In This Update

As we closely monitor the confirmation hearings of Rohit Chopra as the new CFPB Director, we are reviewing, analyzing and developing strategy for several pieces of legislation (some still in the proposal stage) affecting the accounts receivable industry.  Already, we have 17 proposals on our radar – some are pieces of proposals being reintroduced from the last Congress and some are new proposals.  The legislation covers diverse topics; however, several proposals restrict medical debt collections – some COVID-related and other changes in the FDCPA.

Other legislative proposals include collection of debt from servicemembers, bankruptcy reform, reversal of the True Lender rule adopted last year by the OCC, credit reporting, collection of government debt, and a wide reaching proposal by several progressive democrats titled, “Ending Debt Collection Harassment Act”.  This piece of legislation contains extreme restrictions on communicating with consumers and collection of out-of-statute debt.

If you would like more information on RMAI’s advocacy work at the Federal Level, please contact RMAI Executive Director, Jan Stieger (jstieger@rmaintl.org)

The past month has been busy to say the least with active negotiations taking place in seven states. In the past two weeks, RMAI has hired lobbyists in Nevada and New Mexico – joining the list of lobbyists we have already retained in California, Massachusetts, New York, and Washington. On the bright side, RMAI was able to stop a bill in Utah on the final day of the legislative session through the grassroots efforts of our members. Here are some recent developments at the state level that might be of interest:

 Connecticut HB 5048 – This bill would increase the homestead exemption to $250,000. Currently, the homestead exemption is $75,000, “or, in the case of a money judgment arising out of services provided at a hospital” then $125,000.

 California SB 373 – This bill would prohibit a debt buyer from collecting or attempting to collect a consumer debt if the consumer provides documentation to the debt buyer that the debt or any portion of the debt is the result of economic abuse.

 California Department of Financial Protection & Innovation (DFPI) – RMAI submitted a response to DFPI’s request for information as they prepare to issue wide ranging rules for the financial services industry. RMAI stressed the importance to separate debt collectors from other financial products and to follow the existing rules established under

California SB 531 – This bill would expand the definition of “debt buyer” in the California Fair Debt Buying Practices Act to include any person or entity who is “regularly assigned consumer debt for collection purposes.” The bill would also prohibit creditors from selling consumer debts or assigning a third party the right to collect payments unless the creditor has provided a 30-day notice to the debtor before selling the debt that contains the dollar amount of the outstanding debt and the name of the party to whom the debt will be sold. The creditor would be required to provide the notice described to a purchaser of the debt.

 Nevada Work from Home Extension – The Nevada Department of Business and Industry’s Financial Institutions Division has extended its temporary guidance allowing collection agencies and other licensees to operate from home through May 31, 2021.

New Mexico HB 36 – This bill would among other things: (1) tie wage garnishment exemptions to 40 times the highest applicable minimum wage; (2) establish an automatic $2,400 bank levy exemption; (3) increase various personal property exemptions; and (4) increases the Homestead Exemption from $60,000 to a range between $90,000 and $180,000. [RMAI and industry partners fought to reduce the automatic bank levy exemption to a lower number – we expect the bill will be amended shortly to reduce the exemption from $2,400 to $1,500.]

 Ohio SB 13 – This bill would decrease the statute of limitations from eight years to six years on a written contract and four years on an oral contract and would provide exceptions to the state borrowing statute. [RMAI worked with other industry trade associations over the past year to get this bill passed. Creating an exception to the state borrowing statute should be an immense benefit to the membership. This bill has passed both houses of the legislature and is awaiting signature by the Governor.]

 Utah HB 394 – This bill would a creditor or collection agency to provide a payment receipt to the debtor within two business days after receiving a request for a receipt. [RMAI and other industry groups were able to prevent this bill from being passed in the Senate after it had unanimously passed the House. RMAI would especially like to thank our Utah state legislative co-chairs Ryan Barker & Jonathan Kirk for their grassroots efforts.]

 Virginia HB 2307On March 2, 2021, Virginia Governor Ralph Northam signed into law the Virginia Consumer Data Protection Act.  The Act will become effective January 1, 2023. The Act applies to persons that conduct business in the Virginia or produce products or services targeted to Virginia residents. Under the Act, consumers have the right to: (1) access their personal data; (2) correct inaccurate personal data; (3) delete personal data, in certain circumstances; (4) obtain a copy of the personal data they previously provided to a controller; (5) opt-out of the processing of their personal data if related to targeted advertising, sale of personal data or certain profiling activities; (6) appeal a controller’s refusal to take action on a request; and (7) submit a complaint to the attorney general if an appeal is denied.

