RMAI Update November 2018

/RMAI Update November 2018
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The committee is scrutinizing the results of the midterm elections and the effects they will have on RMAI activities. RMAI leadership will be in DC the first week in December attending a Consumer Finance Conference, making Capitol Hill visits to key committee members, and meeting with both the FTC and BCFP. Ongoing education of the debt industry is critical as new leaders are appointed, often with no background in the financial services industry.

RMAI is gearing up for a busy 2019 state legislative session. However, a couple of bills remain active in the current cycle which we are actively tracking. Here is one noteworthy bill that may see some movement before January:

District of Columbia Bill B22-0572 – This bill would reduce the availability of wage garnishment as an option for collections through increased exemptions and lower garnishment rates. The bill would also require prescribed consumer notices informing consumers of their rights prior to garnishing wages. [This bill was heard in the Judiciary & Public Safety Committee on June 7th. A bill markup is anticipated this month. RMAI is working in a coalition effort to obtain amendments.]

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

7th Cir. Holds Debt Collector Waived Arbitration by ‘Gratuitous Delay’

Smith v. GC Servs. Ltd. P’ship, No. 18-1361, 2018 U.S. App. LEXIS 29627 (7th Cir. Oct. 22, 2018)

The U.S. Court of Appeals for the Seventh Circuit held that a defendant debt collector waived its right to arbitrate due to its “gratuitous delay” in seeking arbitration, where it waited 13 months after the filing of the lawsuit before moving to compel arbitration.

The plaintiff applied for and received a credit card from a bank.  The credit card contract included an agreement to arbitrate all disputes related to the account and also a waiver of the right to seek class action relief. The debt collector was hired by the bank to collect an allegedly unpaid balance informed the plaintiff that it would commence collection proceedings unless she disputed the debt in writing.

On July 15, 2016, the plaintiff brought a class action suit against the collector arguing that it violated the FDCPA when it required her to dispute the debt in writing.  On Aug. 7, 2017, thirteen months after the suit began, the collector moved to compel arbitration.

The trial court denied the motion on two grounds.  First, it found that as a non-signatory to the arbitration agreement, the collector could not enforce the agreement.  Second, it found that the collector waived any right to arbitrate by not diligently asserting that right. The collector appealed.

On appeal, the Seventh Circuit noted that “[l]ike any other contractual right, the right to arbitrate can be waived.”  Further, if the collector “waived any right to arbitrate, the company necessarily waived any right to oppose class certification premised on the agreement.”  Thus, the question was whether the court “should infer that forfeiture occurred.”

Examining the totality of the circumstances, the Seventh Circuit explained that “[m]any factors are relevant to this analysis, but due diligence or the lack thereof is particularly important.”  Included in the consideration is “whether the allegedly defaulting party participated in litigation, substantially delayed its request for arbitration, or participated in discovery.”  However, it is not necessary to “find that the nonmoving party was prejudiced by the delay in seeking arbitration.”

The Court noted that even setting aside delay, “the company’s actions from that point were unjustified and manifestly inconsistent with an intention to arbitrate” because it filed an answer to the complaint that contained no reference to the agreement and it failed to supplement its briefs on the motion to dismiss and for class certification even though those motions remained pending.

The Seventh Circuit therefore held that “[o]n these facts, the district court’s conclusion that [the collector] waived its right to arbitration was not erroneous.”

A copy of the opinion in Smith v. GC Services Limited Partnership is available here:   Link to Opinion.

7th Cir Holds Plaintiff’s Oral Testimony of Payment Demand Insufficient to Defeat Defendant’s Documentary Evidence

Duncan v. Asset Recovery Specialists, Inc., No. 17-2598, 2018 U.S. App. LEXIS 30781 (7th Cir. Oct. 31, 2018)

After the plaintiff fell behind on her car payments, the defendant debt collector repossessed the vehicle on behalf of the bank.  Upon learning of the repossession, the plaintiff called the bank and was told she would need to satisfy the full amount of the defaulted loan to receive possession.  Because she could not do so, the plaintiff instead sought only to retrieve personal items she had left in the car.

