reversed a trial court’s dismissal of a consumer’s Fair Credit Reporting Act (FCRA) claim for lack of standing and failure to state a claim, holding that the plaintiff did have Article III standing.
The consumer reviewed her credit report from one of the “big three” credit reporting agencies and discovered that a bank with whom she allegedly had no prior or existing relationship had requested her credit report. The consumer filed suit alleging that the bank violated the FCRA by obtaining her credit report without her consent and not for any of the purposes authorized under the Act. The trial court dismissed the complaint with prejudice for lack of standing and failure to state a claim and the plaintiff appealed.
On appeal, the Ninth Circuit noted that the case presented two issues of first impression in that circuit: “(1) whether a consumer suffers a concrete Article III injury in fact when a third-party obtains her credit report for a purpose not authorized by the FCRA and (2) whether the consumer-plaintiff must plead the third-party’s actual unauthorized purpose in obtaining the report to survive a motion to dismiss.”
The Court answered “yes” to the first question and “no” to the second, holding that “a consumer suffers a concrete injury in fact when a third-party obtains her credit report for a purpose not authorized by the FCRA. . . and a consumer-plaintiff need allege only that her credit report was obtained for a purpose not authorized by the statute to survive a motion to dismiss.”
The Court noted that the FCRA prohibits a person from using or obtaining a consumer report for any purpose unless it is obtained for an authorized purpose and the user certifies the authorized purpose for which it is obtained or used. Additionally, the FCRA provides that a “consumer reporting agency” can only furnish a consumer report for certain enumerated purposes “and no other.” See 15 U.S.C. § 1681(b)(a).
The Ninth Circuit noted the case primarily involved “injury in fact,” explaining that “[t]o establish injury in fact, a plaintiff must show that he or she suffered ‘an invasion of a legally protected interest’ that is ‘concrete and particularized’ and ‘actual or imminent, not conjectural or hypothetical.’” . . . ‘Concrete’ is not, however, necessarily synonymous with ‘tangible.’ Although tangible injuries are perhaps easier to recognize . . . intangible injuries can nevertheless be concrete.’”
“‘In determining whether an intangible harm constitutes injury in fact, both history and the judgment of Congress play important roles … [and] it is instructive to consider whether an alleged intangible harm has a close relationship to a harm that has traditionally been regarded as providing a basis for a lawsuit in English or American courts.’ … ‘The … injury required by Art. III may exist solely by virtue of ‘statutes creating legal rights, the invasion of which creates standing.’”
The Ninth Circuit further recited that “a bare procedural violation may not establish a concrete harm sufficient for Article III standing[,]” but “an alleged procedural violation [of a statute] can by itself manifest concrete injury where Congress conferred the procedural right to protect a plaintiff’s concrete interests and where the procedural violation presents ‘a risk of real harm’ to that concrete interest.”
The Court also explained that it has “recognized a distinction between violations of a procedural right …and a substantive right … [and a] violation of a substantive right invariably ‘offends the interests that the statute protects.’”
Thus, the Court explained first that the plaintiff had standing to sue under the FCRA because “obtaining a credit report for a purpose not authorized under the FCRA violates a substantive provision of the FCRA” rather than simply a procedure.
Second, the Court noted that it had “previously found the invasion of the interest at issue — the right to privacy in one’s consumer credit report — confers standing.”
“Third, historical practice also supports a finding of standing . . . The harm attending a violation of §1681b(f)(1) of the FCRA is closely related to – if not the same as – a harm that has traditionally been regarded as providing a basis for a lawsuit: intrusion upon seclusion (one form of the tort of invasion of privacy).”
The Ninth Circuit concluded that the plaintiff had “standing to vindicate her right to privacy under the FCRA when a third-party obtains her credit report without a purpose authorized by the statute, regardless whether the credit report is published or otherwise used by that third-party.”
