DFPI Marks Success in Implementation of the California Consumer Financial Protection Law

SACRAMENTO, Calif. — A year after implementing one of the most expansive consumer protection laws in the country, the Department of Financial Protection and Innovation (DFPI) announced it has collected close to $1 million in restitution for consumers, fielded hundreds of additional complaints related to the law, and launched more than 100 investigations using its expanded authority under the California Consumer Financial Protection Law (CCFPL).

The Department also created several new divisions to expand oversight and outreach, including the Consumer Financial Protection Division, Office of Financial Technology Innovation, Office of the Ombuds, and a Targeted Outreach Team responsible for working with historically underserved communities that include veterans, senior citizens, students, and immigrants.

“The Department has made substantial progress in its first year to implement the new law, expand protection for consumers, and foster responsible financial innovation,” said Clothilde V. Hewlett, DFPI Commissioner. “We remain committed to accomplishing the goals of Governor Gavin Newsom and are grateful to all stakeholders, including the Legislature, consumer advocates, industry partners, small businesses, community-based organizations, and many others for their continued input and support.”

In 2020, the Legislature passed the CCFPL as AB 1864 (Limón). Identifying gaps in consumer protection due to strict definitions in existing licensing laws, this new law provided the DFPI with the appropriate authority to oversee areas of the financial marketplace previously unregulated by the DFPI, including debt collectors, credit repair and debt relief companies, private postsecondary student loan products, and financial tech services that include early wage access products. The Department has also begun licensing debt collectors.

The first change under the CCFPL was a new name for the Department which was formerly the Department of Business Oversight. Over the past twelve months, the Department has experienced many key successes under the CCFPL. These can be found in a statutory report that has been posted to the DFPI website: https://dfpi.ca.gov/wp-content/uploads/sites/337/2022/03/DFPI-CCFPL-2021-annual-report.pdf.

Key takeaways from CCFPL Report:

Enforcement

During its first year with authority under the CCFPL, the DFPI proactively identified enforcement targets and opened 106 investigations that resulted in 49 public actions under the CCFPL.

The DFPI investigations resulted in 49 public enforcement actions, $975,000 in restitution to consumers, $547,500 in penalties, and included several “first of its kind” actions for the DFPI in debt collection, student debt relief, earned wage access, and private post-secondary education financing.

Regulatory Activities

In 2021, the DFPI issued four invitations for comments to solicit stakeholder feedback on various aspects of implementation of the CCFPL. DFPI received 76 comment letters.

As of the end of 2021, the DFPI had three pending regulation packages pursuant to the CCFPL: 1) complaint procedures, 2) commercial financing UDAAP, and 3) phase one registration categories.

Proposed registration includes debt settlement services, student debt relief services, postsecondary education financing, and wage-based advances.

Research and Market Monitoring

In September 2021, the DFPI created a research team to help the DFPI identify emerging financial activities; scout for unlawful, unfair, deceptive, and abusive practices; and make policy recommendations based on consumer impact.

The research team is evaluating DFPI’s consumer complaint data to identify broader market trends that may pose risks to consumers.

Consumer Complaint Handling

In 2021, the Consumer Services Office (CSO) received 638 complaints regarding products and services subject to the CCFPL.

Complaints submitted under the new law, which covered debt collection activities in the first year, increased each quarter with a dramatic surge in the second half of the year when CCFPL complaints increased nearly 140 percent.

The top categories of complaints included debt collection, cryptocurrency, and “neo banks,” financial technology, or “fintech” service providers, partnering with banks to offer deposit account services. The top complaints appear to have been driven by communications efforts to raise awareness about the DFPI’s expanded authority and mission.

Office of Financial Technology and Innovation

In 2021, the Office of Financial Technology and Innovation (OFTI) met with dozens of companies, venture capitalists, lawyers, industry advocacy groups, federal and state financial regulators, consumer advocacy groups, and academics to better understand stakeholder perspectives on what constitutes responsible innovation in financial services.

OFTI participated in more than a dozen public events to publicize OFTI’s activities and extend the invitation to meet. The Office held weekly office hours, open to all who registered.

