RMAI Update February 2019

/RMAI Update February 2019
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The Committee is kicking off 2019 with a trip to Washington DC with meetings scheduled with the CFPB and the OCC. Additional meetings will be scheduled to form a two day packed agenda.

The Committee is also considering submitting comments to the CFPB regarding the Consumer Disclosure and Validation Notices.

With proposed debt collection rules expected in March, preparing RMAI’s response will be the primary focus of the committee. If you are interested in participating in the drafting of RMAI’s response, please complete the Committee Volunteer Form


 

STATE LEGISLATIVE ACTIVITY

RMAI  is actively monitoring bill introductions to identify legislation that may impact the receivables industry in both positive and negative ways. Here are a few noteworthy bills that have been introduced:

 Connecticut HB 6994 – This bill would protect $2,000 in a debtor’s bank account from garnishment.

 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.

Indiana HB 1055 – This bill would extinguish a judgment lien when one or more of the following are recorded with the office of the county recorder where the judgment lien was recorded: (1) a discharge of judgment lien signed by the judgment creditor or the judgment creditor’s attorney; (2) a certified copy of a satisfaction of judgment that was filed with the court that issued the judgment; (3) a certified copy of a court order that discharges the judgment lien; or (4) a copy of the judgment debtor’s discharge in bankruptcy issued by a federal bankruptcy court and a copy of the bankruptcy schedule listing the judgment debt.

Indiana HB 1061 – This bill would require the awarding of attorney’s fees as part of the cost to the prevailing party in all civil actions.

Indiana SB 441 – This bill would calculate the interest rate on judgments for money when there is no contract between the parties to the suit or when the rate of interest was not agreed upon in the original contract at the lesser of 8 percent or the applicable adjusted rate of interest calculated by the department of state revenue for the nonpayment of taxes.

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.

Oregon SB 472 – This bill would prohibit a business from purchasing or obtaining for valuable consideration a list or compilation of telephone numbers for purpose of making unsolicited calls.

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.

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.

 

New York – RMAI is tracking 20-plus bill of significant concern in New York State. RMAI has a lobbyist in New York and will be in Albany in March for a lobby day. Here is a sampling of the bills:

AB 431 – Employment Report

AB 711 – Large Print

AB 876 – Debtors Rights

AB 1119 – Private Right

SB 691 – SOL & Debt Extinguishment

SB 1835 – Private Right

SB 2239 – Extinguish Debt

SB 2343 – Licensure

SB 2829 – Debtors Rights

 

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 dreid@rmaintl.org.

 

 

February 2019 Court Decisions

CFPB Enters Into $3.2 Million UDAAP Consent Order With Online Lender

In a consent order dated January 22, 2019, the CFPB alleged an online payday and installment loan lender debited consumers’ bank accounts without authorization and failed to honor loan extensions it had granted.

In the consent order, the CFPB asserted that the injury to consumers from the unauthorized debiting was not outweighed by any countervailing benefit to consumers or to competition and the consumers could not have reasonably avoided the injury.  Moreover, the cost to the lender to refrain from the practice would not have been significant.  Accordingly, the CFPB concluded that the lender’s practice of unauthorized debiting constituted an unfair act and practice in violation of section 1031(c) and 1036(a) of the CFPA, 12 U.S.C. §§ 5531(c), 5536(a)(1)(B).

As to the lender’s failure to honor loan extensions, the CFPB similarly concluded that injury to consumers from the lender’s failure to honor loan extensions was not outweighed by any countervailing benefit to consumers or to competition.  Moreover, the CFPB asserted that the cost of correcting the lender’s software errors would not have been significant and the erroneous practice did not confer any benefit to consumers or competition.  The lender’s failure to honor loan extensions also was deemed an unfair act and practice in violation of section 1031(c) and 1036(a) of the CFPA, 12 U.S.C. §§ 5531(c), 5536(a)(1)(B).

Pursuant to the CFPB’s consent order, the lender is permanently restrained and enjoined from:

  • debiting or attempting to debit any consumer’s bank account without having obtained the consumer’s express informed consent;
  • making or initiating electronic fund transfers from a consumer’s bank account on a recurring basis without obtaining a valid authorization signed or similarly authenticated from the consumer for preauthorized electronic fund transfers from that particular bank account and providing the consumer a copy of the authorization signed or similarly authenticated by the consumer for preauthorized electronic fund transfers from the consumer’s account;
  • failing to honor loan extensions granted to consumers, and;
  • debiting the full payment instead of a loan extension fee to consumers granted a loan extension.