The Court then turned to the second issue of first impression: “Must the consumer-plaintiff plead the third-party’s actual unauthorized purpose in obtaining the credit report to survive a motion to dismiss?” In answering “no,” the Court found that a “plaintiff need allege only facts giving rise to a reasonable inference that the defendant obtained his or her credit in violation of §1681b(f)(1) to meet their burden of pleading,” and the defendant bears “the burden of pleading it had an authorized purpose.”
The Court explained that “placing the burden on the plaintiff would be unfair, as it would require the plaintiff to plead a negative fact that would generally be peculiarly within the knowledge of the defendant.” In this case, the complaint contained “sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’”
Accordingly, the trial court’s order of dismissal was reversed and the case was remanded.
3rd Cir. Holds Failure to Turn Over Collateral Repossessed Prior to Bankruptcy Does Not Violate Automatic Stay
The U.S. Court of Appeals for the Third Circuit recently held, in a case of first impression in that circuit, that a secured creditor’s failure to turn over collateral repossessed prior to the filing of the bankruptcy petition does not violate the automatic stay.
The debtor’s automobile was repossessed after she defaulted on her installment loan. She then filed a voluntary petition under Chapter 13 of the Bankruptcy Code, notified her creditors and demanded the return of the automobile. The creditors did not comply, and the debtor filed a motion for turnover and for sanctions for violating the automatic stay.
The Bankruptcy Court entered an order requiring the creditors to return the automobile to the debtor because the automobile was property of the estate under section 542(a) of the Bankruptcy Code, but denied the request for sanctions.
In so ruling, the Bankruptcy Court adopted the minority view “that a creditor does not violate the stay in regard to property of the estate if it merely maintains the status quo.” The majority view is “that Section 542(a)’s turnover provision ‘is self-effectuating’ because ‘it does not allow for the possibility of defenses to turnover.’”
The District Court affirmed the Bankruptcy Court, and the debtor appealed to the Third Circuit.
On appeal, the Third Circuit noted that it was presented with an issue of first impression: “Whether, upon notice of the debtor’s bankruptcy, a secured creditor’s failure to return collateral that was repossessed pre-bankruptcy petition is a violation of the automatic stay.”
The Court answered “no,” joining the minority position taken by the Tenth and D.C. Circuits, “holding that a secured creditor does not have an affirmative obligation under the automatic stay to return a debtor’s collateral to the bankruptcy estate immediately upon notice of the debtor’s bankruptcy because failure to return the collateral received pre-petition does not constitute an act “to exercise control over property of the estate’” under Code section 362(a)(3). The Court thus affirmed the District Court’s order affirming the Bankruptcy Court.
Thus, the Third Circuit rejected the majority position, held by the Second, Seventh, Eighth, Ninth and Eleventh Circuits, that “a secured creditor, upon learning of the bankruptcy filing, must return the collateral to the debtor and failure to do so violates the automatic stay” because doing so violates section 362(a)’s prohibition on any act “to exercise control of property over the estate.” Under these rulings, “Section 362(a)(3)’s automatic stay provision and Section 542(a)’s turnover provision operate together such that a violation of the turnover provision results in a violation of the automatic stay.”
The Court began by examining the statutory language of section 362(a)(3), explaining that “[i]f we ultimately determine that a provision ‘is clear and unambiguous, [we] must simply apply it.’ However, if we find that a provision is ambiguous, ‘we then turn to pre-Code practice and legislative history to find meaning.’”
Although the Third Circuit agreed “that Section 362(a)(3) is unambiguous, [it declined] to hold that a plain reading of that Section compels the conclusion that the creditors in this case violated the automatic stay by failing to turn over the [automobile] to [the debtor].”
The Court concluded that “the text of Section 362(a)(3) requires a post-petition affirmative act to exercise control over property of the estate” which was not present in this case because the car was repossessed before the debtor filed bankruptcy. After the filing of the petition, “the creditors merely passively retained that same possession and control.”