Communications and Outreach

In 2021, the DFPI held three roundtables with community groups, dozens of external stakeholder meetings, presented on the topic at several events and conferences, and participated in dozens of media interviews to raise awareness about the Department’s expanded authority and work.

A communications vendor selected to run a statewide communications campaign conducted four multilingual focus group discussions and launched its campaign March 2022 with radio, print, digital, social media, and outdoor advertisements.

The Targeted Outreach Team participated in 141 events in 2021 with an estimated total attendance of more than 9,700 and distributed more than 96,400 pieces of promotional and educational materials.

About the DFPI

The DFPI licenses and regulates state-chartered banks and credit unions, commodities and investment advisers, money transmitters, the offer and sale of securities and franchises, broker-dealers, nonbank installment lenders, payday lenders, mortgage lenders and servicers, escrow companies, Property Assessed Clean Energy (PACE) program administrators, debt collectors, credit repair and consumer credit reporting agencies, debt-relief companies, certain rent-to-own providers, and more.

For more information about the DFPI, visit their website at https://dfpi.ca.gov/.

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Requesting Too Much Assistance from the Alleged Victim in Identity Theft Investigations

On February 28, 2022, the Court of Appeals for the Seventh Circuit affirmed a district court’s decision to enter summary judgment for a debt collector for alleged violations of the FDCPA and FCRA. Woods v. LVNV Funding, LLC and Resurgent Capital Services, L.P., No. 21-1981 (7th Cir. 2022). Focusing strictly on the FCRA claim, the plaintiff in Woods asserted that the debt collector violated section 1681s-2(b)(1)(A) by failing to conduct a reasonable investigation into his fraud claims.

In this case, once the debt collector received the account and began attempting to collect the debt, it started receiving disputes from the plaintiff. The debt collector responded to the disputes by requesting additional information and documentation regarding the alleged identity theft. Rather than providing information or documentation in support of the dispute to the debt collector, the plaintiff contacted the creditor, who subsequently determined that the debt belonged to the plaintiff.

The plaintiff filed a report with the local police department, alleging that he was the victim of identity theft, and submitting the correspondence from the creditor. The local police spoke with the plaintiff and prepared a report based on the information provided from the plaintiff. The police report included a statement that the creditor “had completed an investigation and . . . determined that it was in fact him.”

After having no success with the police department, the plaintiff filed a formal dispute with the CRAs and included a copy of the police report. The CRAs forwarded the ACDV to the debt collector, who reviewed the information provided and verified to the CRAs that the debt belonged to the plaintiff. Subsequently, the debt collector sent the plaintiff another letter inviting him to provide additional documentation to help resolve the case and attached a blank identity-theft affidavit. The plaintiff did not respond to the debt collector’s requests for information or documentation.

In determining whether the debt collector conducted a reasonable investigation following the receipt of the ACDV, the Seventh Circuit considered the content of the police report attached to the ACDV. Specifically, the Seventh Circuit focused on the officer’s commentary in the police report which indicated that the creditor had investigated the matter and determined that the debt belonged to the plaintiff. The Court noted that the debt collector was “well within its rights to rely on this representation to some degree” given that the ACDV made it seem that the creditor had already resolved the alleged fraud claim and affirmed the district court’s decision finding no FCRA violation.

As for the debt collector’s investigation, the Seventh Circuit stated that it was reasonable for the debt collector to send another request for documentation to the plaintiff because the ACDV made it seem that the vendor had already resolved the fraud claim against the plaintiff. However, the Seventh Circuit seems to suggest that under a different set of facts, continuous requests for documentation may be problematic. In fact, in closing, the Seventh Circuit states that its opinion does not offer furnishers “a license to offload their investigative obligations to consumers by spamming them with requests for additional information.” Thus, while communicating with the alleged victim about an FCRA identity theft dispute is considered reasonable, and even required, in most circumstances, the takeaway from this decision is that the level of involvement from the alleged victim must be determined on a case-by-case basis.

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Prodigal Announces Partnership: Best-in-Class Contact Center Telephony Meets Best-in- Class Interaction Intelligence

MOUNTAIN VIEW,
Calif.–
 Prodigal, the intelligence layer for lenders, is
proud to announce a strategic partnership with LiveVox, a leading cloud-based
provider of customer service and digital engagement tools.

