The Federal Committee kicked off the year with two full days of meetings in Washington DC. RMAI Leadership met with the CFPB discussing their plans to develop proper mechanisms in the innovation of new ideas. While we still hope to see proposed Debt Collection Rules published by the end of March, we are now hearing that the timeframe is now being defined as Spring, 2019.
Leadership also met with the OCC, and among other items, discussed the continued concern that large national banks continue to close our members bank accounts for no apparent reason. They agreed to look into this further, but stated that they were not the source of any directive to take such action. Additionally, several meetings were held on Capitol Hill educating new members of Congress on the industry and sharing the launching of FinancialLiteracy.rocks, which was extremely well received.
The committee anticipates an extremely busy year as RMAI submits comments on the proposed rule and shepherds legislation through Congress that will codify data and documentation requirements for the sale, resale and collection of debt.
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 15% of the individual’s disposable weekly earnings and changes the wage exemption from 30 to 50 times the state minimum wage.
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.
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.
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.
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.
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 was 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 email@example.com.
Bending the FDCPA to the Breaking Point: 3rd Cir. Broadens Scope in Ruling Creditor is a Debt Collector
An entity whose principal business is to purchase debt, but did not itself collect the debt it purchased, was found to be a debt collector subject to the federal Fair Debt Collection Practices Act (FDCPA), even though the collection activity was undertaken by other entities.
The Third Circuit Court of Appeals reached this decision by expanding the scope of the statute’s liability so far that it now falls into conflict with itself. Put another way, a creditor can be a debt collector of its own performing debt which it assigned to a third party to collect. But the third party that undertakes collection would not be a debt collector, even if its principal purpose was debt collection.
Sound confusing? It is, but the story on how the Court arrived there is worth the read.
Who is an FDCPA “Debt Collector”?
The FDCPA defines “debt collector” in two ways. The first is an entity whose principal purpose is the collection of debts. The second is an entity that “regularly” collects debts, “directly or indirectly” that are alleged “to be owed or due or another.”
In Barbato v. Greystone Alliance, LLC, the question was whether Greystone fit the “principal purpose” definition. The issue was critical to Greystone because if it obtained a finding that it was not a debt collector, it would not face FDCPA liability.
Greystone argued its principal business is to purchase charged off receivables, but it did not see itself as a debt collector because it did not collect the debt it purchased. Instead it engaged third-party collection agencies and a law firm for that purpose. Greystone also relied on earlier decisions holding that the FDCPA defined a creditor and debt collector as mutually exclusive, so it could not be both.
The Third Circuit’s resolution of the issue did not end well for Greystone. The Court noted that its recent decision in Tepper v. Amos held that creditors can also be debt collectors for FDCPA purposes. But Tepper was a slightly different case.
Although the entity in Tepper also purchased charged off debt, it also collected that debt in-house. Greystone did not engage in in-house collection and so it set up a plausible argument that it was a creditor unlike the Tepper entity. After all, the definition of the FDCPA includes all types of creditors – those who “offer or extend credit creating a debt” are creditors. But you don’t have to be a lender either, because the FDCPA includes within the creditor definition persons “to whom a debt is owed. . .” Greystone is such a creditor.
Creditors as Debt Collectors
Greystone was ultimately found to be a debt collector. But since Greystone is also creditor it was necessary for the Third Circuit to dispense with a prior ruling from its 2007 decision in FTC v. Check Investors, Inc. which supported Greystone’s position. There, the Third Circuit concluded that “. . .as to a specific debt, one cannot be both a ‘creditor’ and a ‘debt collector,’ as defined in the FDCPA, because those terms are mutually exclusive.”
To determine a person’s status under the FDCPA, in FTC v. Check Investors, Inc., the Third Circuit introduced the “default” test that would exclude an entity from “debt collector” status if the debt it acquired was not in default at the time it was acquired. For 12 years, the default test served a clean way for courts to reconcile the debt collector/creditor distinction.
