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The Federal Regulatory and Legislative Committee has been squarely focused on analyzing the CFPB proposed rule on debt collection. The committee is reviewing section by section identifying issues of concern and is in the process of gathering data to support RMAI’s responses. Look for a series of surveys from RMAI to assist us in developing recommendations and providing supporting data.

The committee continues to move forward our data and documentation legislative proposal. RMAI has met with one consumer group, and plans to meet with others to gather their input. RMAI was in the process of developing written testimony for the upcoming HFS Hearing on Abusive Debt Collection Practices, however, as of this weekend, the hearing has been postponed and a future date has not yet been set.


STATE LEGISLATIVE ACTIVITY

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 and a coalition of industry participants, along with our respective lobbyists, fought up to the final day of the New York Legislature to stop this legislation.]

Ohio HB 251 – This bill would lower the statute of limitations on both written and oral contracts to three years. Currently written contracts are at eight years and oral contracts are at six years. The bill has strong support from the hospital and insurance industries. [RMAI testified in opposition to this bill in committee.]

California SB 616 – This bill would exempt the first $2,000 dollars in a deposit account from a bank levies as a means to satisfy court-ordered judgments. [RMA is supporting an industry coalition in opposition to this bill.]

If you are interested in obtaining a copy of the RMAI state tracking list, please contact David Reid at dreid@rmaintl.org.

NJ Sup Ct Holds Invalidity of Transaction as a Whole Does Not Negate Arbitration Agreement

Goffe v. Foulke Mgmt. Corp., Nos. A-3, 081258, 2019 N.J. LEXIS 791 (June 5, 2019)

The Supreme Court of New Jersey held that where a plaintiff challenges the validity of a transaction as a whole and not specifically the included arbitration agreement, the plaintiff must arbitrate their claims because an arbitration agreement is severable and enforceable, notwithstanding a plaintiff’s general claims about the invalidity of the transaction as a whole.

The plaintiffs (“Plaintiffs”) each purchased cars from the defendant car dealerships (“Dealerships”).  As part of their purchases, the Plaintiffs each signed several agreements (collectively, “Sales Contracts”), including an arbitration agreement (“Arbitration Agreements”).

The Arbitration Agreements provided that “[i]f either you or we file a lawsuit . . . or other action in a court, the other party has the absolute right to demand arbitration following the filing of such action.”  They further provided that “[t]his agreement applies to all claims and disputes between you and us.”

Following the sales, Plaintiffs brought separate lawsuits against the respective Dealerships, each alleging that the Dealerships engaged in deceptive and unconscionable practices, including misrepresentations and concealment in the buying process.  Based on the alleged wrongful conduct, Plaintiffs asserted claims under New Jersey consumer fraud statutes, the federal Truth in Lending Act, and for common law fraud.

The trial courts granted the Dealerships’ motions to dismiss and to compel arbitration.

Plaintiffs appealed and the appellate court consolidated the cases.  The appellate court then reversed the orders of the trial courts.  In reaching its decision, the appellate court concluded that under the Third Circuit’s ruling in Guidotti v. Legal Helpers Debt Resolution, L.L.C., 716 F.3d 764 (3d Cir. 2013), the trial courts should have conducted an evidentiary hearing to resolve  whether the parties entered into an enforceable contract.

The New Jersey Supreme Court then granted the Dealerships’ petitions for certification. The central issue before the New Jersey Supreme Court was “whether plaintiffs should be compelled to address their claims before an arbitrator.”

Plaintiffs argued that because their Sales Contracts were invalid, either in the formation or because they were effectively rescinded through the contract’s cancellation, the Arbitration Agreements also could not be enforced because they were part of the overall invalid Sales Contracts.  The Dealerships argued that the question of the enforceability of the Arbitration Agreements was a question for the arbitrator to decide and not the courts because the Plaintiffs did not issue a challenge specifically to the arbitration provisions.