The plaintiff thereafter had discussions with a representative of the collector who she alleged told her multiple times that she would have to pay $100 to recover her personal items. The Plaintiff further claimed that she had a meeting at the collector’s office at which time the Collector allegedly gave her an “assessment fee” form that stated she would have to pay a $100 fee to retrieve her property.  The Plaintiff considered the $100 fee a demand for loan repayment.

The collector denied making a demand for $100 from the plaintiff, and instead claimed that the $100 was an administrative fee that the bank agreed to pay.  The collector also had a document that supported its claim entitled “Receipt for Redeeming Personal Property” which described the $100 as a “Handling Fee” and contained a handwritten notation that “All Fees billed to [bank].”

The Plaintiff refused to sign the receipt form and therefore never recovered her property.  Instead, she filed a lawsuit alleging that the Collector, its president, and the Bank each violated the FDCPA.

The trial court granted summary judgment in favor of the defendants concluding that: (1) the Plaintiff failed to produce any evidence refuting the defendants’ showing, backed by the documentary record, that neither the Collector nor the Bank attempted to collect a $100 payment from her, and (2) that even accepting the Plaintiff’s allegation that $100 was demanded of her, she did not provide any evidence casting doubt on the defendants’ showing that the $100 was only an administrative handling fee owed to the Collector, as opposed to a demand for repayment on the auto loan owed to the Bank.

The Plaintiff appealed.

In affirming the ruling of the trial court, the Seventh Circuit noted that “[t]he record on summary judgment shows that [the Plaintiff] was not able to back her allegation that [the Collector] demanded the $100 fee of her with anything beyond her own say so.” Conversely, the Collector “backed its contrary testimony with the Receipt for Redeeming Personal Property, which expressly established that [the Bank] – not [the plaintiff] – would make the $100 payment.” That same document showed “that the $100 handling fee was just that – an administrative expense that [the collector] sought to recover for its role in processing requests to redeem personal property from repossessed vehicles.”

Moreover, the Seventh Circuit determined that even if it accepted the plaintiff’s contention that her initial phone calls with the Collector entailed a demand for a $100 payment, “[o]n summary judgment she needed to go further and create a genuine issue of fact as to whether [the collector] demanded such a payment on behalf of [the bank] as a lender.”

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

Missouri Supreme Court Denies Arbitration Where Chosen Arbitrator No Longer Available

A 1 Premium Acceptance, Inc. v. Hunter, No. SC96672, 2018 Mo. LEXIS 445 (Oct. 16, 2018)

The Supreme Court of Missouri recently affirmed the denial of a lender’s motion to compel arbitration of a consumer’s putative class claims because the arbitration provision at issue designated the use of a specific arbitrator that was no longer available to handle creditor claims.

The loan agreement contained an arbitration provision which provided, in part, that any claim or dispute arising under the agreement “shall be resolved by binding arbitration by the National Arbitration Forum (“NAF”), under the Code of Procedure then in effect.” However, several years prior to the commencement of the litigation, the National Arbitration Forum entered into a consent decree that required it to immediately stop providing arbitration services for consumer claims.

Due to NAF’s unavailability, the lender requested that the trial court designate a new arbitrator pursuant to Section 5 of the Federal Arbitration Act (“FAA”), 9 U.S.C. § 1 et seq.

The trial court denied the lender’s request and the lender sought an immediate appeal. The Missouri Supreme Court granted the transfer of the appeal from the intermediate appellate court.

The Court concluded that the terms of the agreement were unequivocal, plain and clear that the parties agreed to arbitrate only before NAF, which was further supported by a requirement that the claims be submitted to the NAF headquarters or one of its branches.  The Court further stated that “nothing in the FAA authorizes (let alone requires) a court to compel a party to arbitrate beyond the limits of the agreement it made.”