The Third Circuit further reasoned that its conclusion “is bolstered by the legislative purpose and underlying policy goals of the automatic stay. It is well-established that one of the automatic stay’s primary purposes is ‘to maintain the status quo between the debtor and [his] creditors, thereby affording the parties and the [Bankruptcy] Court an opportunity to appropriately resolve competing economic interests in an orderly and effective way.’”
By retaining possession of the car “after learning of the bankruptcy filing, the creditors preserved the pre-petition status quo. To hold that such a retention of possession violates the automatic stay would directly contravene the status-quo aims of the automatic stay.”
The Third Circuit rejected the debtor’s argument that the section 542(a) turnover provision was “self-executing,” reasoning that “a creditor’s obligation to turn over estate property to the debtor is not automatic. Rather the turnover provision requires the debtor to bring an adversary proceeding in Bankruptcy Court in order to give the Court the opportunity to determine whether the property is subject to turnover under Section 542(a).”
11th Cir. Reverses Denial of Class Cert in Challenge to Post-Discharge Mortgage Statements
In a putative class action of borrowers who received mortgage statements after a bankruptcy discharge, the U.S. Court of Appeals for the Eleventh Circuit recently reversed a trial court order denying certification for failure to establish predominance.
In so ruling, the Eleventh Circuit held that a mortgage servicer’s affirmative defense, that it is not liable under the federal Fair Debt Collection Practices Act (FDCPA) and the Florida Consumer Collection Practices Act (FCCPA) because the only remedy for violating a discharge injunction is under the Bankruptcy Code, requires no individualized inquiries and is common to all class members.
The named-plaintiff borrowers obtained a home loan secured by a mortgage. After the borrowers defaulted, the note holder filed foreclosure. The borrowers then filed for Chapter 7 bankruptcy protection. The borrowers did not reaffirm the debt, vacated the property, and the bankruptcy court entered a discharge order pursuant to section 524(a)(2) that relieved them from any personal liability on the mortgage debt.
After the discharge order, the note holder’s mortgage servicer sent the borrowers multiple monthly statements for their mortgage loan. In response the borrowers sued the mortgage servicer on behalf of themselves and a putative class alleging claims arising out of the FDCPA and the FCCPA.
The named-plaintiff borrowers alleged that the servicer violated the FDCPA because sending the monthly statements falsely represented that the servicer “had a legal right to collect the mortgage debt from the [borrowers] and also falsely represented the legal status of the debt.” The named-plaintiff borrowers also claimed that the servicer violated the FCCPA as the mortgage statements allegedly “claim[ed] and attempt[ed] to enforce a debt which was not legitimate and not due and owing.”
Relevant to this appeal, the servicer raised an affirmative defense that the Bankruptcy Code precluded the FDCPA and FCCPA claims.
The borrowers moved for class certification and asked the trial court to certify the following class:
All Florida consumers who (1) have or had a residential mortgage loan serviced by [the servicer], which [the servicer] obtained when the loan was in default; (2) received a Chapter 7 discharge of their personal liability on the mortgage debt; and (3) were sent a mortgage statement dated September 11, 2013 or later, in substantially the same form [as mortgage statements the borrowers received that] was mailed to the debtor’s home address in connection with the discharged mortgage debt.
The trial court determined that the named-plaintiff borrowers failed to establish predominance as required under Federal Rule of Civil Procedure Rule 23(b)(3) because the class included members who, like the named-plaintiff borrowers, vacated their homes, as well as members who did not leave their homes. Thus, the servicer’s preemption defense would only apply when borrowers remained in their homes and it would be necessary to conduct individualized inquiries “for every class member to determine whether the § 524(j) exception applied, and if so, whether the Bankruptcy Code precluded and/or preempted the FDCPA and FCCPA.”
This interlocutory appeal followed.
The Eleventh Circuit framed the question before it as follows: “whether the district court abused its discretion in deciding that common issues did not predominate for the alleged claims.”