Customer interactions provide invaluable insights on financial
health, experiential, and behavioral data, but also represent an epicenter of
inefficiency and compliance risk. Prodigals
partnership with LiveVox joins two performance-driven, omnichannel solutions
together in a simple and modular handshake to put consumers first.

LiveVox offers a cutting-edge API ecosystem to support
integrations with its world-class telephony infrastructure. LiveVoxs platform forks out
real-time shadow audio streams to power intelligent applications.

Prodigal easily integrates with LiveVox to deliver real-time,
in-browser interaction intelligence. For Prodigal customers, this partnership
represents a major milestone on their technological evolution: real-time
intelligence and agent productivity are available in browser, no IT bandwidth negotiation required.

Prodigal will seamlessly deliver products
that translate customer interactions to insights, meeting the growing need for
accurate intelligence across healthcare, consumer lending, and collections industries.

In addition to consumer experience benefits,
Prodigal customers can expect productivity benefits as insights
empower agents with
after-call summaries and next-action prompts.

Im excited to bring the transformative value of a
Prodigal and LiveVox partnership to our customers. When we align with
like-minded organizations to improve our solutions, we can offer more than the
sum of our parts: 1+1 = 5,” said Shantanu Gangal, CEO of Prodigal.

Long-time Prodigal customers already see that
premium. Said Greg Schubert,
President & CEO of Sequium Asset Solutions,Prodigal’s real time insights had material impact
quickly. It made agents both effective on every customer interaction and
efficient between interactions. Prodigal
s native integration
with LiveVox made these business goals our sole focus from day one.”

LiveVox (Nasdaq: LVOX) is a next generation
contact center platform that powers more than 14 billion omnichannel
interactions a year. By seamlessly unifying blended omnichannel communications,
CRM, AI, and WEM capabilities, the Company
s technology delivers
exceptional agent and customer experiences, while helping to mitigate
compliance risk. With 20 years of cloud experience and expertise, LiveVox
s
CCaaS 2.0 platform is at the forefront of cloud contact center innovation. The
Company has more than 650 global employees and is headquartered in San
Francisco, with offices in Atlanta; Columbus; Denver; New York City; St. Louis;
Medellin, Colombia; and Bangalore, India. To stay up to date with everything
LiveVox, follow at @LiveVox or visit livevox.com.

Prodigal has redefined technologys
role in customer care, pioneering a new category of intelligence for financial
and healthcare services. The Company uses artificial intelligence and machine
learning to deliver actionable insights ultimately maximizing revenue,
optimizing operations, and minimizing compliance risk for its customers.
Prodigals global team, whose backgrounds
intersect at financial services and data science, is headquartered in Mountain
View, California. Prodigal is backed by Menlo Ventures, Accel and Y Combinator.
For more information about Prodigal, please visit
prodigaltech.com and follow us @prodigaltech

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CFPB Says its UDAAP Authority Includes Ability to Review for Discrimination; Updates UDAAP Exam Procedure

On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it will use its supervisory operations to evaluate discrimination in all consumer finance markets including credit, servicing, collections, consumer reporting, payments, remittances, and deposits. 

Acknowledging this is new territory and an expansion of its supervisory authority,  CFPB Director Rohit Chopra stated, “we will be expanding our anti-discrimination efforts to combat discriminatory practices across the board in consumer finance.”  Though fair lending laws may not apply to these markets, according to the CFPB, since discrimination meets the definition of “unfairness” it has the authority to make a determination regarding discrimination and disparate impacts to consumers. As such, the CFPB will use its authority to ensure companies are appropriately testing for and eliminating discrimination.

To meet its newly expanded efforts, the CFPB updated the UDAAP exam manual. The exam manual, which notes that consumers can be harmed whether or not discrimination is intentional, requires examiners to look at a covered entities process for assessing risks and discriminatory outcomes, including documentation of customer demographics and the impact of products and fees on different demographic groups. The CFPB will also use its authority to look at how companies test and monitor their decision-making processes for unfair discrimination.