The New Jersey Supreme Court first reviewed the decision in Prima Paint Corp. v. Flood & Conklin Mfg. Co., 388 U.S. 395, 87 S. Ct. 1801 (1967), wherein the Supreme Court of the United States (“SCOTUS”) “held that when a plaintiff raises a claim of fraud in the inducement of a contract as a whole – rather than fraud in the making of the arbitration agreement itself – the FAA requires that the dispute be resolved by the arbitrator.”

SCOTUS’s determination in Prima Paint “recognized that arbitration agreements are severable from the rest of the contract and that the arbitration agreement may be valid separate and apart from the contract as a whole, provided that a party has not challenged the arbitration agreement itself.”

The New Jersey Supreme Court noted that “Plaintiffs do not dispute the validity of the arbitration agreement itself nor do they dispute the delegation provision within it that delegates the question of arbitrability to the arbitrator.” Instead, “they have continuously maintained that the contract was the product of fraudulent inducement and that the arbitration agreement – within that sales contract – is thus also invalid.”

Thus, based on SCOTUS precedent, the New Jersey Supreme Court had “no doubt that the arbitration agreements in plaintiffs’ contracts . . . are entitled to enforcement.”  “[T]he argument that either plaintiff did not understand the import of the arbitration agreement and did not have it explained to her by the dealership is simply inadequate to avoid enforcement of these clear and conspicuous arbitration agreements that each signed.”

Accordingly, the New Jersey Supreme Court held that the Plaintiffs “must arbitrate their claims as to the enforceability of the overall sales contract,” as well as “their various statutory and common law claims.”

7th Cir. Creates Split on Spokeo Standing, Rules in Favor of Defendant in FDCPA Disclosure Case

Casillas v. Madison Ave. Assocs., No. 17-3162, 2019 U.S. App. LEXIS 16798 (7th Cir. June 4, 2019)

The U.S. Court of Appeals for the Seventh Circuit ruled that a debtor lacked Article III standing to sue a debt collector, who failed to notify her that to seek verification of a debt she had to communicate her dispute in writing, because the only harm she suffered was receiving the incomplete letter.

In so ruling, the Seventh Circuit created a circuit split on this issue as in Macy v. GC Services Limited Partnership, 897 F.3d 747 (6th Cir. 2018), where the Sixth Circuit held under identical facts that the complaint in that case alleged a concrete injury because depriving a consumer of this information put them at a greater risk of future harm.

In this case, the debt collector sent a letter to the debtor demanding payment that largely complied with section 1692g(a) of the FDCPA, except it did not state that the debtor had to dispute the debt in writing to obtain verification.

The debtor did not allege that she sent a dispute regarding the debt or that she would do so, but claimed the letter breached her rights under the FDCPA and sought to recover $1,000 in statutory damages for herself, a statutory award for the class members, attorneys’ fees, and costs.

While the case was pending the Seventh Circuit decided Groshek v. Time Warner Cable, Inc., 865 F.3d 884 (7th Cir. 2017), which followed the Supreme Court’s Spokeo decision in holding that without anything more “a plaintiff cannot satisfy the injury‐in‐fact element of standing simply by alleging that the defendant violated a disclosure provision of a consumer protection statute.”  As such, the trial court concluded that the debtor lacked Article III standing.

On appeal, the Seventh Circuit observed that to establish standing a plaintiff must allege “an injury-in-fact that is traceable to the defendant’s conduct and redressable by a favorable judicial decision.”  This case concerned the first injury-in-fact requirement which involves “an invasion of a legally protected interest which is (a) concrete and particularized and (b) actual or imminent, not conjectural or hypothetical.”

The Seventh Circuit held that even though the FDCPA enables consumers to sue debt collectors for violations, it does not mean that every plaintiff has standing, even in the context of a statutory violation.  Article III requires that a plaintiff suffer “a concrete injury,” and a “bare procedural violation” like the one the debtor alleged would not satisfy this requirement.

The Seventh Circuit acknowledged that the Sixth Circuit’s opinion in Macy which concluded under a nearly identical fact pattern that a failure to notify plaintiffs that they had to dispute their debts in writing established a concrete injury sufficient to confer Article III standing because “[w]ithout the information about the in‐writing requirement, Plaintiffs were placed at a materially greater risk of falling victim to abusive debt collection practices.”