Both the Tepper and Barbato decisions concluded that the Supreme Court’s 2017 decision in Henson v. Santander Consumer USA Inc. abrogated the “default” status test and, as a result, so too the understanding that the definitions of creditor and debt collector were “mutually exclusive.”
A Messy End to the Default Status Test
But the death of the default status test does not support undoing the principle that one could not be both a creditor and debt collector with respect to the same debt, it only supports it. The test was created for the sole purpose of transforming a debt buyer creditor into a debt collector.
As the Third Circuit conceded in FTC v. Check Investors, Inc., the default test “overlooks the fact that the person engaging in the collection activity may actually be owed the debt and is, therefore, at least nominally a creditor.” It was necessary to create the test because the Court believed “Congress has unambiguously directed our focus to the time the debt was acquired in determining whether one is acting as a creditor or debt collector under the FDCPA.”
With the default test gone, the status of Greystone as a creditor would seem to be advanced. It was not the case.
Finding “New Ways” to Expand FDCPA Liability
Tepper and Barbato flavor their decisions with references to development of the debt buying industry since the 1978 enactment of the FDCPA. This development, according to the Third Circuit in Tepper, necessitated that “courts have had to find new ways to distinguish ‘debt collectors’ from ‘creditors’ to determine whether the FDCPA applies to a particular entity.” Read another way, it was necessary to create a new way to keep debt buying subject to the FDCPA even though a debt buyer is “nominally a creditor.”
If Henson ended the default status test, can we still overlook that the fact that a debt purchaser is a creditor? The Barbato decision says you can and pointed to its 2000 decision in Pollice v. National Tax Funding, L.P., where an entity like Greystone purchased defaulted property taxes and municipal sewer and water bills and then engaged others to collect the purchased debts.
While that decision too relied on the default status test, Barbato says that was only part of the reasoning. National Tax Funding was found to be a debt collector because “there [was] no question that the `principal purpose’ of [the] business is the `collection of any debts,’ namely, defaulted obligations which it purchases from municipalities.” That is not much of a distinction since the focus in Pollice’s rationale was still on the purchase of “defaulted obligations.”
Perhaps recognizing this weakness, Barbato takes another route. Examining the two categories of the “debt collector” definition, the decision noted that the “principal purpose” definition focuses on “what” a business is collecting. “As long as a business’s raison d’être is obtaining payment on the debts that it acquires, it is a debt collector.”
Expansion of FDCPA Liability to Traditional Creditors and Performing Loans
There is a troubling problem in Barbato that is difficult to reconcile. By doing away with the default status test, the mere acquisition of debt is now the trigger, even if the debt is a performing loan.
Here lies the conflict. Persons who are collecting debt not in default at the time it was obtained by the collector are excluded from the definition of debt collector under 15 U.S.C. § 1692a(6)(F)(iii), provided they are collecting a debt “owed or due another . . .” But, when one is collecting a debt for itself, after Barbato and Tepper, the default status test is now gone and an entity whose principal purpose is “obtaining payment on the debts that it acquires” is now a debt collector, even when the debt is “not in default.”
Some can now argue that an entity whose principal purpose is to acquire performing loans with the sole purpose of collecting on those loans is a debt collector under the FDCPA. Suppose that same entity retains a third party to collect the performing debt. Under 15 U.S.C. § 1692a(6)(F)(iii), the third party is not a collector, even if their principal business is debt collection or they regularly engage in debt collection for another.
The internal conflict is created solely because entities like Greystone were intended to be treated as creditors. A creditor collecting its own debt does not need an exemption like that found in § 1692a(6)(F)(iii) because Congress did not contemplate courts would ever read the FDCPA as the Third Circuit did.
Perhaps the Third Circuit did not need to go as far as to kill off the default status test and could reason that the structure of the statute implies that the acquisition of defaulted debt as a principal purpose qualifies as the “collection of any debts.” But it is hard to imagine the Court going back now after twice concluding that Henson “rejected the ‘default’ test.”