Additionally, the updated exam manual includes questions related to:

  • whether the entity has a process in place to percent discrimination, including the evaluation of all policies and procedures for discrimination and continued monitoring (Question 1(f) page 13)
  • whether the company’s compliance management system includes a process for periodic analysis and monitoring of all decision-making processes (Question 2(j) page 14)
  • policies, procedures, and training to prevent discrimination (Question 2(k)(m) page 14)
  • the decision-making process for collections (Question 3(l) page 15)
  • how the entity evaluates and makes necessary adjustments and corrections to prevent discrimination.

insideARM Perspective:

Let’s get this piece out of the way: discrimination is a terrible thing. No one in the ARM industry is advocating for the ability to discriminate. That said, in order to go down this path (and setting aside whether the CFPB has the authority to do this), the CFPB needs to provide the industry more information regarding what it intends to look for than the vague, loose, open-ended questions found in the exam manual. 

Additionally, the CFPB should explain how it intends to look at subjective issues which might affect its analysis of a debt collector. For example, if the biggest client of an ARM entity is an inner-city hospital or a retail chain located in a heavily minority populated area, it would make sense for that ARM entity to have more monitory consumers in certain stages of collections. Instead, the new exam manual seems to take an entirely objective approach and does little to explain how an ARM entity can comply.

When the CFPB announces new expectations and new exam manual updates to go along with those expectations, it’s a good time to think about the gaps in your CMS. One of the best tools for this job is a risk and gap assessment. 

Find out how to start your own assessment with the on-demand webinar, A Complete Guide to Risk and Gap Assessments – How to Get Started (from insideARM and Research Assistant). You’ll learn what you can expect from a good risk and gap assessment, plus, find out how to test, how to break an assessment into manageable chunks and assign responsibility, how to win support from operations, and how to build towards ongoing audits so you get all the benefits of an assessment without having to put in all the work. Get it here.

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Harvest Strategy Group, Inc. Appoints Brad McCurnin as CEO and David Ravin as Vice Chairman

DENVER, Colo. – The board of directors of Harvest Strategy Group, Inc. takes great pride in announcing the promotions of Brad McCurnin to President and Chief Executive Officer and David Ravin to Vice Chairman effective April 1, 2022. These new responsibilities support Harvest’s growth in the industry and will help distribute additional strategic management tasks between them as they pioneer new opportunities for the company. 

“Over the years at Harvest and working in the industry, I have had the great pleasure of working for the best people in the industry and making lifelong friendships,” Brad McCurnin says. “As incoming President & CEO for Harvest Strategy Group Inc., I am thankful to be working with our talented team to deliver on our mission of leading the accounts receivable management industry through partnerships, service, technology, and superior results. I look forward to taking the next step as CEO of Harvest to lead our organization and continue our growth serving the industry.” Brad McCurnin

Mr. McCurnin is also passionate about Harvest’s charitable initiatives, which included 10 charities in 2021 with a focus on Diversity, Equity, and Inclusion (DEI), as well as helping families who are most in need. Mr. McCurnin has been active in the accounts receivable industry for over 20 years with a focus on operations, analytics, and modeling. He holds an MBA from Louisiana State University.

“Since the company was founded in 2007, Harvest has grown beyond even our expectations,” David Ravin says. “Our unique culture and values are what enable Harvest to enjoy an average tenure of nearly a decade among its management team and staff and provide our clients with best-in-class recovery management services. I am proud to take on the responsibility as Vice Chairman and am excited to continue to work with Brad and the rest of our management team to grow Harvest into the premier receivables organization.” David Ravin

David Ravin is a 16 year veteran of the collections industry and has worked closely with Mr. McCurnin in many roles for Harvest Strategy Group. David began as CEO before moving into the Executive Vice President role. Mr. Ravin has a Bachelor’s in Film Production and Screenwriting from the University of Colorado-Boulder and worked as the Assistant SVP of Physical Production for Spyglass Entertainment for several years before working as a Client Relations Manager for Machol & Johannes, PC. He has attended both the University of Denver Daniels College of Business and the Northwestern University Kellogg School of Management for executive development courses. 

