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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.]

Ohio HB 251 – This bill would decrease the statute of limitations from 8 years to 6 years on a written contract and 4 years on an oral contract. [This bill is in active negotiations and subject to amendment.]

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

Ontario Systems

FTC Announces Consumer Protection Law Enforcement Action, Settlement

The Federal Trade Commission on Wednesday announced a major consumer protection law enforcement action and settlement against a Texas-based company for engaging in an unlawful pyramid scheme. The company, its former CEO, and two top promoters are banned from engaging in any multi-level marketing business. In addition, the company and CEO have agreed to pay $150 million.

During Wednesday’s press conference, Andrew Smith, director of the FTC’s Bureau of Consumer Protection, noted that “multi-level marketing is not inherently illegal.” An illegal pyramid scheme encourages new business opportunities involving without looking at whether participants have a meaningful opportunity for selling products. The company’s business directive was to “recruit business builders who recruit business builders.”

Mr. Smith further outlined the factors or “telltale signs” that a consumer may be dealing with an illegal pyramid scheme:

  • The compensation depends on the recruitment of others
  • Participants must purchase specific amounts of product to qualify for levels of compensation
  • Participants should beware of earning or lifestyle claims

In determining the $150 million settlement, Mr. Smith commented that it can be a “difficult calculation.” The FTC’s Bureau of Consumer Protection, in conjunction with the Bureau of Economics, conducted analysis that determined an amount that would result in a fair resolution and allow a meaningful redress program to those consumers affected. In general, the FTC looks for the “top-line” harm that considers gross revenue less any refunds, along with looking at trends of gross revenue as collected over time while taking into account the groups of consumers who may not have been deceived.

The Plano company promoted energy drink products. The FTC did not challenge the products offered by the company or those claims made regarding the products. At issue was engaging in a deceptive practice concerning a deceptive business opportunity and the methods used to recruit individuals as participants. The company will continue to offer its products but must rely on traditional distribution methods that do not involve a multi-level marketing structure.

11th Cir. Holds No Violation of Bankruptcy Discharge for ‘Informational Statement’

Roth v. Nationstar Mortg., LLC (In re Roth), 935 F.3d 1270 (11th Cir. 2019)

The U.S. Court of Appeals for the Eleventh Circuit recently affirmed the bankruptcy court’s denial of a debtor-borrower’s motion for sanctions, which alleged that her mortgage loan servicer violated her bankruptcy discharge by mailing a communication in a purported attempt to collect upon a discharged debt.

The borrower on a mortgage loan filed a voluntary petition for bankruptcy under Chapter 13.  Her bankruptcy schedules listed the mortgage on non-homestead property, which she indicated she would surrender.  Her Chapter 13 plan provided that “[s]ecured creditors, whether or not dealt with under the Plan, shall retain the liens securing such claims.” Prior to the borrower’s completion of payments under her Chapter 13 plan and discharge of the debt, the mortgage was transferred to a new loan servicer.

The servicer was notified of the discharge, which prohibited any attempt to collect debts from the borrower.  However, the discharge order also provided that “a creditor may have the right to enforce a valid lien, such as a mortgage or security interest, against the [borrower’s] property after the bankruptcy, if that lien was not avoided or eliminated in the bankruptcy case and that the Borrower may voluntarily pay any debt that has been discharged.”

About four months after entry of the discharge order, the servicer began mailing monthly mortgage statements to the borrower, providing the amount due, due date, payment instructions, and a disclaimer that the statements were not debt collection.  After the servicer continued to mail statements to the borrower despite receipt of a cease and desist letter from her attorney, the borrower filed a motion for sanctions in bankruptcy court alleging violations of the discharge injunction under section 11 U.S.C. § 524 of the Bankruptcy Code, the federal Fair Debt Collection Practices Act, 15 U.S.C. § 1692, et seq., and the Florida Consumer Collection Practices Act, Fla. Stat. § 559.55, et seq. The parties reached a settlement to resolve the borrower’s motion for sanctions.

After the settlement, the borrower received a communication from the servicer entitled “Informational Statement” which again contained an amount due, and deadline and instructions to tender payment.

The informational statement also contained a lengthy disclaimer that “[the] statement is sent for informational purposes only and is not intended as an attempt to collect, assess, or recover a discharged debt from you, or as a demand for payment from any individual protected by the United States Bankruptcy Code. If this account is active or has been discharged in a bankruptcy proceeding, be advised this communication is for informational purposes only and is not an attempt to collect a debt. Please note, however [servicer] reserves the right to exercise its legal rights, including but not limited to foreclosure of its lien interest, only against the property securing the original obligation.”