The Court further commented somewhat critically that the contract was one of adhesion freely drafted by the lender, and “[h]aving made the choice to insist upon NAF – and only NAF – as the arbitration forum, [the lender] cannot now look to Section 5 of the FAA to expand the arbitration promise it extracted from [the borrower] in the Agreement.”

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

1st Cir. Confirms Rooker-Feldman Barred Borrower’s State and Federal Law Claims

Klimowicz v. Deutsche Bank Nat’l Tr. Co., No. 17-1916, 2018 U.S. App. LEXIS 29545 (1st Cir. Oct. 19, 2018)

The U.S. Court of Appeals for the First Circuit recently affirmed dismissal of a borrower’s state and federal law claims, concluding that the federal district court lacked jurisdiction under the Rooker-Feldman doctrine because the borrower’s federal suit sought to invalidate the state courts’ judgments.  The Rooker-Feldman doctrine divests lower federal courts of jurisdiction to hear certain cases brought by parties who have lost in state court.

After a borrower defaulted on her mortgage loan, the mortgagee filed a petition to foreclose the mortgaged property.  Final judgment was entered in the mortgagee’s favor, and the property was sold to the mortgagee at a foreclosure sale.

The mortgagee then turned to the state’s county Housing Court and filed a summary process action to evict the borrower, who in turn filed a counterclaim.  The mortgagee was awarded possession of the property and the borrower’s appeal of the eviction action was dismissed for failure to post bond.

Five months later, the borrower field suit against the mortgagee in the U.S. District Court for the District of Massachusetts, among other things alleging claims for wrongful foreclosure, violation of the Massachusetts consumer protection statute, breach of the covenant of good faith and fair dealing and negligent infliction of emotional distress.

The mortgagee’s motion to dismiss was granted by the federal trial court which held that it lacked subject-matter jurisdiction over the borrower’s claims under the Rooker-Feldman doctrine.  The borrower appealed.

The Court concluded that the borrower’s claims were all premised upon her claims that the mortgagee acquired the mortgage through a pattern of fraudulent activity – the very issue raised in her counterclaim to the eviction action and denied by the lower court — and were nothing more than artfully pleaded attempts to evade the reach of the Rooker-Feldman doctrine.

Similarly, both the foreclosure and eviction actions were sufficiently final to trigger the Rooker-Feldman doctrine, as final judgment of foreclosure was entered five years prior to the initiation of the federal suit, and the borrower forfeited her opportunity to appeal the housing court’s eviction judgment by failing to post bond.

In order to grant the borrower’s requested relief to vacate the final judgment of foreclosure and enter an injunction prohibiting post-foreclosure proceedings, the district court would be compelled to review, reject and reverse the state courts’ rulings — an invitation that could not be accepted under the Rooker-Feldman doctrine.

Accordingly, because the borrower’s federal suit sought to invalidate the state courts’ judgments, the First Circuit held that the federal trial court lacked jurisdiction to consider the borrower’s claims, and the federal trial court’s dismissal order was affirmed.

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

11th Cir. Upholds Approval of FACTA Class Settlement Despite Non-Lodestar Class Counsel Fees, Other Issues

Muransky v. Godiva Chocolatier, Inc., 27 Fla. L. Weekly Fed. C 1393 (U.S. 11th Cir. 2018)

The U.S. Court of Appeals for the Eleventh Circuit recently affirmed a class settlement where the defendant allegedly violated the federal Fair and Accurate Credit Transactions Act (FACTA) by printing point-of-sale credit card receipts that included more than the last five digits of the card number.  FACTA prohibits merchants from printing “more than the last 5 digits of the card number or the expiration date upon any receipt provided to the cardholder at the point of the sale or transaction.”  15 U.S.C. § 1681c(g)(1).