Regarding the FDCPA claim, the named-plaintiff borrowers alleged that the servicer attempted “to collect a mortgage debt that had been discharged” in violation of § 1692e(2)(A), which prohibits any false representation of “the character, amount, or legal status of any debt.” The servicer asserted, in its affirmative defense, “that the Bankruptcy Code provides the only remedy for a claim that a creditor violated a bankruptcy court’s discharge injunction and thus bars an FDCPA claim resting on the creditor’s attempt to collect a debt in violation of a bankruptcy court’s discharge injunction.”
The Eleventh Circuit found that the trial court erred when it found that the servicer’s preemption affirmative defense only applied “to class members who remained in their homes.” Instead, because the servicer’s affirmative defense “potentially barred every class member’s FDCPA claim, the district court was required to treat the defense as raising a common issue.”
Specifically, according to the Eleventh Circuit, the trial court wrongly ignored the borrowers’ allegations that the servicer violated discharge injunctions when it sent mortgage statements to class members who left their homes “as section 524(a) provides that a bankruptcy court’s discharge order operates as an injunction that bars any act to collect a discharged debt as a personal liability of the debtor.” 11 U.S.C. § 524(a)(2). Thus, the servicer’s affirmative defense “that it is not liable under the FDCPA because the only remedy for violation of a discharge injunction is under the Bankruptcy Code applies to all class members,” regardless of whether they vacated their properties.
Turning to the alleged FCCPA claim, the Eleventh Circuit reached the same conclusion. The servicer raised the same defense that the Bankruptcy Code preempted each class member’s FCCPA claim. For the same reasons that it used concerning the FDCPA claim, the Eleventh Circuit determined that the trial court abused its discretion in finding that the preemption affirmative defense raised an individualized issue instead of an issue common to all class members.
Therefore, the Eleventh Circuit reversed the trial court’s order denying class certification, and remanded for the trial court to reconsider whether common questions of law or fact predominate given that whether the Bankruptcy Code preempted the alleged claims raises a common, rather than an individualized, issue.
LIVE MONTHLY WEBINARS (Free to Members)
- Class Action Litigation: Strategies for Defending or Settling Class Claims – Thursday, January 23, 2019 at 9:00am PT/12:00pm ET
***All recorded monthly webinars are FREE to our members. Special series and select required courses for certification are paid at member rate.
CONGRATULATIONS TO OUR NEW AND RENEWAL CERTIFIED BUSINESSES, VENDORS, AND INDIVIDUALS!
CRCP – New
Amanda Schenck- EZ Messenger
CRCP – Renewal
Michael Crossan – Collins Asset Group
Kenneth Hamill – Resurgent Capital Services
Rance Willey – Troy Capital, LLC
Joseph Fejes – Jefferson Capital Systems, LLC
Mountain Run Solutions, LLC
Accelerated Inventory Management, LLC
Genesis Recovery Services, Inc.
CRB – Renewal
Halsted Financial Services
Troy Capital, LLC
The Cadle Company
View all certified businesses and vendors
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For questions about certification, contact Caitlyn Vaden at (916) 482-2462 or email@example.com.
Welcome new RMAI members!
Boston Portfolio Advisors, Affiliate – FL
Heritage Global Capital, LLC, Affiliate – NY
J.J. Marshall & Associates, Inc., Associate Collection Agency – MI
Kedem Financial, Inc., Associate Debt Buyer – CA
NLP Logix, Affiliate – FL
Orion Capital Solutions, LLC, Associate Collection Agency – NY
Shermeta Law Group, PLLC, Associate Law Firm – MI
Read more about these and other members on the Member Search page.
Membership Renewals … December 31, 2019 is the deadline to renew!
- Do you need a new W-9 form?
Email Shannon Parod at firstname.lastname@example.org
- Has your company moved?
If so, please contact email@example.com with your new mail address.
- Do you work remotely and haven’t seen your renewal?
Chances are your renewal invoice was mailed to the corporate office.
HR Spotlight Brought to You by the RMAI & Insperity Partnership:
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RMAI works hard to open new markets and promote the industry at various conferences and events.