The Cost of Barbato and Tepper
The debt buying industry has faced FDCPA risk for some time and has created its own standards through its trade organization RMAI, which not only requires FDCPA compliance, but self-imposes standards exceeding it. There is little if any impact on that sector.
The cost of Barbato and Tepper’s expansion will be paid by indirect lenders, special purpose entities created solely to hold performing debt and the like. The decisions’ “new way” of keeping debt buyers within the FDCPA do so by eviscerating the distinction between a creditor and debt collector and the cost for taking that route will be paid by disruption of the far larger consumer financial services industry.
In the eyes of the Third Circuit, if an entity’s “raison d’être is obtaining payment on the debts that it acquires, it is a debt collector,” even if the debt is a performing loan. While the suspect reasoning of Barbato and Tepper may limit their adoption outside the Third Circuit, their application to creditors will be tested often in the coming years.
7th Cir. Rejects Licensing and UDAP Claims Against Online Valuation Service
The U.S. Court of Appeals for the Seventh Circuit has ruled that an estimate on real estate marketplace company’s website of a property’s value did not violate the Illinois Real Estate Appraiser Licensing Act because the licensing act does not provide a private right of action. The court also found that the estimate did not violate the Illinois Uniform Deceptive Trade Practices Act claim because an estimate is an opinion that falls outside the scope of the act.
The sellers had listed their home for sale with a $1.495 million asking price. They noticed that the company had a “Zestimate” valuing their property at $1,333,350. A Zestimate estimates real estate value using publicly available data and a proprietary algorithm. The company advises customers that it does not inspect any of the properties and that the Zestimates, while a useful starting point, “may be inaccurate.”
The sellers feared that the Zestimate would make it harder to sell their property and asked the company to increase the estimated amount or to remove it from the online database. The company refused and the sellers then sued the company in state court alleging that it violated the licensing act by appraising real estate without a license. The lawsuit also claimed that the company violated the Illinois Uniform Deceptive Trade Practices Act because the company would not change or remove disputed estimates.
The matter was removed to the trial court on diversity grounds. The trial court found that the sellers failed to state a claim for which relief may be granted and dismissed all of their claims.
On appeal, the Seventh Circuit first examined the alleged licensing act claim and agreed with the trial court that the licensing act “omits a private right of action.” The court “found that the multiple means of enforcing the licensing act, and the stiﬀ penalties for noncompliance, show that a private action is not necessary to make the statute eﬀective.”
The Court next turned to the alleged trade practices act violation and again, the Seventh agreed with the trial court because the act “deals with statements of fact, while Zestimates are opinions which canonically are not actionable.”
The sellers argued that the Court should create an exception to this rule because the company “refuses to alter or remove Zestimates on request.” The Seventh Circuit rejected this argument because it “does not make a Zestimate less an opinion.”
The sellers also argued that removing particular estimates, like theirs, would improve the accuracy of the proprietary algorithm. The Seventh Circuit flatly rejected this notice because removing a given estimate would not improve the algorithm. Instead, the algorithm is more likely to be accurate overall “when errors are not biased to favor sellers or buyers.”
Thus, the Seventh Circuit held that the trade practices act did not cover the estimate nor did the Illinois Consumer Fraud and Deceptive Business Practices Act, which the plaintiffs also invoked, “for essentially the same reasons … the trade practices act claim fails, and for the further reason that plaintiffs are not buyers of real estate” and the Seventh Circuit affirmed the judgment of the trial court.
7th Cir. Holds Per-Transaction Credit Reporting Does Not Violate FDCPA
The U.S. Court of Appeals for the Seventh Circuit ruled that where a debt collector factually reported to a credit reporting agency that a consumer owed nine debts of $60 instead of aggregating them into one debt of $540, the debt collector did not misstate the “character” of the debt.
Under the FDCPA, it is a violation to make a false representation of “the character, amount or legal status of any debt.” 15 U.S.C. 1692e(2)(A).