The Eleventh Circuit held:

  1. Consistent with rulings from other federal appellate courts, the named plaintiff had Spokeo standing to pursue the claims, because the FACTA claims were similar to the common law tort of breach of confidence; and
  1. Class counsel’s untimely attorney’s fees motion, filed two weeks after the deadline for class members to object had passed, did not warrant reversal because four other class members objected after receiving notice of the preliminary approval of class settlement; and
  1. A lodestar analysis was not required for class counsel’s fees because the compensation secured by class counsel and risk of litigation justified an award of one-third of the settlement fund for attorney’s fees and a $10,000 incentive to the class representative.

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

11th Cir. Rejects Borrower Challenges Alleging Lender-Placed Insurance Overcharges, Kickbacks

Patel v. Specialized Loan Servicing, LLC, 27 Fla. L. Weekly Fed. C 1344 (U.S. 11th Cir. 2018)

The U.S. Court of Appeals for the Eleventh Circuit recently affirmed the dismissal of consolidated putative class action cases against mortgage loan servicers and an insurance company, holding that the filed-rate doctrine barred the plaintiffs’ claims.

The plaintiffs alleged that their mortgage loan servicers breached the loan documents and the implied covenant of good faith and fair dealing by supposedly overcharging for “force-placed” insurance (FPI) when the borrowers failed to maintain the coverage required by the mortgage to protect the lender’s security interest.  The claims also included allegations that the insurance company gave the servicers “rebates” or “kickbacks” that were not passed on as savings to the borrowers.

In addition, the plaintiffs alleged that the servicers “colluded” with the insurance company “to disguise the alleged overcharges as legitimate expenses” in violation of the federal Truth in Lending Act, 15 U.S.C. § 1601, tortiously interfered with an existing business relationship, were unjustly enriched and violated the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. § 1962(c), (d), and the Florida Deceptive and Unfair Trade Practices Act, § 501.201, Fla. Stat.

The defendants moved to dismiss the complaint, arguing that plaintiffs’ claims were barred by the filed-rate doctrine which “precludes any judicial action which undermines agency rate-making authority.” The trial court agreed and dismissed the cases for failure to state a claim under Federal Rule of Civil Procedure 12(b)(6). The plaintiffs appealed.

On appeal, the Eleventh Circuit explained that the filed-rate doctrine prohibits a “regulated entity” from charging more than the rate approved by the administrative agency authorized by law to determine the rate.

The Court further explained the filed-rate doctrine bars two types of lawsuits: direct challenges to the filed rate and “facially-neutral challenges—i.e., any cause of action that is not worded as a challenge to the rate itself….” The latter “are barred when an award of damages ‘would, effectively, change the rate paid by the customer-[plaintiff] to one below the filed rate paid by other customers’ or ‘would, in effect, result in a judicial determination of a reasonableness of that rate[.]’” The Court took pains to point out that it doesn’t matter “whether the plaintiff is a rate-payer.”

The Eleventh Circuit then established a “simple framework for determining whether the filed-rate doctrine bars a cause of action. First, the court examines whether the complaint facially attacks a filed rate. Second, if the complaint does not facially attack a filed rate, the court asks whether it implicates the nonjusticiability principle by challenging the components of a filed rate.”

The Eleventh Circuit majority then reasoned that although the plaintiffs argued on appeal that they were not challenging the reasonableness of the defendant insurer’s rates, “the complaints belie this claim” because, most obviously, “the plaintiffs repeatedly state that they are challenging [the insurer’s] premiums.” “[A]nd since these premiums are based upon rates filed with state regulators, plaintiffs are directly attacking those rates as being unreasonable as well.”

The Court concluded that the plaintiffs’ “complaints therefore contain textbook examples of the sort of claims that we have previously held are barred by the nonjusticiability principle.”

Accordingly, the Eleventh Circuit affirmed the trial court’s dismissal for failure to state a claim.

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

11th Cir. Upholds Dismissal, Suggests Sanctions for ‘Shotgun Pleading’

Jackson v. Bank of Am., N.A., 898 F.3d 1348 (11th Cir. 2018)

The U.S. Court of Appeals for the Eleventh Circuit recently rejected an attempt by homeowners to collaterally attack a state court mortgage foreclosure judgment, affirming the trial court’s dismissal of an amended complaint with prejudice for failure to state a claim on alternative grounds.