The Act does not apply to certain entities, data and activities, including financial institutions or data subject to the Gramm-Leach-Bliley Act (“GLBA”), covered entities and business associates governed by the Health Insurance Portability and Accountability Act rules, institutions of higher education; activity related to the use of personal information regulated by the Fair Credit Reporting Act, and data processed or maintained for certain employment purposes.

Notably, the GLBA exemption applies not only to data subject to the GLBA, but also to financial institutions subject to the GLBA. The Act does not provide a private right of action.  If an alleged violation is not cured within 30 days, the attorney general may seek an injunction and a civil penalty up to $7,500 per violation.

 Washington HB 1525 – This bill would establish an automatic $1,000 bank exemption on bank garnishments. The law would sunset on July 1, 2025. [RMAI and the Washington Collector’s Association successfully fought to reduce the automatic bank exemption from $2,500 to $1,000 and have it tied to a sunset date.]

Ninth Circuit Applies Strict Liability to Time-Barred Suit, But Holds BFE Might Apply

Kaiser v. Cascade Capital, LLC, No. 19-35151, 2021 U.S. App. LEXIS 6754 (9th Cir. Mar. 9, 2021)

The United States Court of Appeals for the Ninth Circuit recently held that a collector violated 15 U.S.C. §§ 1692e and 1692f by filing suit on a time-barred debt and violated § 1692e by sending a letter with an implied threat of suit on a time-barred debt, regardless of whether the collector knew that the debt was beyond the applicable statute of limitations.

The consumer plaintiff owed a deficiency balance on a retail installment sales contract. The defendant law firm sent a letter stating that it had “been retained with the authority to file a lawsuit” and subsequently filed that lawsuit in Oregon state court. The sending of the letter and the filing of the lawsuit occurred more than four years after the consumer’s default, but within six years of default. The consumer argued that suit was time-barred by the four-year SOL applicable to contracts for sales of goods found in Oregon’s codification of the Uniform Commercial Code. The law firm countered that the suit was instead governed by Oregon’s six-year SOL applicable to “other” contracts. The state court sided with the consumer and dismissed the collection lawsuit.

The consumer then filed a class-action lawsuit in federal court, which the district court dismissed on the grounds that the law firm did not violate the FDCPA because the question of which SOL applied was unsettled at the time the firm sent its letter and filed the collection lawsuit.

The Ninth Circuit reversed, holding that filing suit on a time-barred debt is misleading and unfair in violation of 15 U.S.C. §§ 1692e and 1692f, and also holding that threatening suit on a time-barred debt likewise violates § 1692e’s prohibition on misleading representations.

On appeal, the law firm argued that its letter and lawsuit could violate the FDCPA only if it “knew or should have known” that the subject debt was time barred. Among other things, the firm argued that the CFPB’s debt collection rule, as then proposed, would apply a knew-or-should-have-known standard to a suit or threat of suit on time-barred debt. The firm also argued that its suit did not violate the rules of civil procedure and certainly did not constitute sanctionable conduct under those rules.

The Ninth Circuit rejected these arguments, citing a prior case in which it held that the FDCPA applies strict liability to misleading and unfair collection practices. See Clark v. Cap. Credit & Collection Servs., Inc., 460 F.3d 1162, 1175– 76 (9th Cir. 2006). While observing that the CFPB’s debt-collection rule is not yet in effect, the court noted that the final rule adopted a strict-liability approach rather than the proposed knew-or-should-have-known standard. The court then explained that litigation conduct can violate the FDCPA even if that conduct is permitted by the rules of civil procedure. See McCollough v. Johnson, Rodenburg & Lauinger, LLC, 637 F.3d 939, 951 (9th Cir. 2011).

Applying strict liability, the court held that the firm’s lawsuit on a time-barred debt violated §§ 1692e and 1692f. The court then found that the letter also violated § 1692e because the statement “[t]his firm has been retained with the authority to file a lawsuit against you for a debt owed by you…” was an implied threat of litigation. Furthermore, the letter’s reference to potential future interest that might be ordered by a “court of competent jurisdiction” would also cause the least sophisticated consumer to interpret the letter as a threat to file suit. The Ninth Circuit rejected the firm’s argument that the letter’s inclusion of a Greco disclaimer would prevent the least sophisticated consumer from inferring a threat of suit, noting that while Greco disclaimers might insulate a firm from implied meaningful-involvement representations they cannot undo threats of litigation.