The Seventh Circuit disagreed with this approach because regardless of whether the omission created a risk that consumers who sought to dispute the debt may waive their statutory rights, it created no risk for the named plaintiffs who did not dispute the debt or even plan to dispute the debt.  In the Seventh Circuit’s view, the risk that the omission may harm “someone” does not confer standing.  Instead, the omission “must have risked harm to the plaintiffs.”

The debtor also argued that she sufficiently alleged a concrete injury because depriving her of the knowledge that she had to submit disputes in writing constituted an “informational injury.”  The Seventh Circuit had little trouble rejecting this argument because “the denial of information subject to public disclosure is one of the intangible harms that Congress has the power to make legally cognizable. (Emphasis in original).  A public disclosure law protects “the public’s interest in evaluating matters of concern to the political community” and denying a request for information under such a law “necessarily implicates that interest.”  The debtor did not seek and was not denied any such information.

The debtor also argued that Havens Realty Corp. v. Coleman, 455 U.S. 363 (1982), demonstrated that she suffered a concrete “informational injury” because the defendant violated a statutory requirement. Havens Realty involved a minority plaintiff that sued the defendant after it “falsely told her that an apartment complex had no vacancies.”  Although the plaintiff in Havens Realty did not intend to rent an apartment, she requested the information because she suspected that the defendant was practicing “unlawful racial steering.”  She had a concrete injury because the Fair Housing Act gave everyone “a legal right to truthful information.”  The debtor argued that the FDCPA “likewise conferred on all debtors a right to complete information about their statutory rights.”

The Seventh Circuit disagreed because the Havens Realty plaintiff did not allege harm based on any received “inaccurate or incomplete information.”  Instead, she claimed the defendant harmed her by lying to her because of her race.  That invasion was precisely the “interest that the Fair Housing Act protects: freedom from racial discrimination in the pursuit of housing.”  That was not the harm the debtor in this case claimed or the harm that the FDCPA protects against.

1st Cir. Upholds Use of ‘Integrated Records’ from Prior Servicer

United States Bank Tr., N.A. v. Jones, No. 18-1719, 2019 U.S. App. LEXIS 16126 (1st Cir. May 30, 2019)

The U.S. Court of Appeals for the First Circuit recently affirmed a mortgage foreclosure judgment, holding that the district court properly admitted into evidence a computer printout from the loan servicer containing incorporated information from prior loan servicers.

The plaintiff borrower defaulted on her mortgage loan and the bank filed a diversity action in the U.S. District Court for the District of Maine. “At trial, [the bank] sought to establish the total amount owed on the loan account by introducing a computer printout … that contained an account summary and a list of transactions related to the loan.”  Relying on the printout, the  district court granted judgment in favor of the bank and the borrower appealed, arguing the admission of the printout violated the Federal Rules of Evidence.

Affirming the District Court’s ruling, the First Circuit reasoned that “Rule 803(6), known as the business records exception, authorizes the admission of certain documents under an exception to the usual prohibition against the admission of hearsay statements, that is, statements by an out-of-court declarant offered into evidence to prove the truth of the matter asserted.”

The borrower argued that admitting the printout was improper because it summarized some transactions that were created by two prior loan servicers, whose records were “integrated” into the current servicer’s “database when [it] succeeded them as servicer.” Thus, the printout was inadmissible “unless supported by testimony of a custodian or qualified witness with personal knowledge of the record keeping of the respective prior servicers.”

The Court rejected this argument because “there is no categorical rule barring the admission of integrated business records under Rule 803(6) based only on the testimony of a representative of a successor business. … Rather the admissibility of the evidence turns on the facts of each case.”

The First Circuit explained that “we have affirmed the admission of business records containing third-party entries without third-party testimony where the entries were ‘intimately integrated’ into the business records, … or where the party that produced the records ‘relied on the [third-party] document and documents such as those in his business….”

The First Circuit concluded that the district court did not abuse its discretion in finding the computer printout “with its integrated elements reliable enough to admit under Rule 803(6).” It reasoned that an employee of the servicer testified that “the servicer relied on the accuracy of the mortgage history and took measures to verify the same.” In addition, the borrower did not dispute the accuracy of the printout based on “overbilling or unrecorded payments, as she surely could have done if the records were inaccurate.”