One day after the foreclosure sale of their home, the plaintiff homeowners sued their lender, loan servicer, and MERS in state court in Alabama, attempting to assert 14 claims under Alabama and federal law.

The complaint was poorly written, making it difficult for each of the defendants to frame their answer. The gist of the complaint was that the servicer improperly declared the plaintiffs in default on their mortgage and stopped accepting their payments without providing an explanation. The plaintiffs sought a declaratory judgment that the plaintiffs were not in default on their loan, prohibiting the foreclosure plus compensatory and punitive damages for the mental anguish caused by the allegedly wrongful foreclosure.

The defendants removed the case to the federal trial court and moved for a more definite statement under Federal Rule of Civil Procedure 12(e), arguing the complaint was a “shotgun” pleading that lumped all of the factual allegations into each count by incorporation, did not differentiate between the defendants and omitted key chronological facts.

The trial court granted the motion and gave the plaintiffs 21 days to serve an amended complaint. After several deadline extensions, the plaintiffs filed their amended complaint, but it contained only minor changes and suffered from the same basic lack of clarity

One of the defendants answered the amended complaint, denying the material allegations and raising failure to state a claim as an affirmative defense. The others moved to dismiss on the same failure to state a claim basis as before.  The magistrate judge issued a report recommending dismissal of the amended complaint against the three moving defendants for failure to state a claim. The plaintiffs objected to the magistrate judge’s report and recommendation, but just before the judge was set to rule, they moved for leave to file a second amended complaint. Shortly thereafter, the defendant that had answered moved for judgment on the pleadings.

The trial court denied the plaintiffs’ motion for leave to amend, adopted the magistrate judge’s report and recommendation, and dismissed the amended complaint with prejudice as to the three moving defendants. The plaintiffs then stipulated to dismissal of the amended complaint against the remaining defendant that had answered. The following day, the trial court entered final judgment, from which the plaintiffs appealed.

On appeal, the Eleventh Circuit quickly affirmed the trial court’s dismissal, but on different grounds, explaining that “[t]he amended complaint is an incomprehensible shotgun pleading . . .  making it nearly impossible for Defendants and the Court to determine with any certainty which factual allegations give rise to which claims for relief. As such, the Amended Complaint patently violated Federal Rule of Civil Procedure 8, which requires a plaintiff to plead ‘a short and plain statement of the claim showing that the pleader is entitled to relief.’’

The Court went on to reiterate its prior decisions regarding the “vices” of shotgun pleadings such as additional expense and delay in the administration of justice. “Tolerating such behavior constitutes toleration of obstruction of justice … [which] is why … a District Court retains authority to dismiss a shotgun pleading on that basis alone.”

The Eleventh Circuit then pointed out that a trial court must give a plaintiff one chance to remedy any noncompliance with Rule 8(a) and the plaintiffs were provided that opportunity. “What matters is function, not form: the key is whether the plaintiff had fair notice of the defects and a meaningful chance to fix them. If that chance is afforded and the plaintiff fails to remedy the defects, the trial court does not abuse its discretion in dismissing the case with prejudice on shotgun pleading grounds.”

The Appellate Court also cited Federal Rule of Appellate Procedure 38, which allows the court of appeals to “award just damages and single or double costs to the appellee” if it determines that an appeal is frivolous. Because plaintiffs’ counsel was on notice of the Court’s precedent regarding shotgun pleadings due to the case law cited in the defendants’ motion to dismiss, yet persisted and then added insult to injury by appealing his incomprehensible complaint, the Court concluded that “[t]his constitutes an abuse of judicial process, a ‘deliberate use of a legal procedure, whether criminal or civil, for a purpose for which it was not designed.’”

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

Need re-certification credits? Working toward becoming a Certified Receivables Compliance Professional (CRCP)? Want the latest information in the Chief Compliance Officer world? RMAI has all this and more with live monthly and pre-recorded webinars.