In response to the informational statement, the borrower: (i) filed suit against the servicer in federal trial court alleging a violation of the FDCPA; and (ii) filed a second motion for sanctions against the servicer in the bankruptcy proceedings, again alleging violations of the discharge injunction under section 11 U.S.C. § 524 of the bankruptcy code.  The federal trial court case settled, while the bankruptcy court denied the borrower’s motion for sanctions holding that the informational statement was not an attempt to collect the discharged mortgage loan debt, and therefore did not violate the discharge injunction.

The borrower appealed the denial of the motion for sanctions to the trial court, which affirmed the bankruptcy court’s opinion and rejected her request to apply the “least sophisticated consumer” standard to section 524. The borrower next appealed the trial court’s affirmation of the bankruptcy court’s denial of her motion for sanctions, and separately, its decision to dispose of the motion without an evidentiary hearing.

On appeal, the Eleventh Circuit first noted that Section 524(a)(2) provides that a discharge of debt in a bankruptcy proceeding “operates as an injunction against the commencement or continuation of . . . an act . . . to collect . . . any such [discharged] debt.” 11 U.S.C. § 524(a)(2).  This injunction is enforced through section 105, whereby the bankruptcy court “may issue any order, process, or judgment that is necessary or appropriate to carry out the provisions of this title.” 11 U.S.C. § 105(a).

The Court held that together, the sections authorize the bankruptcy court to impose civil contempt sanctions “when there is no objectively reasonable basis for concluding that the creditor’s conduct might be lawful under the discharge order” or “no fair ground of doubt as to whether the order barred the creditor’s conduct.”  Taggart v. Lorenzen, 139 S. Ct. 1795, 1799, 1801 (2019).  Thus, the Eleventh Circuit was first tasked with determining whether the informational statement’s objective was to pressure the borrower to repay a discharged debt, and if so, to evaluate whether it was sanctionable under section 105.  In re McLean, 794 F.3d 1313, 1322 (11th Cir. 2015); Taggart, 139 S. Ct. at 1799.

Reviewing the informational statement, the Eleventh Circuit found that the inclusion of an “amount due,” “due date” and negative escrow balance did not diminish the disclaimer language in bold typeface on the first page of the communication.  The Court further noted that the borrower had the option to repay the debt under section 524(f) of the bankruptcy code, because the servicer had not completed a foreclosure on the property.

The borrower argued that the Eleventh Circuit should adopt the “least sophisticated consumer” standard, but the Eleventh Circuit declined, noting that what is considered “debt collection” may vary between statutory schemes. Here, the Court noted, the statutory scheme under section 524 of the Bankruptcy Code allows for creditors, such as the servicer, to send potentially helpful informational statements to debtors, such as the borrower, without simultaneously casting those statements as debt collection.

Accordingly, the Eleventh Circuit concluded that the informational statement was not designed to have the “objective effect” of “pressur[ing] the debtor to pay a discharged debt.”

Because the Eleventh Circuit held that the informational statement did not violate the bankruptcy discharge injunction, it did not have to consider whether sanctions were appropriate under section 105 of the Bankruptcy Code.

Lastly, the Court declined to accept the borrower’s argument that she was improperly denied an evidentiary hearing on her motion for sanctions, noting that it was not requested by either party, and the bankruptcy court needed only to review the informational statement to determine whether its objective effect was to pressure a debtor to repay a discharged debt, and that the borrower’s subjective belief was irrelevant.

For the above reasons, the bankruptcy court’s denial of the borrower’s motion for sanctions without hearing was affirmed.

3rd Cir. Holds QR Code on Envelope Violates FDCPA

DiNaples v. MRS BPO, LLC, 934 F.3d 275 (3d Cir. 2019)

The U.S. Court of Appeals for the Third Circuit recently held that a debt collector violated the federal Fair Debt Collection Practices Act (FDCPA) when the envelope it sent to a debtor displayed an unencrypted code that revealed the debtor’s account number when scanned.

A consumer defaulted on her credit card and the bank that issued it assigned the account to a debt collection agency. The debt collector sent the consumer “a collection letter as a pressure-sealed envelope that had a QR [or quick response] code printed on its face. QR codes … can be scanned by a reader downloadable as an application (better known as an ‘app’) on a smartphone.”

Upon being scanned, the QR code reader would reveal a sequence of letters, symbols and numbers, part of which was the internal reference number associated with the consumer’s account at the debt collection agency.