Reversing the trial court, the Seventh Circuit stated that “arithmetic does not affect a debt’s ‘character,’” and the “statutory word ‘amount’ rather than the word ‘character’ is what governs reporting the debt’s size.” The consumer did not allege misrepresentation of the amount of the debt.
The court explained that the word “character” in section 1692e(2)(A) references the “kind of obligation.” For example, “[a] secured auto loan would be of one character, an unsecured credit-card debt another, a judgment debt a third, and a subordinated debenture (an instrument junior by contract) a fourth.” Viewing “character” in this light, the number of transactions “does not affect the genesis, nature, or priority of the debt and so does not concern its character.”
The court also noted “per-transaction reporting” could potentially benefit the consumer since she may more readily recognize the nine charges for $60 instead of one charge for $540.
4th Cir. Holds Tax Payment Agreement Subject to TILA and EFTA, Plaintiff Had Spokeo Standing
The U.S. Court of Appeals for the Fourth Circuit recently held that a Tax Payment Agreement entered into pursuant to Virginia law was a consumer credit transaction subject to the federal Truth in Lending Act (“TILA”) and Electronic Funds Transfer Act (“EFTA”). The Court further ruled that the plaintiff had standing to assert his EFTA claim because it alleged “a substantive violation of the rights conferred by EFTA.”
The plaintiff entered into a Tax Payment Agreement (“TPA”) with the defendant company pursuant to Virginia Code 58.1-3018, which governs “any agreement whereby a third party contracts with a taxpayer to pay to a county, city or town on behalf of that taxpayer the local taxes, charges, fees or other obligations due and owing to the county, city or town.”
The plaintiff claimed that many of the terms of the TPA included incorrect amounts, that the company did not include an itemized list of closing costs in the documents, and that the TPA was missing required disclosures. He further claimed that the TPA required him to agree to pay the company by preauthorized electronic fund transfers (“EFTs”) and that the required authorization form did not contain an option to decline.
The plaintiff brought a proposed class action complaint against the company in federal court alleging violations of the TILA and EFTA, and a Virginia statute. The trial court granted the company’s motion to dismiss the Virginia statutory claim but denied the motion to dismiss the TILA and EFTA claims. It then certified for interlocutory review: (1) its decision that the plaintiff had standing to proceed on his EFTA claims, and (2) its determination that TPAs under the Virginia Code are subject to TILA and EFTA as consumer credit transactions.
Affirming the decision of the trial court, the Fourth Circuit held first that the plaintiff “has standing to bring claims under EFTA because the harm that he alleges in a substantive statutory violation that subjects him to the very risks that EFTA . . . was designed to protect against.”
The court, citing Spokeo, noted that to meet the constitutional minimum requirements for standing to sue, a “plaintiff must have . . . suffered an injury in fact, . . . that is fairly traceable to the challenged conduct of the defendant, and . . . that is likely to be redressed by a favorable judicial opinion.” The company argued that the plaintiff did not meet the injury-in-fact requirement, which requires the plaintiff allege an injury that is “particularized,” “concrete,” and “actual or imminent, not conjectural or hypothetical.”
The Fourth Circuit disagreed, finding that the plaintiff’s alleged injury was particularized because it stemmed from the TPA which allegedly required him to consent to the EFT authorization and required him to waive his right to cancel preauthorized EFTs. It was sufficiently concrete because it was not “a bare procedural violation,” but instead “a substantive violation of the rights conferred by EFTA.” The alleged injury was also “actual or imminent” because the company required the plaintiff to agree to preauthorized EFTs.
With respect to the whether the TPA was a “consumer credit transaction,” the Court “first consider[ed] whether the TPA is a credit transaction and, second, whether it is a consumer transaction.”