6th Cir. Reverses Dismissal in Short-Term Cash Advance Class Action Involving Two Definitions of ‘APR’

In re Fifth Third Early Access Cash Advance Litig., 925 F.3d 265 (6th Cir. 2019)

The U.S. Court of Appeals for the Sixth Circuit recently reversed the dismissal of a breach of contract claim in a putative class action involving short-term cash advance loans, finding that the contract at issue was ambiguous because it provided two inconsistent definitions of “annual percentage rate” that could not be reconciled.

The defendant bank created a short-term cash advance program for eligible customers who held checking accounts with the bank.  Specifically, the bank would deposit loans up to $1,000 directly into customers’ accounts, and the bank would then automatically pay itself back along with a 10% transaction fee, after a customer’s direct deposit posted or 35 days passed, whichever occurred first (the “program”).  The program’s governing contract disclosed the program’s APR as 120% in all cases.

The plaintiff borrowers held checking accounts with the bank and obtained loans through the program, which they paid back in less than 30 days after receiving their respective loans.

The borrowers proceeded to file a putative class action against the bank asserting, among other things, claims for breach of contract and violations of the federal Truth in Lending Act, 15 U.S.C. § 1601.  In support of their breach of contract claim, the borrowers alleged that the bank breached the terms of the contract “by charging [the borrowers] and the other [c]lass members APRs in excess of 120% on Early Access Loans,” and “by failing to provide an accurate APR summary for Early Access Loans on monthly bank statements.”

The bank subsequently moved to dismiss the borrowers’ complaint, which the trial court granted in part and dismissed the breach of contract claim.  In dismissing the breach of contract claim, the trial court held that the contract “unambiguously disclosed the method for calculating APR despite admitting that the result ‘may be misleading.’”

The borrowers thereby filed a motion for reconsideration, which the trial court denied without prejudice due to ongoing settlement negotiations.  However, settlement negotiations subsequently stalled, leading the borrowers to move for an entry of final judgment as to their dismissed breach of contract.  The trial court granted the borrowers’ motion, certified the breach of contract claim for entry of a final judgment, and stayed the remainder of the litigation pending appeal.

The borrowers argued to the Sixth Circuit that the bank breached the contract “by charging them APRs in excess of 120% on Early Access Loans” while the bank contended it adhered to the contract’s definition of APR.

The Court examined the contract’s definition of APR and concluded the contract defined APR in two separate ways.  First, the contract stated that “APR is a measure of the cost of credit, expressed as a yearly rate,” as the term APR is defined by Regulation Z (the “APR Definition”).  See 12 C.F.R. § 226.14(a).

Second, the contract separately provided a formula (the “APR Formula”) whereby “[t]he Annual Percentage Rate is calculated by dividing the transaction fee by the Advance amount and multiplying the quotient by the number of statement cycles within a year…[f]or example, $100 Advance with a $10 transaction fee = $10/$100 = 0.1% X 12 cycles = 120% APR.”

The Sixth Circuit determined the APR Formula to be static, “and always the same regardless of the length of the loan.”  Thus, the Court determined that any APR produced using the APR Formula could not be “expressed as a yearly rate.”  Indeed, the Court noted the APR Definition could never be consistent with the APR Formula.

Because the APR Definition and APR Formula found in the contract were inconsistent with each other and could not be reconciled, the Sixth Circuit found the contract to be ambiguous raising a question of fact to be resolved by the trial court on remand.

Accordingly, the Sixth Circuit reversed the trial court’s judgment dismissing the borrowers’ breach of contract claim and remanded the matter for further proceedings.

CALL FOR PRESENTATIONS – DUE MONDAY, AUGUST 5, 2019

RMAI is now accepting proposals for the upcoming 23rd Annual Conference, February 4 – 6, 2020 at the Aria Resort & Casino, Las Vegas, NV. Presentations should be unique, creative and industry focused as audience interaction and engagement are key!