The consumer filed a putative class action lawsuit against the debt collection agency, alleging that it violated subsection 1692f(8) of the FDCPA which prohibits debt collectors from “[u]sing any language or symbol other than the debt collector’s address, on any envelope when communicating with a consumer by use of the mails.”

Both sides moved for summary judgment. The trial court granted the plaintiff’s motion as to liability based on the Third Circuit’s ruling five years ago in Douglass, which “held that a debt collector violates § 1692f(8) by placing on an envelope the consumer’s account number with the debt collector.” The trial court reasoned that “there was no meaningful difference between displaying the account number itself and displaying a QR code — scannable ‘by any teenager with a smartphone app’— with the number embedded.”

The trial court also rejected both the debt collector’s argument that the plaintiff “had not ‘suffered a concrete injury,’ explaining that [plaintiff] was injured by “‘the disclosure of confidential information[,]’” and the “argument that it was protected by the FDCPA’s ‘bona fide error defense.’”

The trial court entered judgment for the plaintiff and the certified class.  The debt collector appealed.

On appeal, the Third Circuit first addressed whether the plaintiff had standing to sue, the first step in determining whether it had subject matter jurisdiction over the case. The Court explained that in order to satisfy the “case or controversy” required for a federal court to hear a case under Article III of the Constitution, the plaintiff must “have standing to sue.  “Standing has three elements: ‘[t]he plaintiff must have (1) suffered an injury in fact, (2) that is fairly traceable to the challenged conduct of the defendant, and (3) that is likely to be redressed by a favorable judicial decision.”  “An ‘injury in fact’ is one that is ‘concrete and particularized’ and ‘must actually exist . . . It must be ‘real,’ not ‘abstract.’”

After reviewing the Supreme Court’s ruling in Spokeo to determine whether the plaintiff’s intangible injury was sufficiently concrete, the Court concluded that the plaintiff “suffered a concrete injury when her debt collector sent her a letter in an envelope displaying a QR code that, when scanned, revealed her account number with the debt collection agency.”

The Court reasoned that it had previously applied the principles set forth in Spokeo in its 2018 decision in St. Pierre v. Retrieval-Masters Creditors Bureau, which “held that a debtor suffered a concrete injury when a debt collector . . . sent him a collection letter in an envelope displaying his account number with the debt collector.”

The Third Circuit went on to explain that “[i]n Douglass, we had held that displaying a consumer’s account number on an envelope was not ‘benign,’ explaining that such conduct ‘implicates a core concern animating the FDCPA—the invasion of privacy . . . Thus, in St. Pierre, we concluded that the harm inflicted by exposing the debtor’s account number was ‘a legally cognizable injury.’”

The Court concluded that even though it did not expressly address the QR code issue in Douglass and St. Pierre, “the reasoning of those two cases inevitably dictates that [the plaintiff] has suffered a concrete injury. . . Whether disclosed directly on the envelope or less directly through a QR code, the protected information has been made accessible to the public.” Accordingly, the plaintiff did not have to show “that someone had actually intercepted her mail, scanned the barcode, read the unlabeled string of numbers and determined the contents related to debt collection—or it was imminent someone might do so.”

The Court next considered whether the trial court correctly held that “[plaintiff] had a successful claim under the FDCPA,” and concluded that “[t]here is no dispute that that [§ 1692f(8)] plainly prohibits the QR code.”

The Court rejected the debt collector’s argument “to read a benign language exception into § 1692f(8)” because a literal reading “would seemingly prohibit including ‘a debtor’s address and an envelope’s pre-printed postage,’ as well as ‘any innocuous mark related to the post, such as ‘overnight mail’ and ‘forwarding and address correction requested.’” The Third Circuit reasoned that the disclosure of the account number itself was an invasion of privacy. “As explained above with respect to standing, the harm here is still the same — the unauthorized disclosure of confidential information. And if such disclosure was not benign, disclosure via an easily readable QR code is not either. Protected information has still been compromised.”

The Third Circuit also rejected the debt collector’s bona fide error defense because “the bona fide error defense in § 1692k(c) does not apply to a violation of the FDCPA resulting from a debt collector’s incorrect interpretation of the requirements of that statute.’

6th Cir. Holds FCRA Preempts State Common Law Claims, Joins 2nd and 7th Cirs.

Scott v. First S. Nat’l Bank, 936 F.3d 509 (6th Cir. 2019)

The U.S. Court of Appeals for the Sixth Circuit recently held that the FCRA’s preemption provisions apply to state common law claims concerning a furnisher’s reporting obligations, joining similar rulings by the Seventh and Second Circuits.