IACC 2020 Annual Convention | January 15-17, 2020
Featuring Jan Stieger RMAI Executive Director Presenting State of the Industry Session
RMAI members can register at a discounted rate, using this special registration form.
RMAI Annual Conference | February 4-6, 2020
RMAI Executive Summit | July 28-30, 2020
In this update:
Thank you to our December 2018- December 10, 2019 Legislative Fund Contributors!
Cavalry Investments, LLC
Financial Recovery Associates, Inc.
Portfolio Recovery Associates, LLC
Resurgent Holdings, LLC
Crown Asset Management, LLC
Unifund CCR, LLC
Digital Recognition Network
Encore Capital Group, Inc.
Plaza Services, LLC
Second Round, LP
Glass Mountain Capital, LLC
Security Credit Services, LLC
Velocity Portfolio Group, Inc.
Absolute Resolutions Corp
First Financial Portfolio Service, LLC
National Loan Exchange, Inc.
Quall Cardot LLP
RAzOR Capital, LLC
The Bureaus, Inc.
Winn Law Group, APC
Accelerated Data Systems
Andreu, Palma, Lavin & Solis, PLLC
C & E Aquisition Group
Central Portfolio Control, Inc.
Full Circle Financial Services, LLC
G. Reynolds Sims & Associates, P.C.
Geist Holdings, Inc.
Indiana Receivables, Inc.
Investment Retrievers, Inc.
Kino Financial Co., LLC
Malone and Martin, PLLC
Mullooly, Jeffrey, Rooney & Flynn, LLP
Ontario Systems, LLC
PCI Group Inc.
Peroutka, Miller, Klima & Peters, P.A.
Stenger & Stenger P.C.
The Cadle Company
The Law Offices of Ronald S. Canter, LLC
Acctcorp International, Inc.
AGORA Data, Inc.
Aldridge Pite Haan, LLP
Alliance Credit Services, Inc.
Arko Consulting LLC
Butler & Associates, P.A.
Capital Solutions Bancorp, LC
CBE Group, Inc.
Clear Payment Solutions
Collins Asset Group LLC
Comtronic Systems, LLC
Converging Capital, LLC
Credit Control, LLC
D & A Services, LLC
Delta Outsource Group, Inc.
Diversified Consultants, Inc.
DNF Associates LLC
Dynamic Recovery Solutions
Federal Pacific Credit Company
FLOCK Specialty Finance
Fort Crook Financial Co.
Galaxy Capital Acquisitions, LLC
Genesis Recovery Services
Halsted Financial Services, LLC
Harvest Strategy Group, Inc.
Hudson Cook, LLP
Hunt & Henriques
Icon Equities, LLC
International Debt Buying Consultants, LLC
Kirschenbaum & Phillips, P.C.
Law Office of James R. Vaughan, P.C.
Law Offices of Daniel C. Consuegra, P.L.
Law Offices of Steven Cohen, LLC
Lockhart, Morris & Montgomery, Inc.
Metronome Financial LLC
Mid Atlantic Portfolios, LLC
Midwest Fidelity Services, LLC
Monarch Recovery Management, Inc.
MRS BPO, LLC
National Recovery Associates
National Recovery Solutions, LLC
NCB Management Services, Inc.
Noble Financial Solutions, Inc.
Payment Brokers Group, LLC
Pharus Funding, LLC
POM Recoveries, Inc.
Poser Investments, Inc.
RAS LaVrar LLC
Resource Management Services, Inc
Rocky Mountain Capital Management, LLC
SAM, Inc. – Solutions for Account Management
Sandia Resolution Company, LLC
Simmonds & Narita LLP
Solutions by Text
Sonnek & Goldblatt, Ltd.
Tag Process Service, Inc.
Tobin & Marohn
Troutman Sanders LLP
Troy Capital, LLC
Universal Fidelity LP
Vargo & Janson, P.C.
Viking Client Services, Inc.