UPCOMING WEBINARS

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) to one and a half (1.5) credits out of the four (4) credits of Current Issues in Debt Buying required for re-certification. Click to register.

Congratulations to our new and renewed companies and individuals!

New Companies
Convergence Acquisitions, LLC

Renewed Companies
Diverse Funding Associates, LLC
C & E Acquisition Group, LLC
DNF Associates
G Reynolds Sims and Associates, P.C.

Renewed Individuals
Daniel Mezzancello, Director, Legal, Regulatory and Compliance, Resurgent Capital Services
John Rich, President, Credit Management Corporation
Timothy Sullivan, President, HS Financial Group LLC

View all certified companies and certified individuals on our website.

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

Welcome new RMA members!

Consumer Portfolio Services, Inc. — Originating Creditor — California
Kirk Law — Associate Law Firm — Utah
Mountain West Law Group, P.C. — Associate Law Firm — Colorado

Thank you to Dave Snyder of Encore Capital who was instrumental in recruiting the following new member:

Walters Levine & Lozano —Associate Law Firm — Florida

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

Membership Renewals … December 31, 2018 is the deadline to renew!

  • Does your AP department know that DBA is now RMA, the Receivables Management Association International?
    If not, let them know we can send a new W-9 for your 2019 renewal to be paid.
  • Has your company moved?
    If so, please contact bsouza@rmassociation.org with your new mail address.
  • Do you work remotely and haven’t see your renewal?
    Chances are your renewal invoice was mailed to the corporate office.

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

RMA works hard to open new markets and promote the industry at various conferences and events—look for us at these events.

2018 National Creditors Bar Association | October 3-6

California Association of Collectors, Inc. (CAC) is offering RMA members the CAC member rate to attend their Annual Conference Expo. Register Here and use promo code (RMACAC2018) | October 8-9

  • CAC is an RMA Authorized Education Provider and will accept education from their conferences and webinars for RMA’s Certified Receivables Compliance Professional (CRCP).

Lend360 | October 8-10
As a special courtesy, Lend360 is offering an exclusive registration discount of $600 off the current registration rate to RMA members. For the special rate, please use code: RMA360

2018 Compliance Forum | October 16-18

The RMA Annual Conference is a must attend event for the receivables management industry.  February 5-7 2019 in Las Vegas @ the Aria Resort and Hotel.  We have a fantastic lineup of education and networking events.  Get industry insights, legal updates, connect with originating creditors and industry professionals.  Visit rmassociation.org/ac19 for more information.

Contribute Now

Thank you October 2017- October 2018 Legislative Fund contributors. Your support allows us to influence threatening legislation, while also promoting and preserving the best interests of our members. Make your contribution today!

Diamond ($25,000)

Certified Debt Buyer
Portfolio Recovery Associates, LLC

Titanium ($15,000)

Certified Debt Buyer
Cavalry Investments, LLC

Platinum ($10,000)

Certified Debt Buyer
Encore Capital Group

Gold ($7,500)

Certified Debt Buyer
Velocity Portfolio Group

Silver ($5,000)

Certified Debt Buyer
CKS Financial
Crown Asset Management, LLC
JH Capital Group

Affiliate
Cornerstone Support

Bronze ($2,500)

Certified Debt Buyer
Absolute Resolutions Corp.
Galaxy Asset Management, LLC
Integras Capital Recovery LLC
RAzOR Capital
Second Round, LP
Security Credit Services, LLC
The Bureaus, Inc.

Associate Collections Agency
Credit Control, LLC
Glass Mountain Capital, LLC

 

Brass ($1,000)

Certified Collection Agency
First Financial Asset Management, Inc. FFAM360

Certified Debt Buyer
Credit Management Corporation
Gemini Capital Group, LLC
HS Financial Group
Resurgence Capital, LLC
The Cadle Company

Certified Law Firm
Peroutka, Miller, Klima & Peters, P.A.