However, the Ninth Circuit ended its opinion by holding that the application of the wrong SOL can qualify as a bona fide error (“BFE”). Although the Supreme Court has foreclosed the application of BFE to mistakes of law related to interpretations of the FDCPA, its holding in Jerman did not address whether BFE could be applied to mistakes with respect to state law. See Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. 573 (2010). The Ninth Circuit noted that other circuits are split on this question, with the Eighth Circuit finding that the mistaken interpretation of a state statute does not support a BFE defense and the Tenth Circuit holding that mistakes of state law can qualify for the BFE defense. Picht v. Jon R. Hawks, Ltd., 236 F.3d 446, 451 (8th Cir. 2001), Johnson v. Riddle, 305 F.3d 1107, 1121–24 (10th Cir. 2002).

While acknowledging that “ignorance of the law” is generally not a defense, the Ninth Circuit explained that this maxim does not apply to mistakes related to the legal effect of a collateral matter. The mistaken belief that the FDCPA does not prohibit suits on time-barred debts would not qualify for the BFE defense; however, the incorrect application of a six-year SOL instead of a four-year SOL “implicate[s] a legal element entirely collateral to the FDCPA” and is treated instead as a factual mistake. The court also found that the process debt collectors use to determine the applicable statute of limitations more closely resembles the maintenance of a procedure “reasonably adapted to avoid…error” (a required element of the BFE) than the legal analysis used to interpret the FDCPA.

Because the case involved an appeal of a dismissal at the pleadings stage, there was no factual record related to a potential bona fide error defense. Therefore, the Ninth Circuit could give no indication as to whether such a defense might ultimately succeed following remand to the district court.

5th Cir. Finds Collector’s Call Without Reference to Debt is Not an FDCPA “Communication”

Fontana v. HOVG LLC, No. 20-30471, 2021 U.S. App. LEXIS 5829 (5th Cir. Feb. 26, 2021)

After failing to reach a consumer by phone to discuss his debt, a debt collector called the consumer’s sister, who answered.  The collector introduced herself by name, asked if the consumer was available (which he was not), and requested the sister to give a message to the consumer to call the collector back regarding an “important personal business matter.”  Upon inquiry, the collector provided the name of the collection agency, which was not indicative of the fact it was a collection agency.

Feeling “concerned and harassed” by the collector’s call to his sister, the consumer filed suit in federal court alleging that the debt collector violated subsection 15 U.S.C. §1692c(b), which prohibits debt collectors from “communicat[ing], in connection with the collection of any debt, with any person other than the consumer” or certain other prescribed parties to the debt “without the prior consent of the consumer.”

The debt collector’s motion to dismiss for failure to state a claim was granted, and the consumer appealed.

On appeal, the United States Court of Appeals for the Fifth Circuit observed that the debt collector did not mention the debt or provide any information related to it and merely mentioned that the call was about “an important personal business matter.”  As such, it did not convey any information that a debt existed or imply that the call was in connection with the debt.

The Court noted that if the collector had “provided any additional information beyond its name, the analysis might be different.  In Hart v. Credit Control, LLC, 871 F.3d 1255 (11th Cir. 2017), a debt collector left a message stating, in part, that “This call is from a debt collector.” The Court explained that “[b]y stating the caller’s purpose, the debt collector in that case had not directly conveyed any information regarding the underlying debt to be collected. Yet it had indirectly conveyed the information that such a debt existed and implied that the call was in connection with that debt.”

Affirming the trial court’s judgment, the Fifth Circuit found that because the debt collector’s call did not convey “information regarding a debt,” or even imply the existence of a debt, “it was not a ‘communication’ as defined by the Act.”

7th Cir. Holds Detrimental Reliance Necessary for Standing in FDCPA Case

Smith v. GC Servs. Ltd. P’ship, 986 F.3d 708 (7th Cir. 2021)

A consumer received a letter from a debt collector that stated: “If you dispute this balance or the validity of this debt, please let us know in writing.  If you do not dispute this debt in writing within 30 days after you receive this letter, we will assume this debt is valid.”