Harvesting Potential

David Ravin and Brad McCurnin’s close working relationship has pushed Harvest Strategy Group to the forefront of the ARM industry. Harvest is a member of both leading industry organizations Receivables Management Association International (RMAI) and ACA International. In addition, they maintain membership with the National Automotive Finance (NAF) Association to expand their outreach in every sector they help manage. 

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Harvest challenges boundaries, thinks outside the box, and feels a sense of ownership and accountability for the results created for clients. Under Mr. Ravin and Mr. McCurnin’s guidance, Harvest maximizes each company’s litigation and management strategies. Harvest’s proprietary ProScore data model helps to ensure the best direction for each account so that the right channels find the right accounts.

Learn More

With the unique ability to align client’s needs with specific in-network participants, the Harvest team is engaged end-to-end with comprehensive compliance oversight and performance management. To learn more about Harvest Strategy Group or to contact them to learn more about how their account management services can help clients manage their receivables, call (303) 531-0654 or visit their website at harveststrategygroup.com.

About Harvest Strategy Group

Harvest Strategy Group provides single-point-of-contact, nationwide recovery management services for banks, finance companies, debt buyers, and credit unions. The company fosters an entrepreneurial environment and encourages its staff to challenge boundaries, think outside the box, and feel a sense of ownership and accountability for results. Harvest’s mission is to lead the accounts receivable management industry through strength in partnerships, exceptional service, and the delivery of superior results. Harvest Strategy Group Inc. is located in Denver, CO. 

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Equifax, Experian, and TransUnion Support U.S. Consumers With Changes to Medical Collection Debt Reporting

CHICAGO, Ill. — On March 18, 2022, the three nationwide credit reporting agencies (NCRAs) – Equifax (NYSE: EFX), Experian (LON: EXPN), and TransUnion (NYSE: TRU) – announced significant changes to medical collection debt reporting to support consumers faced with unexpected medical bills. These joint measures will remove nearly 70% of medical collection debt tradelines from consumer credit reports, a step taken after months of industry research.

According to the Kaiser Family Foundation, two-thirds of medical debts are the result of a one-time or short-term medical expense arising from an acute medical need. After two years of the COVID-19 pandemic and a detailed review of the prevalence of medical collection debt on credit reports, the NCRAs are making changes to help people to focus on their personal wellbeing and recovery.

Effective July 1, 2022, paid medical collection debt will no longer be included on consumer credit reports. In addition, the time period before unpaid medical collection debt would appear on a consumer’s report will be increased from 6 months to one year, giving consumers more time to work with insurance and/or healthcare providers to address their debt before it is reported on their credit file. In the first half of 2023, Equifax, Experian and TransUnion will also no longer include medical collection debt under at least $500 on credit reports.

The companies’ CEOs provided a joint statement on the decision to change medical collection debt reporting:

“Medical collections debt often arises from unforeseen medical circumstances. These changes are another step we’re taking together to help people across the United States focus on their financial and personal wellbeing,” said Mark W. Begor, CEO Equifax; Brian Cassin, CEO Experian; and Chris Cartwright, CEO TransUnion. “As an industry we remain committed to helping drive fair and affordable access to credit for all consumers.”

For more information, please visit: Equifax, Experian, and TransUnion.

About Equifax

At Equifax (NYSE: EFX), we believe knowledge drives progress. As a global data, analytics, and technology company, we play an essential role in the global economy by helping financial institutions, companies, employers, and government agencies make critical decisions with greater confidence. Our unique blend of differentiated data, analytics, and cloud technology drives insights to power decisions to move people forward. Headquartered in Atlanta and supported by more than 13,000 employees worldwide, Equifax operates or has investments in 24 countries in North America, Central and South America, Europe, and the Asia Pacific region. For more information, visit Equifax.com.

About Experian

Experian is the world’s leading global information services company. During life’s big moments — from buying a home or a car to sending a child to college to growing a business by connecting with new customers — we empower consumers and our clients to manage their data with confidence. We help individuals to take financial control and access financial services, businesses to make smarter decisions and thrive, lenders to lend more responsibly, and organizations to prevent identity fraud and crime.