The lender was ordered to pay the CFPB a $3.2 million fine.

A copy of the consent order can be accessed here:  Link to Consent Order.

2nd Cir. Rules in Favor of FTC in FDCPA ‘Unlawful Calls’ Enforcement Action

FTC v. Moses, 2d Cir. Nos. 16-3811-cv, 16-3805-cv, 2019 U.S. App. LEXIS 1006 (Jan. 11, 2019)

Two individuals co-owned corporations that were part of a single debt collection enterprise largely engaged in the collection of payday loans.  Their employees allegedly identified themselves as “officers” or “investigators,” accused the consumers of committing crimes by failing to pay and threatened legal action.  Some such calls were placed to friends, family members, employers or co-workers of the consumers.

Upon receipt of consumer complaints, the Office of the New York State Attorney General investigated the corporations and their owners.  Without admitting fault, the owners, on behalf of themselves and the corporations, executed an Assurance of Discontinuance (AOD) wherein they agreed they were subject to specified state and federal laws, agreed to dissolve some of the corporations, and committed to hiring a compliance officer to implement new procedures.  However, shortly thereafter the owners incorporated new corporations, some in other states, and continued to engage in the disavowed practices.

The FTC brought this action in federal court in New York alleging that the corporations and their owners of continuing to operate companies with collectors who continued to mask their identities, falsely accused consumers of crimes and refused to reveal to debtors the circumstances and nature of alleged debts.

The FTC moved for summary judgment, requesting over $10 million in monetary relief and seeking that the corporations and their owners be held jointly and severally liable.  One of the owners (“Owner 1”) did not dispute the corporations’ wrongdoings but argued that he could not be held individually liable for their actions, contending that he lacked control over and knowledge of their wrongdoings.

The magistrate judge’s report and recommendations concluded that the FTC had proved that Owner 1 both had “the authority to control the [corporations] and knew of their wrongdoing after executing the AOD, and that its request for monetary relief “reasonably approximate[d] the [corporations’] unjust gains.”  The trial court adopted the magistrate’s report and recommendation in its entirety.

On appeal, Owner 1 argued that a genuine dispute of material fact existed regarding his control of the corporations.  Because ample evidence proved that Owner 1 had knowledge of the corporations’ violations before and after execution of the AOD, the appellate court disagreed with Owner 1’s assertion.

Owner 1 also argued that the disgorgement in the amount of $10,852,396 was grossly excessive because it was predicated on “approximately 45 calls where it claimed that fraudulent claims were made,” which was “a far cry from the court’s finding that the entire operation was ‘permeated with fraud.’”  However, the FTC submitted more than 500 complaints regarding the owners’ and their corporations’ debt collection practices, aggressive telephone scripts and audio recordings that prove wide dissemination of misrepresentations.  Accordingly, the disgorgement award was deemed appropriate and the trial court’s judgment in the FTC’s favor was affirmed.

A copy of the opinion can be accessed here:  Link to Opinion.

8th Cir. Vacates FCRA Class Settlement on Spokeo Grounds

Schumacher v. SC Data Ctr., Inc., 8th Cir. No. 17-3112, 2019 U.S. App. LEXIS 505 (Jan. 8, 2019)

The U.S. Court of Appeals for the Eighth Circuit recently vacated a trial court’s order approving a class action settlement agreement because the trial court did not first determine whether the FCRA class representative had standing.

The plaintiff filed a putative class action in Missouri state court alleging the defendant violated the federal Fair Credit Reporting Act (“FCRA”) by failing to provide her with a copy of her consumer report and time to explain the report before rescinding her employment offer.  She also alleged improper disclosure and improper authorization related to the defendant’s use of a form to procure the consumer report. The defendant removed the case to federal court.

Shortly thereafter, the parties reached a settlement agreement during mediation. Days later, the U.S. Supreme Court rendered its decision in Spokeo v. Robins, “holding that the Ninth Circuit failed to properly analyze Article III standing in assessing a claim brought under the FCRA.”

The defendant then moved to dismiss for lack of standing, which the trial court denied, reasoning that “[plaintiff’s] standing to bring the FCRA claims underlying this settlement is irrelevant to whether she has standing to enforce the parties’ settlement agreement.”  The trial court approved the settlement and the defendant appealed.