The consumer filed suit in federal court arguing that she was entitled to choose how to dispute a debt and that the letter’s instructions to put the dispute in writing violated the federal Fair Debt Collection Practices Act.  Specifically, she alleged the language did not comply with 15 U.S.C. § 1692g(a)(3), “which requires a debt collector to send each consumer ‘a statement that unless the consumer, within thirty days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector.’”

The trial court dismissed the suit, finding that the consumer failed to allege any injury necessary to confer Article III standing, primarily relying on Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) and Casillas v. Madison Avenue Associates, Inc., 926 F.3d 329 (7th Cir. 2019).

The United States Court of Appeals for the Seventh Circuit noted this appeal had been put “on hold” while it considered numerous other cases questioning Article III standing with respect to alleged FDCPA violations, including Larkin v. Fin. Sys. of Green Bay, 982 F.3d 1060 (7th Cir. 2020), Gunn v. Thrasher, Buschmann & Voelkel, P.C., 982 F.3d 1069 (7th Cir. 2020), Brunett v. Convergent Outsourcing, Inc., 982 F.3d 1067 (7th Cir. 2020), Spuhler v. State Collection Serv., 983 F.3d 282 (7th Cir. 2020) and Bazile v. Fin. Sys. of Green Bay, Inc., 983 F.3d 274 (7th Cir. 2020) (see the RMAI Update for February 2021).

Contrasting earlier cases with the recent Circuit opinions, the Court explained:

In the wake of Spokeo and Casillas, many litigants and some district judges distinguished between “procedural” claims, which would be governed by Spokeo and Casillas, and “substantive” claims, for which any asserted violation of the statute would be treated as an injury. Larkin and its successors in this circuit disapprove that distinction and hold that injury in fact is essential to standing, whether the asserted violation is best understood as substantive or procedural.

In this case, the Court found the consumer never explained how a need to dispute the debt in writing stopped her from doing so “(she does not claim to be illiterate),” or what difference it would have made since she did not allege the debt collector was attempting to collect any amount other than what she owed.

The Court concluded that “[s]he is no worse off than if the letter had told her that she could dispute the debt orally,” and affirmed the trial court’s dismissal for lack of Article III standing.

Mark your Calendars for the 2021 Legislative Fund Donor Reception in Las Vegas

RMAI is holding its annual Legislative Fund Donor Reception at the Annual Conference in Las Vegas on Wednesday, March 14th from 4:10 – 5:00pm. This reception is for any conference attendee whose company donated to RMAI’s Legislative Fund from January 1, 2020 to April 14, 2021. If your company is not currently donating to the Legislative Fund, we encourage you to start.

Invited attendees enjoy cocktails, appetizers, and a brief legislative update while we thank our donors for their contributions to the fund. Special donor awards will be given to companies that have donated at the Bronze Level of $2,500 or more in 2020.

Contribute to the Legislative Fund by donating online or sending a completed contribution form via email or by mail.

RMAI is grateful for members’ generous support of the Legislative Fund. See a list of current contributors on the right sidebar of this newsletter.

UPCOMING WEBINARS

ANNUAL CONFERENCE ‘LIVE’ WEBINARS (MARCH AND APRIL)REGISTER HERE

Licensed to Thrive – Managing Collection Agency Licensing Issues, Wednesday, March 17th at 9:00am PT/12:00pm ET

Maximizing opportunities – Connecting with consumers in the wake of Regulation F’s Calling Restrictions, Wednesday, March 24th at 9:00am PT/12:00pm ET

Preparing for, Managing, and Cleaning Up/Remediating Federal and State Investigations, March 31st at 9:00am PT/12:00pm ET

Diversity & Inclusion: Having the Difficult Conversations with your Staff, Wednesday, April 7th at 9:00am PT/12:00pm ET

RECORDED WEBINARS

CHIEF COMPLIANCE OFFICER WEBINAR SERIES – CFPB Rule

Reaching Consumers/Persons by Telephone Under the CFPB’s New FDCPA Rule

Email and Safe Harbor – How to Navigate New Regulation F’s Bona Fide Error Defense

Text Messaging & Safe Harbor – How to Navigate New Regulation F’s Bona Fide Error Defense

Time, Place, and Manner – Oh My! Breaking Down Reg. F’s Requirements and Strategies for Compliance

Letters – Regulation F’s Do’s and Don’ts

Get certified in 2021 through RMAI Receivables Management Certification Program. Check out these helpful resources to learn how to earn the CRCP, CRB and CRV designations:

Did you know that if your Certified Business has one or more affiliated business entities (debt buying company, law firm, collection agency, creditor), you can certify them as a Family of Companies for ONLY $150 each?