We have 20,000 people operating across 44 countries, and every day we’re investing in new technologies, talented people, and innovation to help all our clients maximize every opportunity. We are listed on the London Stock Exchange (EXPN) and are a constituent of the FTSE 100 Index.

Learn more at www.experianplc.com or visit our global content hub at our global news blog for the latest news and insights from the Group.

About TransUnion

TransUnion is a global information and insights company that makes trust possible in the modern economy. We do this by providing an actionable picture of each person so they can be reliably represented in the marketplace. As a result, businesses and consumers can transact with confidence and achieve great things. We call this Information for Good®.A leading presence in more than 30 countries across five continents, TransUnion provides solutions that help create economic opportunity, great experiences, and personal empowerment for hundreds of millions of people.

Media Contacts:

FTI Consulting

CRAs@fticonsulting.com

Kate Walker

Equifax

mediainquiries@equifax.com

Scott Anderson

Experian

scott.n.anderson@experian.com

David Blumberg

TransUnion

david.blumberg@transunion.com

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Crown Asset Management Announces Promotions For Eight Team Members

DULUTH, Ga.– Crown
Asset Management
has announced eight promotions:


Shawn Bradley has been promoted from Vice
President of Finance to Senior Vice President of Finance & Corporate
Strategy
. Shawn joined Crown in 2020 as the Director of Finance and has
overseen a handful of Crown strategies including capital markets, prospective
portfolio acquisition evaluation, mergers and acquisitions, due diligence, deal
structuring, legal documentation, and relationship management. In his expanded
role, he will lead the strategic efforts in finance, business development,
information technology, human resources, accounting, and project management.
Shawn has extensive experience in banking and finance, which includes lending
to direct and indirect non-bank financial institutions focused on near-prime
and non-prime consumer markets, commercial finance companies, as well as
distressed debt investors. 

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Rebekah Luebcke has been promoted from Director of
Operations to Vice President of Operations. Rebekah joined Crown Asset
Management in 2017, bringing over 15 years of customer service and management
experience in the accounts receivable management and payment processing
industries. She has overseen many of Crown’s extensive daily activities and
will work as VP of Operations to ensure Crown is operating at maximum
efficiency. 

  

Leah Ri has been promoted from Senior Financial
Analyst to Manager of Financial Planning and Analysis. Leah joined
the Crown Asset
Management team in 2017 as a Financial Analyst and
has been instrumental in a wide array of financial obligations including
budgeting, forecasting, and building financial models. Her deep understanding
of Crown’s internal financial processes will be key to her managerial
responsibilities moving forward. 


Sarah Pittman has been promoted from Legal
Services Lead to Legal Services Manager. Sarah will lead a staff of
legal support staff professionals and provide documentation, research, and
additional support to the Crown Legal Services team. Her unique skills and
experience will help her further develop the associates on her team, create
efficiencies in the team’s processes, and bring additional value to the
organization.


Laura Powers has been promoted from Staff
Accountant to Senior Accountant. Laura has performed exceptionally well
in all tasks assigned to her since she joined the company in 2017 and will now
regulate and authenticate financial transactions and reporting generated by
Crown’s servicers and other external customers

 

Sharn Fuller joined CAM in November 2018 and
has been with the Audit and Compliance Department since January 2020. Sharn’s
recent promotion from Compliance Auditor to Senior Compliance Auditor
will allow Sharn to be immersed in additional aspects of the department’s responsibilities
and deliverables while continuing to support CAM’s ongoing compliance goals and
objectives. 

 

Bryce Thomas and Rhonda Bradtmueller
have been promoted from Business Analysts to Senior IT Analysts. Crown’s
history is supplemented by rigorous data and predictive analysis efforts led by
team members like Bryce and Rhonda. In their new roles, they will ensure that
each unique and proprietary system Crown offers can be tailored to each
client’s needs while providing the documentation and management needed to
complete assigned projects. 

Brian
Williams, Crown Asset Management Owner and CEO
stated:
“Acknowledging each of these team members’ dedication, commitment to Crown, and
excellence in their department is something I take pride in as CEO. Their
contributions make Crown who we are. I am proud of the work each of our team
members puts in each day, and I look forward to our continued growth in 2022
with these eight team members in further leadership positions.” 