On appeal, the Eighth Circuit held that “the trial court erred by not assessing standing before enforcing the settlement agreement.”

The Court reasoned that “Article III standing must be decided first by the court and presents a question of justiciability; if it is lacking, a federal court has no subject-matter jurisdiction over the claim.” In addition, the trial court has a continuing obligation to make sure that standing exists throughout the case, not just when the complaint is filed. This applies to class actions because an order approving a settlement agreement is a judgment that is invalid unless the court has subject matter jurisdiction.

The Eighth Circuit rejected the class representative’s argument that the trial court did not need to address standing after Spokeo because the defendant was bound by the settlement agreement even if the law changed, reasoning that Spokeo “was not a change in the substantive law bearing on [plaintiff’s] claim that would have ‘altered the settlement calculus.’”

In other words, the class representative argued that only changes in the law that directly affect Article III standing or subject-matter jurisdiction would invalidate a settlement. However, the Eighth Circuit rejected this argument, holding that “Spokeo did not change the law of standing and thus was not a post-agreement change in the law. It merely reiterated that an Article III injury must be both particular and concrete.”

The Eighth Circuit concluded that because there was no finding in the record reflecting whether the plaintiff had standing, the trial court’s approval of the settlement would be vacated and the case remanded for a determination of whether plaintiff had standing to sue, expressing no opinion “on whether the Seventh Circuit’s opinion on FCRA standing or one of the competing approaches in other circuits is best applied to the facts of this case.”

A copy of the opinion can be accessed here:  Link to Opinion.

11th Cir. Rejects FDCPA Claim That Debt Collector Misidentified the Creditor

Lait v. Med. Data Sys., 11th Cir. No. 18-12255, 2018 U.S. App. LEXIS 31814 (Nov. 9, 2018)

A consumer accrued debt from medical services rendered. Thereafter, he received a letter from a debt collection that listed the medical service provider’s name next to a service date but did not expressly refer to the entity as the creditor.

The consumer sued the collector, alleging that the collection letter failed to “meaningfully convey the name of the creditor to whom the debt is owed” in violation of the FDCPA.  The collector moved to dismis, arguing that the letter contained the name of the creditor, even though it did not apply the descriptive term “creditor.”

Applying the “least sophisticated consumer” standard, the trial court granted the motion to dismiss, finding it implausible that the consumer would fail to grasp that the provider was his creditor after reading the collection letter as a whole.

On appeal, the consumer argued that the trial court erred for two reasons: (1) that it was plausible that the collector misidentified his creditor, and; (2) that the least sophisticated consumer would not understand the creditor’s identity.

In addressing the consumer’s first argument, the court noted in its unpublished opinion that the complaint itself failed to allege a misidentification as to the creditor. Instead of alleging facts establishing that the collector failed to effectively convey the name of the creditor, the complaint merely disputed the effectiveness of the collection letter.  Therefore, even evaluating the plausibility of the claim in a light most favorable to the plaintiff consumer, the court held there was no error in granting dismissal.

The Eleventh Circuit also rejected the consumer’s argument that the least sophisticated consumer would not understand the debt collector’s statement of his creditor’s identity.  The Eleventh Circuit opined that the least sophisticated consumer could be expected to connect the dots to understand that the provider was the creditor since the collection letter listed the provider’s name next to an outstanding balance.

Moreover, the only other entity referenced in the collection letter was that of the collector, which explicitly identified itself as the collection agency.   Thus, the consumer had no valid argument that the least sophisticated consumer would think the creditor was anyone other than the provider, as “the debt collector is obviously the agent of the creditor,” as opposed to the creditor itself.

A copy of the opinion can be accessed here:  Link to Opinion.

9th Cir. Holds Debtor Who Successfully Challenges Automatic Stay Fee Award Also Entitled to Appellate Fees

Easley v. Collection Serv. of Nevada, 910 F.3d 1286 (9th Cir.2018)

In a case of first impression, the U.S. Court of Appeals for the Ninth Circuit recently held that a debtor who successfully challenges — as opposed to a debtor who defends — an award of attorney’s fees and costs for violations of the automatic stay under § 362(k) of the Bankruptcy Code is entitled to an award of appellate fees and costs.