Although credit has been defined to generally exclude tax liens and tax assessments in the official CFPB interpretation of TILA’s implementing regulation (“Staff Commentary”), the Staff Commentary clarifies that “third-party financing of such obligations (for example, a bank loan obtained to pay off a tax lien) is credit for the purposes of the regulation.”
The Court determined that the TPA provided for third-party financing of a tax obligation for two reasons: (1) “it is clear from the terms of the TPA itself, which state that [the company] will pay [the plaintiff’s] taxes in exchange for installment repayments, interest, and fees from [the plaintiff],” and (2) because the TPA “creates third-party obligations between [the company and plaintiff].”
Finally, the court disagreed with the company’s argument that the TPA was not a “consumer transaction” because enforcement of the underlying obligation, i.e. the property taxes, was motivated by the public welfare rather than “personal, family, or household purposes.” The court explained that “the debt at issue here is not the tax that [plaintiff] owes to the locality,” but “[i]nstead it is one level removed – it is [plaintiff’s] obligation to [the company], a third party, to repay [the company’s] financing of [plaintiff’s] tax obligation.”
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.
- Surveying the TCPA Litigation Landscape After Marks – March 28, 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.
On March 1, 2019, RMAI adopted version 7.0 of the Receivables Management Certification Program making significant enhancements substantive changes to some of the standards. Be sure to check out the new version 7.0 to see if any of the relevant changes apply to your company!
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!
Scott Renner, Velo Law Office
Ben Gerstein, Pro Asset Information Solutions
Anthony Guarjardo, Integras Capital Recovery LLC
Christy Barger, Cornerstone Support Inc.
Mikel Burroughs, RIP Medical Debt
Laura Jensen, Absolute Resolutions Corp
Jessica Hearn, University Fidelity LP
Jon Mazzoli, Capital Services
Melissa Meggison, First Financial Asset Management, Inc.
Michael Seibel, Sandia Resolutions Company LLC
Peter Ragan, Jr., Velocity Investments LLC
Michael Adams, Integras Capital Recovery, LLC
Susan Becker, Jormandy, LLC
Peter Fitzpatrick, Ophrys, LLC
Ramon Lio, Portfolio Investment Solutions, LLC
Diana MacFarlane, Resocore Asset Management Inc.
Nikki Noyes, Stoneleigh Recovery Associates, LLC
Katherine O’Brien, Jefferson Capital Systems, LLC
Jonathan Thompson, TSI – Transworld Systems Inc
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:
Balto Software | Afflliate | MO
Capital Solutions Bancorp, LC | Originating Creditor | FL
Cash Factory USA | Originating Creditor | NV
CJ Acquire, LLC | Assoc. Debt Buyer | CA
First American Acceptance Co., LLC | Assoc. Debt Buyer | NJ
Gault Financial LLC | Assoc. Debt Buyer | TN
Giact Systems, LLC | Affiliate | TX
HarrisLoftus, PLLC | Assoc. Law Firm | VA
Palinode, LLC | Affiliate | TN
Rocky Mountain Capital Management, LLC | Assoc. Debt Buyer | NY
Scott & Associates, PC | Assoc. Law Firm | TX
Read more about these members and other members on the Member Search page
RMAI Receives Overwhelming Response for 2019 Committee Participation
101 RMAI members submitted committee interest forms for this year. This is a significant increase from 2018 where 72 RMAI members submitted committee interest forms (50 interest forms were submitted in 2017).
Several volunteered to serve on more than one committee. Of the 101 members who submitted interest forms, 48 are first-time volunteers. This is a positive confirmation of member engagement and members wanting to help shape the future of the ARM industry. No matter what committee you serve on, you are an Ambassador for the association and we couldn’t do the good work we do without you.
HR Spotlight Brought to You by the RMAI & Insperity Partnership:
5 trusty tips for hiring candidates you can’t afford
Thank you to our March 2018-March 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
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
Poser Investments, Inc.
Troy Capital, LLC
Unifund CCR LLC
West Bay Recovery, Inc.
Certified Law Firm
G. 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
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
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