Plaintiffs executed a commercial loan agreement through which a bank extended a loan for a renovation project.  The loan agreement did not contain any promise that the bank would extend additional loans to the plaintiffs, but the plaintiffs believed that the bank would loan any extra funds needed to complete the renovation because they discussed the possibility of cost overruns before entering into the contract and received a verbal assurance from the bank.

The plaintiffs subsequently informed the bank that they may need an additional funds to complete the renovation and submitted a revised estimated cost substantially higher than the original estimate. The bank did not approve the request after discovering that the plaintiffs had incurred additional debt since the first loan.

The plaintiffs’ credit line was scheduled to mature on June 24, 2014.  On June 17, 2014, the bank notified the plaintiffs that because their request to renew the credit line was still pending, the bank would not require them to repay the balance and they would only require the plaintiffs to continue to make interest payments until the bank rendered a determination about whether to renew the credit line. Unlike the previous years, the bank failed to extend the credit line’s maturity date during the review period, and its computer system transmitted delinquency reports to the credit bureaus in July and August 2014 that allegedly damaged the plaintiffs’ credit score.

The plaintiffs obtained financing from a different lender and used the proceeds to pay off their loans with the bank and to complete the renovation project.  However, the bank’s automated computer system continued to report the plaintiffs’ entire prior payment history, including the fact that they had previously been delinquent on the loans. The bank told the plaintiffs it would resolve the issue.

In October 2014, the bank updated its reporting to indicate the plaintiffs had paid off their loans and were no longer delinquent.  Despite the update, the bank reported that the plaintiffs were delinquent in September, October, and November of 2014, even though the plaintiffs had paid off the entire balance of their loans in early September, and in September 2015, the bank sent a second update to the credit bureaus indicating the plaintiffs had paid off the loans.  The bank told the plaintiffs it had resolved the issue.

The borrowers filed a complaint alleging that the bank: 1) violated the FCRA, 15 U.S.C. § 1681, et seq., by willfully and/or negligently failing to investigate their complaints and to correct its reporting; 2) breached its duty of good faith and fair dealing; 3) tortiously interfered with the plaintiffs’ business relationships by deliberately reporting false information; and 4) made fraudulent misrepresentations that it would loan additional funds to complete the renovation.

The bank removed the case to federal court.  After discovery, the bank moved for summary judgment on all claims.  The plaintiffs filed a motion for partial summary judgment on their claim that the bank breached its duty of good faith and fair dealing. The trial court granted the bank’s motion for summary judgment and denied the plaintiffs’ motion for partial summary judgment and this appeal followed.

Section 1681s-2(b) of the FCRA imposes two obligations on furnishers of information:  “(1) to provide accurate information, and (2) to undertake an investigation upon receipt of a notice of dispute regarding credit information that is furnished.” Downs v. Clayton Homes, Inc., 88 Fed. Appx 851, 853 (6th Cir. 2004).  The FCRA creates a private right of action for consumers to enforce the requirements under section 1681s-2(b) only if the consumer files a dispute with a consumer reporting agency to trigger the furnisher’s duty to investigate. Merritt v. Experian, 560 Fed. Appx. 525, 528-29 (6th Cir. 2014).

The plaintiffs never filed a dispute with a consumer reporting agency.  Instead, they argued that by dismissing their FCRA claims despite the bank’s representation that it would remedy the problem, the trial court undermined the pro-consumer purposes of the FCRA.  The Sixth Circuit disagreed, finding that “the FCRA protects both consumers and furnishers” by requiring that a consumer file a dispute with a consumer reporting agency.  The consumer reporting agency can then screen the complaint and provide notice of the dispute to a furnisher if warranted.

The plaintiffs asserted that the bank breached the duty of good faith and fair dealing and tortiously interfered with their business relationships because the bank deliberately harmed their credit score and argued that the trial court erred in ruling that the FCRA preempted their state common law claims.  In support, the plaintiffs cited Miller v. Wells Fargo & Co., 2008 WL 793676 (W.D. Ky. Mar. 24, 2008), for the proposition that the FCRA preempts state statutory claims but not state common law claims.

The FCRA provides that “[n]o requirement or prohibition may be imposed under the laws of any State with respect to any subject matter regulated under [section 1681s-2 of this title], relating to the responsibilities of persons who furnish information to consumer reporting agencies.” 15 U.S.C. § 1681t(b)(1)(F).