 

About Crown Asset Management

Founded in 2004, Crown
Asset Management, LLC
, is a professional receivables management firm that outsources
purchased accounts to a nationwide, proprietary network of collection agencies
and law firms. Utilizing a cutting-edge predictive analytical model during
pre-purchase portfolio due diligence, their team focuses on achieving
appropriate financial returns while ensuring the best possible experience for
consumers. They are an
RMAI
Certified Receivables Business
headquartered in Duluth, GA.

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RMAI Celebrates a Decade of Its National Certification Program

SACRMENTO, Calif. —  The RMAI Certification Council announces the adoption of version 10.0 of the Receivables Management Certification Program (RMCP) after a seven-month development and review process. Several significant enhancements were added to the program in version 10.0, including requiring Certified Businesses to:

  • Maintain a cyber-crime insurance policy.
  • Maintain a policy which prevents discriminatory collection practices.
  • Notate consumer communication restrictions and transmit those restrictions when appropriate.
  • Obtain specific data and documents when purchasing or selling installment loans (fintech and traditional).

“As we launch version 10.0 of our national certification program, its humbling to see how far RMAI has come in the development of uniform standards of best practice for the receivables management industry,” said Adam Parks, President of the Receivables Management Association International (RMAI).

RMAi Version 1 to Version 10 Comparison

“As we prepare for our second decade of advancing comprehensive and uniform standards of best practice, RMAI’s focus will remain on the consumers we protect and the industry we proudly serve. The statistics demonstrate the value RMAI certification brings to both audiences as we continue to see reduced complaints and litigation against RMAI certified businesses.”

For more information on RMAI certification for receivable businesses and individuals, please visit the RMAI website at www.rmaintl.org/certification. For more information on version 10.0, view our program overview.

About Receivables Management Association International

Receivables Management Association International (RMAI) is a nonprofit trade association representing more than 590 businesses that support the purchase, sale, and collection of performing and nonperforming receivables on the secondary market. The RMAI Receivables Management Certification Program and Code of Ethics set the global standard within the receivables industry due to the rigorous uniform standards of best practice which focus on protecting consumers.

More information about RMAI is available at www.rmaintl.org.

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Recycled Number Blues: Good Faith Defense Rejected Again as Liberty University Trapped in TCPA Suit

Editor’s note: This article is provided through a partnership between insideARM and Squire Patton Boggs LLP, which provides a steady stream of timely, insightful and entertaining takes on TCPAWorld.com of the ever-evolving, never-a-dull-moment Telephone Consumer Protection Act. Squire Patton Boggs LLP—and all insideARM articles—are protected by copyright. All rights are reserved

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LTD Financial Services, L.P. Launches Improved Customer Interaction Website

HOUSTON, TX — LTD Financial Services, L.P., a full service accounts receivable management and business process outsourcing company, is excited to launch its new and improved consumer website. The new website provides consumers additional flexibility and self-serve functionality with the ability to:

  • Negotiate and make payment arrangements
  • Update contact information including mailing address, email address, and phone numbers
  • Update preferred contact method(s)
  • View payment history
  • Review past letters
  • Notify of a dispute
  • Request additional account information

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“We have put great thought and resources into the development of our new site.” Says David John, CEO of LTD. “Our goal is to provide consumers with a portal that gives them access to their account 24 hours a day, 7 days a week. In addition to the freedom to manage their account at any time of the day or night, some consumers prefer to self-manage without interacting with an agent. This site gives them that ability, and more.”

Visit the updated LTD website at www.ltdfin.com.

About LTD Financial Services, L.P.

Established in 1993, LTD Financial Services, L.P. is a nationally recognized provider of ARM and BPO services. LTD’s solutions consistently deliver quality customer experiences and superior financial results for our clients through leading technology, omni-channel communications, and data driven decisions in a fully compliant, customer-centric culture. Our approach places our clients first in every aspect of our relationship including Customer Solutions, Care, Collections, Recovery, Compliance, Controls, Communication, and Accountability.

LTD Financial Services, L.P. Launches Improved Customer Interaction Website
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