Certified Broker
DebtTrader

Affiliate
CMS Services
Convoke, Inc.
Digital Recognition Network
FLOCK Specialty Finance
Harvest Strategy Group, Inc.
Resource Management Services, Inc.
RNN Group, Inc.
Troy Capital, LLC
Vertican Technologies, Inc.

Associate Debt Buyer
Balbec Capital
Phoenix Asset Group, LLC
U.S. Equities Corp

Associate Law Firm
Andreu, Palma, Lavin & Solis, PLLC
Bedard Law Group, P.C.
Delev & Associates, LLC
Mullooly, Jeffrey, Rooney & Flynn, LLP
Rausch, Sturm, Israel, Enerson & Hornik, LLC
Simmonds & Narita, LLP
Tobin & Marohn
Winn Law Group, APC

Other

Certified Debt Buyer
Acctcorp International, Inc.
Autovest, LLC
Capio Partners
Capital Alliance Financial, LLC
Cascade Capital, LLC
Collins Asset Group
Converging Capital, LLC
Debt Recovery Solutions, LLC
Federal Pacific Credit Company, LLC
Icon Equities, LLC
Indiana Receivables, Inc.
Investment Retrievers, Inc.
NCB Management Services, Inc.
Pharus Funding, LLC
Portfolio Group Investors, LLC
Poser Investments, Inc.
Quantum3 Group, LLC
Stoneleigh Recovery Associates
United Debt Holdings
West Bay Recovery, Inc.

Certified Collection Agency
Frontline Asset Strategies, LLC

Certified Law Firm
Dobberstein Law Firm, LLC
G. Reynolds Sims & Associates, P.C.
Law Offices of Daniel C. Consuegra, P.L.
Law Offices of Steven Cohen, LLC

Affiliate
Accelerated Data Systems
CenterPoint Legal Solutions, LLC
ComplyARM, Inc.
Comtronic Systems, LLC
Debt Sales Partners
Diversified Consultants, Inc.
Equifax, Inc.
Metronome Financial, LLC
MRS BPO, LLC
PCI Group Inc.
ProVest LLC
SAM, Inc. – Solutions for Account Management
TransUnion
VeriFacts, Inc.
VoApps

Associate Collection Agency
Adams London & Weiss, LLC
Alpha Recovery Corp.
Apple Recovery, LLC
Capital Collection Management, LLC
Financial Recovery Services, Inc.
FMS, Inc.
Lockhart, Morris & Montgomery, Inc.
Radius Global Solutions
SIMM Associates, Inc.
Tate & Kirlin Associates, Inc.

Associate Debt Buyer
ABC Collections, LLC
Allen & Durrant Corp.
Alliance Credit Services, Inc.
Atlas Acquisitions
Emergent Business Group Inc.
Fair Collections & Outsourcing, Inc.
Genesis Recovery Services
International Debt Buying Consultants, LLC dba Portfolio Management Group
National Recovery Solutions, LLC
PerSolve, LLC
RIP Medical Debt
Universal Fidelity LLC
Western States Financial Management, LLC

Associate Law Firm
Brownstein Hyatt Farber Schreck, LLP
Butler & Associates, P.A.
Harrington, Anderson & DeBlasio
Hinshaw & Culbertson
Hudson Cook, LLP
Hunt & Henriques
Keith. D. Weiner & Associates, LPA
Kirschenbaum & Phillips, P.C.
Malone Akerly Martin PLLC
Maurice Wutscher LLP
Pressler, Felt and Warshaw, LLP
Schachter Portnoy, LLC, Attorneys at Law
Slovin & Associates
Sonnek & Goldblatt, Ltd.
Spencer Fane LLP
The Law Offices of Ronald S. Canter
Vargo & Janson, P.C.
Venable, LLP

Individual(s) and/or Non-member(s)
Central Portfolio Control, Inc.
Court Appearance Professionals
David Reid
Greenberg Advisors, LLC
Susie Chandler

2018-11-28T11:51:55+00:00 November 15, 2018|RMA Update|