Submissions Due by Monday, August 5, 2019!

View Call for Presentations.

Submit a proposal.

Contact Shannon Parod at sparod@rmaintl.org or 916.482.2462 with any questions you may have.

UPCOMING WEBINARS

LIVE MONTHLY WEBINARS (Free to Members)

SPECIAL SERIES (4 Webinars for $200 – for Members)

  • Chief Compliance Officer Webinar Series
  • Managing Organizational Expectations – August 27, 2019
  • What Every Compliance Professional Ought to Know About Staying Abreast of State and Local Laws, Regulations, And Rules – September 18, 2019
  • Managing A Risk Event – October 22, 2019
  • Data Privacy – November 12, 2019

***All recorded monthly webinars are FREE to our members. Special series and select required courses for certification are paid at member rate.

DID YOU KNOW RMAI OFFERS TWO (2) TYPES OF CERTIFICATION DESIGNATIONS?

Business/Vendor Certification: complete a series of standards geared towards your business type along with an external audit every 3 years to maintain a single compliance footprint for the receivables management industry.

NOTE: An individual within your business MUST obtain Individual Certification prior to obtaining Business/Vendor Certification.

Individual Certification: complete 24 education credits within two (2) years and receive your Certified Receivables Compliance Professional (CRCP) designation.

Visit the RMAI’s Certification Page for more information.                           

CONGRATULATIONS TO OUR NEW AND RENEWAL CERTIFIED BUSINESSES AND INDIVIDUALS!

New Businesses

Coastal Settlement Recovery, Inc.

New Century Financial Services, Inc.

Renewed Businesses

Lawgix Lawyers, LLC

New Individuals

Craig Antico, RIP Medical Debt

Mike Colby, Second Round, LP

Ryan Hunt, DebtTrader

John Kirincic, E-Cast Settlement

Jerry Terrill, Superlative RM

Renewed Individuals

Matthew Clark, US Asset Management, Inc

Svetlana Denekamp, Resurgence Capital, LLC

Victor Diaz, Diaz & Associates, Inc.

Phil Stenger, Stenger & Stenger, PC

Jennifer Wilson, DebtTrader

View all certified businesses

View all certified individuals

For questions about certification, contact Caitlyn Vaden at (916) 482-2462 or cvaden@rmaintl.org.

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

Ceteris Asset Solutions, LLC Associate Debt Buyer MD
Markoff Law, LLC Associate Law Firm IL

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

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

RMAI Executive Summit | July 30-August 1
RMAI Chicago Regional Event – Wrigley Field | September 16
RMAI Annual Conference | February 4-6, 2020

Contribute Now

Thank you to our June 2018 – June 15, 2019 legislative fund contributors!

Diamond ($25,000)

Certified Debt Buyer
Cavalry Portfolio Services, LLC

Portfolio Recovery Associates, LLC

Associate Collection Agency
Financial Recovery Services, Inc.

Titanium ($15,000)

Certified Debt Buyer
Unifund CCR LLC

Platinum ($10,000)

Certified Debt Buyer
Encore Capital Group

Gold ($7,500)

Certified Debt Buyer
Crown Asset Management, LLC
Second Round, LP

Silver ($5,000)

Certified Debt Buyer
Jefferson Capital Systems, LLC
Plaza Services, LLC
Velocity Portfolio Group

Affiliate
Digital Recognition Network

Bronze ($2,500)

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

Associate Collection Agency
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
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
Portfolio Recovery Associates, LLC
Poser Investments, Inc.
Troy Capital, LLC
West Bay Recovery, Inc.

Certified Law Firm
Reynolds Sims & Associates, P.C.
Law Offices of Daniel C. Consuegra, P.L.
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
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
Credit Control, LLC
FMS, Inc.
Noble Financial Solutions, Inc.
Radius Global Solutions
Tate & Kirlin Associates, Inc.
Viking Client Services, Inc.
ZenResolve

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
Tag Process Service, Inc.
TransUnion
VeriFacts, Inc.
Vertican Technologies, Inc.
VoApps

Originating Creditor
Capital Solutions Bancorp, LC

Individual
David Reid