The Sixth Circuit observed that, although a handful of trial courts have followed this “statutory approach,” two Courts of Appeals that have addressed the issue both explicitly rejected the “statutory approach”, and held that FCRA also preempts state common law claims.  Purcell v. Bank of Am., 659 F.3d 622 (7th Cir. 2011); Macpherson v. JPMorgan Chase Bank, N.A., 665 F.3d 45 (2nd Cir. 2011).  Agreeing, the Sixth Circuit concluded that the FCRA preempts state statutory and common law causes of action concerning a furnisher’s reporting of consumer credit information.

Accordingly, the Sixth Circuit affirmed the trial court’s judgment in favor of the bank.

UPCOMING WEBINARS

LIVE MONTHLY WEBINARS (Free to Members)

CHIEF COMPLIANCE OFFICER WEBINAR SERIES (4 Webinars for $200 – for Members)

  • Managing Organizational Expectations – Tuesday, August 27, 2019 (recording available)
  • What Every Compliance Professional Ought to Know About Staying Abreast of State and Local Laws, Regulations, and Rules – Wednesday, September 18, 2019 (recording available)
  • Managing A Risk Event – October 22, 2019 at 9:00am PT/12:00pm ET
  • Best Data Privacy Practices for 2020 and Beyond – 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 RMAI’s Certification Page for more information.

               

CONGRATULATIONS TO OUR NEW AND RENEWED CERTIFIED BUSINESSES AND INDIVIDUALS!

New Vendor
Garnet Capital Advisors, LLC

Renewed Businesses
Admin Recovery
PCA Acquisitions V, LLC
Absolute Resolutions Corporation

New Individuals
Gregory Goetz- Fusion Financial
LaDonna Bohling- Receivable Solutions, Inc.

Renewed Individuals
Shannon Parod- RMAI
Brett Soldevila-  Security Credit Services, LLC
Charles Riter Jr.- Emergent Business Group
Richard Weissman- O & L Law Group, P.L.
Aristotle Sangalang- The Bureaus, Inc.
Mark Naiman- Absolute Resolutions Corp.
David Reid- RMAI

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!

AGS Law, Associate Law Firm – CT
Attorneys On Demand,
Associate Debt Buyer – CA
Guglielmo & Associates, PLLC,
Associate Law Firm – AZ
Robinson Hoover & Fudge, PLLC,
Associate Law Firm – OK
Spring Oaks Capital, LLC,
Associate Debt Buyer – VA  
Time Investment Company, Inc.,
Originating Creditor – WI

Membership Renewal Statements Have Been Mailed — Please Be Aware of…

  • Is your business address current? If your business has moved, please email your new address to bsouza@rmaintl.org.
  • Does your AP department know DBA is now RMAI, the Receivables Management Association International? If not, let them know and we can send a new W-9 for your 2020 renewal to be paid.
  • Do you work remotely and haven’t seen your renewal? Chances are your renewal invoice was mailed to the corporate office.
  • Add/Remove Staff from Your Membership? Let us know … info@rmaintl.org

 

HR Spotlight Brought to You by the RMAI & Insperity Partnership:
Boost Employee Performance

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

RMAI Annual Conference | February 4-6, 2020

Contribute Now

Thank you to our October 2018 – October 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
Federal Pacific Credit Company
First Financial Portfolio Service, LLC. FFAM360
Resurgence Capital, LLC
Security Credit Services, LLC
The Bureaus, Inc.
Winn Law Group, APC

Associate Collection Agency
Glass Mountain Capital

Affiliate
Cornerstone Support
National Loan Exchange NLEX

Brass ($1,000)

Certified Debt Buyer
Gemini Capital Group, LLC
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
Rausch, Sturm, Isreal, Enerson & Hornik, LLC
Stenger & Stenger P.C.

Affiliate
Geist Holdings, 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
C & E Acquisition Group
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
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
National Recovery Solutions, LLC

Associate Debt Buyer
Alliance Credit Services, Inc.
Atlas Acquisitions
Balbec Capital
Conquest Receivables
Fort Crook Financial
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
The Law Offices of Ronald S. Canter, LLC
Tobin & Marohn
Vargo & Janson, P.C.
Venable LLP
Winn Law Group, APC

Associate Collection Agency
Capital Collection Management, LLC
Central Portfolio Control, Inc.
Credit Control, LLC
FMS, Inc.
Noble Financial Solutions, Inc.
Radius Global Solutions.
Viking Client Services, Inc.
ZenResolve

Affiliate
Accelerated Data Systems
Attunely, Inc.
Clear Payment Solutions
CMS Services
ComplyARM, Inc.
Comtronic Systems, LLC
Convoke, Inc.
DebtTrader
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