Your affiliated business entities must meet the following criteria to qualify for a Family of Companies under the same Certification:

  • Have the same Chief Compliance Officer
  • Have the same executive management team that exerts control over business operations
  • Maintain a uniform network of compliance on all accounts serviced between the business entities
  • Be governed by the same corporate policies and procedures
  • Agree to be audited in a single unified audit
  • Agree deficiency and remediation against one business entity will apply to all of the business entities

Learn how to add a Family of Companies by clicking here.

CONGRATULATIONS TO OUR NEW & RENEWAL CERTIFIED BUSINESS, AND INDIVIDUALS

CRCP – New

David Jones – Stenger & Stenger, P.C.

CRB-New

River Heights Capital, LLC

CRCP – Renewals

Jessica Hearn – Universal Fidelity LP

Heather Kochamba – Galaxy Capital Acquisitions

Scott Renner – Velo Law Office

Christy Barger – Cornerstone Support Inc.

CRB – Renewals

Dalty Acquisitions

Pharus Funding LLC

United Holding Group

 

View all certified businesses and vendors.

View all certified individuals.

For questions about certification, contact Brianna Halsey at (916) 482-2462 or bhalsey@rmaintl.org.

Welcome New RMAI Members!

Accelerated Portfolio, Inc. | Associate Debt Buyer | VA
Access Receivables Management | Associate Collection Agency | MD
CBK, Inc. | Associate Collection Agency | KS
Law Offices Howard Lee Schiff, P.C. | Associate Law Firm | CT
Matrix Imaging Solutions, LLC | Affiliate | NY
NRA Group, LLC | Associate Collection Agency |PA

Network with RMAI Members
One key benefit of your RMAI membership is networking with other members. Take advantage of the online membership directory where you can sort by Member Type, search for a specific company by name, or click on any of the headings to do an alpha sort by Business, Type or State.
Log into your membership account to start networking!

Do you know of a company that may be interested in joining RMAI? Please share this LINK to the online membership application or have them contact our Member Services Manager Kristy Schrimsher at kschrimsher@rmaintl.org.

We hope you like RMAI’s “Good News” social media posts highlighting the good work of our members. If you or your company are doing positive things in your community, let us know. Please email Penny Cunha, RMAI Deputy Director, at pcunha@rmaintl.org.

RMAI’s leadership cultivates relationships within the receivables management industry to expand business opportunities for members.

RMAI 2021 Annual Conference | April 12-15, 2021 – NEW DATES!

RMAI 2021 Executive Summit | August 2-4, 2021

RMAI Atlanta Regional Event I September 27-28

Please be aware, we have heard recent reports of scammers offering to sell our Annual Conference attendee list, posing as representatives of RMAI and potentially even using our logo. RMAI does not sell its exhibitor or attendee lists, and no third-party is authorized to distribute or sell any lists related to our events.  Any claims of this sort are fraudulent. If you receive a message making this kind of claim, do not engage and delete the message.

As we mark the one-year anniversary of the COVID-19 pandemic, RMAI is committed to keeping you informed. We distribute Member Alerts when warranted with guidance for our members and maintain our COVID-19 resource page on the RMAI website, conveniently accessible without a member password. We also offer eight recorded webinars on COVID-19 related topics. You can find and register for recorded webinars here.

In compliance with California’s guidelines re: minimizing non-essential employees in offices, the RMAI staff is working remotely. We continue to be available to serve you by phone and email.

The RMAI Update is on hiatus in April for the RMAI 2021 Annual Conference. Look for the RMAI Update to return to your inbox again in May.

Contribute Now

Thank you to our March 2020 – March 11, 2021 Legislative Fund Contributors!

Diamond $25,000
Cavalry Investments, LLC

Financial Recovery Services, Inc.

Portfolio Recovery Associates, LLC

Resurgent Holdings, LLC

Titanium $15,000

Velocity Portfolio Group, Inc.

Platinum $10,000

C&E Acquisition Group, LLC/Diverse Funding Associates, LLC/DNF Associates

CKS Financial

Crown Asset Management, LLC

Encore Capital Group, Inc.

Unifund CCR LLC

Gold $7,500

First Financial Portfolio Service, LLC

Silver $5,000

Collins Asset Group LLC

Oliphant United, LLC

The Bureaus, Inc.