Husband and wife debtors filed a petition under Chapter 13 of the Bankruptcy Code in October 2012, which triggered the automatic stay under section 362 of the code. The debtors listed a $3,535 unsecured, nonpriority debt in their schedules owed to a medical services company. The debt, however, had previously been assigned to a collection agency in July 2012.  The collection agency, which did not receive notice of the bankruptcy, filed a collection action against the wife in July 2013. The parties entered into a payment plan, but the debtor defaulted.

The collection agency served a writ of garnishment on the debtors in April 2014. The debtor’s counsel demanded that the garnishment be dissolved, but the wife’s wages were garnished for several more weeks before stopping.

In June 2014, the debtors filed a motion for contempt in the bankruptcy court against the collection agency for violating the automatic stay. The motion was unopposed and was granted it in August 2014, awarding $1,295 in damages and $1,277 for attorney’s fees and costs. The debtors appealed both awards, arguing that “the bankruptcy court erred in failing to account for several days of attorneys’ work needed to end the stay violation.”

While the appeal was pending, the Ninth Circuit held in In re Schwartz-Tallard that section 362(k)(1) of the Bankruptcy Code authorized an award of reasonable attorney’s fees and costs incurred on appeal in defending a judgment under section 362(k).

The trial court affirmed the damages award, “but remanded to the bankruptcy court the attorneys’ fees calculation in light of Schwartz-Tallard. The bankruptcy court then awarded attorneys’ fees and costs of $16,324.40, in addition to the $1,277 initially awarded  [but] refused to award attorneys’ fees and costs incurred on appeal, claiming it lacked jurisdiction due to a pending application for these fees before the trial court.”

In June 2017, the trial court denied the debtors’ motion for appellate attorney’s fees and costs because the debtors failed to file a memorandum of “points and authority” required by the court’s local rules. In the alternative the trial court held that section 362(k) “does not allow for recovery of appellate work when a party is prosecuting, and not defending, the judgment on appeal.” The debtors appealed to the Ninth Circuit.

The Ninth Circuit first addressed the trial court’s applicable local rule, which provides in relevant part that “[t]he failure of a moving party to file points and authorities in support of the motion constitutes a consent to the denial of the motion….”

The Ninth Circuit reasoned that, although “[o]nly in rare cases will we question the exercise of jurisdiction in connection with the application of local rules[,]” the case before it was “one of those rare cases.” It then concluded that the trial court abused its discretion because the debtor’s motion “clearly indicated that the attorneys’ fees and costs requested pertained solely to the appeal and did not need to be further segregated.”

Turning to the issue of appellate attorney’s fee and costs, the Court concluded that although it was “unaware of any previous case that has analyzed § 362(k)’s application of this principle, the purpose of § 362(k) strongly favors the outcome we now reach.”  Because the Ninth Circuit found that § 362(k) is meant to protect debtors when a creditor violates the automatic stay and “thus seeks to make debtors whole, as if the violation never happened, to the degree possible[,] [t]his reasonably includes awarding attorney’s fees and costs on appeal to a successful debtor, even when the debtor must bring the appeal.”

Accordingly, the trial court’s order refusing to award the debtors their attorneys’ fees and costs incurred on appeal was reversed and the case was remanded to the trial court with instructions to remand to the bankruptcy court to determine the amount of reasonable appellate attorney’s fees and costs.

A copy of the opinion is available here:  Link to Opinion.

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.

UPCOMING WEBINARS

  • TCPA – March 20, 2019 (*Date subject to change)

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.

Congratulations to our new and renewed companies and individuals!

Renewed Companies
Resurgent Holdings, LLC

New Individuals
Nicole Rogers, CKS Financial

Renewed Individuals
Sam Tuchman, Peppertree Capital, Inc

 

View all certified companies and certified individuals on our website.

For help with certification, contact Michelle Wren at (916) 482-2462 or mwren@rmaintl.org

Welcome new RMAI members!