U.S. Equities Corp.

Bronze $2,500

Investment Retrievers, Inc.

National Loan Exchange, Inc.

RAzOR Capital, LLC

SAM, Inc. – Solutions for Account Management

Security Credit Services, LLC

Tobin & Marohn

Brass $1,000

Andreu, Palma, Lavin & Solis, PLLC

Balbec Capital, LP

Ballard Spahr LLP

Butler & Associates, P.A.

Capio

Central Portfolio Control, Inc.

Crown Asset Management, LLC

Digital Recognition Network

Equifax, Inc.

Gaskell & Giovannini, LLC

Halsted Financial Services, LLC

Investinet, LLC

Investment Retrievers, Inc.

Jefferson Capital Systems, LLC

Jormandy, LLC

Kino Financial Co., LLC

Plaza Services, LLC

Pressler, Felt and Warshaw, LLP

Resurgence Capital, LLC

Stenger & Stenger P.C.

Stephen L. Bruce & Associates

The Cadle Company

The Law Offices of Ronald S. Canter, LLC

TrueAccord

United Holding Group

Verifacts, Inc.

Vertican Technologies, Inc

Other

Accelerated Data Systems

Acctorp International, Inc.

Action Collection Agencies, Inc.

Aldridge Pite Haan, LLP

Alliance Credit Services, Inc.

Alpha Recovery Corp.

Andreu, Palma, Lavin & Solis, PLLC

Applied Innovation, Inc.

Arko Consulting LLC

ARM Compliance Business Solutions, LLC

ATKB Portfolio Management

Attunely Inc.

Ballard Spahr, LLP

Bloom & Associates, P.A.

Capital Collection Management, LLC

Cascade Capital, LLC

Central Research, Inc.

CMS Services

Collins Asset Group

Commercial Credit Group Inc.

Complete Credit Solutions

Comtronic Systems, LLC

Convergence Acquisitions, LLC

Converging Capital, LLC

Convoke, Inc.

Credit Control, LLC

Credit Management Corporation

CSS Impact!

D & A Services, LLC

Scott Carruthers, APLC

David Reid

DebtTrader

Delev & Associates, LLC

Delta Outsource Group, Inc.

Dynamic Recovery Solutions

Faloni Law Group, LLC

FLOCK Specialty Finance

FMS, Inc.

FocusOne, Inc.

Full Circle Financial Services, LLC

Reynolds Sims & Associates, P.C.

Gaskell & Giovannini, LLC

Genesis Recovery Services

Glass Mountain Capital, LLC

Harvest Strategy Group, Inc.

Hunt & Henriques

Indiana Receivables, Inc.

Invenio Financial, a Phillips & Cohen Associates Company

Jan Stieger

Keith D. Weiner & Associates Co., LPA

Kelly Knepper- Stephens

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

Lippman Recupero

Lockhart, Morris & Montgomery, Inc.

Logicoll, LLC

London & London

LTD Financial Services

Malone Frost Martin PLLC

Maurice Wutscher LLP

Mercantile Adjustment Bureau, LLC

Metronome Financial LLC

Monarch Recovery Management, Inc.

MRS BPO, LLC

Mullooly, Jeffrey, Rooney & Flynn, LP

National Check Resolution, Inc.

National Enterprise Systems, Inc.

National Recovery Associates

National Recovery Solutions

NCB Management Services, Inc.

NDS, LLC

Nelson & Kennard

Neustar, Inc.

Nuvei

Ontario Systems, LLC

Orion Capital Solutions, LLC

Palinode, LLC

PCI Group, Inc.

PerSolve, LLC

Pharus Funding, LLC

Phin Solutions, Inc.

Portfolio Recovery Associates, LLC

Portnoy Schneck, L.L.C.

Poser Investments, Inc.

Premier Forty Financial, LLC

ProVest

Quantum3 Group, LLC

Resource Management Services, Inc

RevSpring

RIP Medical Debt

Robinson Hoover & Fudge, PLLC

SCORE Statistical Consulting

Simmonds & Narita LLP

Solutions by Text

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Troy Capital, LLC

United Holding Group

Universal Fidelity LP

US Mortgage Resolution, LLC

USI Solutions, Inc.

VanDerHeyden Law Office PA

Vargo & Janson, P.C.

Venable LLP

Venandi Systems, LLC

Viking Client Services, Inc.

VoApps

Wipfli LLP