The RMAI membership continues to grow. Welcome to our newest members:

Aldridge Pite Haan, LLP — Associate Law Firm — Georgia
Gwynn Group, Inc. — Affiliate — Texas
Noble Financial Solutions, Inc. — Associate Collection Agency — Oklahoma
PDCflow — Affliate — Utah
The Oakes Law Firm, LLC — Associate Law Firm — Louisiana
Atlantic Holdings Corporation — Originating Creditor
Base Commerce, LLC — Affiliate
Coastal Law Firm, APLC — Associate Law Firm
Credit Control Services, Inc. — Associate Collection Agency
Credit Shop/Mercury Mastercard — Originating Creditor
Debtsy, Inc. — Associate Collection Agency
Delta Outsource Group, Inc. — Associate Collection Agency
Empire Credit and Collection — Associate Collection Agency
Mancinelli Goeman Law Group, PC — Associate Law Firm
Open Assets LLC — Associate Debt Buyer
Santander Consumer USA — Originating Creditor
T-Mobile, USA — Originating Creditor
Upgrade, Inc.— Originating Creditor

Read more about these members and other members on the Member Search page

Serve on a committee in 2019!
Looking for a place to share your industry knowledge, talent and passion? Consider strengthening your network and volunteer on an RMAI committee! There are several opportunities to match your skills and interest.

Help shape webinar content and the annual conference — use your editorial skills or help recruit authors for RMAI’s bi-annual magazine … these are just some examples, fill out the participation form and affect the industry with committee involvement.

HR Spotlight Brought to You by the RMAI & Insperity Partnership:
5 trusty tips for hiring candidates you can’t afford

RMAI works hard to open new markets and promote the industry at various conferences and events.

ICBA Convention | March 18-20
Investor’s Conference on Equipment Finance | March 20
LendIt Fintech | April 8-9

Contribute Now

Thank you February 2018-February 2019 Legislative Fund contributors. Your support allows us to influence threatening legislation, while also promoting and preserving the best interests of our members. Make your contribution today!

Diamond ($25,000)

Certified Debt Buyer
Portfolio Recovery Associates, LLC

Titanium ($15,000)

Certified Debt Buyer
Cavalry Portfolio Services, LLC

Associate Collection Agency
Financial Recovery Services, Inc.

Platinum ($10,000)

Certified Debt Buyer
Encore Capital Group

Gold ($7,500)

Certified Debt Buyer
Crown Asset Management, LLC

Silver ($5,000)

Certified Debt Buyer
CKS Financial
Jefferson Capital Systems, LLC
Plaza Services, LLC
Second Round, LP
Velocity Portfolio Group

Affiliate
Digital Recognition Network

Bronze ($2,500)

Certified Debt Buyer
Resurgence Capital, LLC
Security Credit Services, LLC
The Bureaus, Inc.

Associate Collection Agency
Credit Control, LLC
Glass Mountain Capital

Affiliate
Cornerstone Support
National Loan Exchange NLEX

Brass ($1,000)

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
TrueAccord

Associate Law Firm
Andreu, Palma, Lavin & Solis, PLLC
Malone and Martin, PLLC
Stenger & Stenger P.C.

Affiliate
RNN Group, Inc.

Individuals
Jan Stieger
Jon Mazzoli
Mike Colby
In Memory of Trish Baxter

Non-member
Kino Financial Co., LLC

Other

Certified Debt Buyer
Acctcorp International, Inc.
Capio Partners, LLC
Collins Asset Group LLC
Credit Management Corporation
Debt Recovery Solutions, LLC
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.
NDS, LLC
PCA Acquisitions V, LLC
Pharus Funding, LLC
Portfolio Group Investors, 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

Certified Broker
DebtTrader

Associate Debt Buyer
Alliance Credit Services, Inc.
Atlas Acquisitions
Balbec Capital
Genesis Recovery Services
International Debt Buying Consultants, LLC
National Recovery Solutions, LLC
NDA Investments
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
Law Offices of Daniel C. Consuegra, P.L.
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
FMS, Inc.
Noble Financial Solutions, Inc.
Radius Global Solutions
Tate & Kirlin Associates, Inc.
Viking Client Services, Inc.

Affiliate
Accelerated Data Systems
Attunely, Inc.
CenterPoint Legal Solutions, LLC
Clear Payment Solutions
CMS Services
ComplyARM, Inc.
Comtronic Systems, LLC
Convoke, Inc.
Diversified Consultants, Inc.
Equifax, Inc.
FLOCK Specialty Finance
Harvest Strategy Group, Inc.
Metronome Financial, LLC
MicroBilt Corporation
MRS BPO, LLC
Ontario Systems, LLC
Payment Brokers Group, LLC
PCI Group Inc.
Resource Management Services, Inc.
SAM, Inc. – Solutions for Account Management
TransUnion
VeriFacts, Inc.
Vertican Technologies, Inc.
VoApps

Individual
David Reid

2019-02-15T15:39:55+00:00 February 15, 2019|RMAI Update|