Archives for December 2018

STERLING, Ill. — VeriFacts employees miss no opportunity to stretch their creative and clever muscles, as could be seen on Boss’s Day in October.  What better way to celebrate the appreciation and achievements of CEO Stephanie Clark, than with a witty and bold surprise. Employees gathered in the office for the monthly meeting as Stephanie made her way to the front to address the company.  Much to her surprise, she was greeted by over 100 Hawaiian shirts and mustaches awaiting the updates. And so it began, yet another rambunctious tradition; Magnum PI day to celebrate the VeriFacts history of quality investigative work and a company culture that runs deep throughout each level of the organization.  

If you know VeriFacts, you’re probably already picturing it; the flowered shirts, the stick-on mustaches, the aviator sunglasses.  If not, let’s get you up to speed. Over the last 30 years, VeriFacts has come to be known for its genuine, lively spirit. Whether internally with employees or on the road with clients and vendors, it’s no secret that the sense of Go Big or Go Home is alive and well.  As VeriFacts continues to take the industry by storm, bystanders marvel at the edgy forward thinkers behind the wheel.  The creative and fun culture has developed into not only a place where people want to work, but where people want to stay.  The flexibility and fulfillment breeds long term employees that truly master their craft.

About VeriFacts

Since 1987, VeriFacts has provided quality skip tracing services to the financial industry.  Over 50 years combined experience within the executive team alongside an innovative R&D team provide the most trusted verified solutions available on the market today.  Long lasting vendor partnerships ensure the most transparent compliance and security controls while the client services team offers individualized support and a 100% quality guarantee.

To learn more about VeriFacts and the programs available to support collection efforts, please email sales@verifactsinc.com or call 800-542-7434.

When discussing FCRA, we often concentrate our focus on certain individuals and entities trying to enforce the statute: the CFPB (or BCFP), FTC, class action firms, and individual plaintiffs.  Nonetheless, a recent settlement demonstrates the importance of yet another actor—state agencies. In In the Matter of Encore Capital Group, Inc., Midland Funding, LLC, and Midland Credit Management, Inc., a debt buyer learned this lesson while facing a multi-million dollar enforcement action from over 40 states, alleging violations of both FCRA and the Fair Debt Collection Practices Act (the “FDCPA”).

Editor’s Note: Here is insideARM’s article about the Encore/Midland matter.

While state authority to enforce the FDCPA and other consumer finance statutes arose as a result of the Dodd-Frank Consumer Financial Protection Act, state agencies have long been vested with the authority to enforce FCRA. 15 U.S.C. § 1681s(c) provides state agencies with the authority to investigate and bring enforcement actions against credit reporting agencies, furnishers, and other regulated persons under FCRA. This includes a broad range of relief, including injunctive relief, actual damages, statutory damages, and attorney’s fees.

The authority of state agencies under FCRA is not unlimited. State agencies must confer with the CFPB and the FTC, and allow the federal agencies to participate in any FCRA suit they file. Even more importantly, state agencies must start by seeking injunctive relief rather than monetary relief. And their monetary relief is limited to relief for violations that occur after the defendant breaches injunction.

Because of these limitations, state agencies rarely file suit to enforce FCRA. Nonetheless, companies who find themselves in the crosshairs of state regulators for other reasons should keep a close eye on FCRA compliance, particularly while negotiating settlement agreements with state regulators.  If, for instance, a settlement agreement contains injunctive provisions involving FCRA (as is the case in the Midland settlement agreement), then the state agency will have a broad range of FCRA-related enforcement mechanisms at its disposal if it believes that the settlement agreement was violated.

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Editor’s note: This article is provided through a partnership between insideARM and Womble Bond Dickinson. WBD provides a steady stream of their timely, insightful and entertaining take on this ever-evolving, never-a-dull-moment topic. WBD – and all insideARM articles – are protected by copyright. All rights are reserved.

ROCHESTER, N.Y. — Mark E. Davitt, CEO of Continental Service Group, Inc., d/b/a ConServe, was recognized last night at a celebratory event to honor the 2018 ICON Award recipients at the Genesee Valley Club in Rochester, New York. Presented by the Rochester Business Journal, the ICON Honors awards recognizes Greater Rochester Area business leaders over the age of 60 for their notable success and demonstration of strong leadership both within and outside of their chosen field.

Mark was honored for his contributions to his community, his organization, and the collections industry. His vision and leadership have distinguished him amongst his colleagues within the business community and this induction ceremony was a recognition of his outstanding achievements and unrivaled ethics.

According to Marlene Bessette, President and CEO of the Catholic Family Center, “Mark brings an elevated sense of community involvement to his workplace. Through his organization’s Jeans for Charity and matching gift program, Mark makes corporate social responsibility visible every day. The program, which has been in place since 2008, is a unique way to give every employee a chance to make a difference to a charity or cause that has a personal meaning to them while getting to dress down in their favorite pair of jeans.” Sister Mary Anne Laurer, Director of Development at Sisters of Saint Joseph of Rochester, notes that “Mark is a business and community leader who fits the Rochester ICON description in every way. He is humble with no signs of ostentation, and he sees the bigger picture and acts generously on behalf of the community in vital areas of education and community engagement.” Mark’s Mission, Vision, and Values have served as the basis of his organization’s fundamental principles while simultaneously exemplifying the true essence of ethics and integrity for his team.

About ConServe ConServe is a top-performing award-winning provider of accounts receivable management services specializing in customized recovery solutions in higher education, government, consumer and commercial markets. For over 30 years, we have been a consumer-centric organization that operates as an extension of our Client’s valued brand. Anchored with ethics and compliance, we’ve redefined collections with The ConServe Advantage® while partnering with our Clients to give them peace of mind and to help them achieve their goals. Ethics. Technology. Performance.

Put The ConServe Advantage® to work for you: www.conserve-arm.com We’re hiring: www.ConServeJobs.com

About ConServe’s Jeans For Charity program: ConServe’s Jeans For Charity initiative began in 2008 when the team’s employees had an idea to launch a program that would provide a way for the company’s mission of “improving the human condition” to coordinate with the organization’s commitment of giving back to their community. ConServe employees are given the opportunity to participate in monthly charitable donations, benefitting a wide-range of recipients, in exchange for having the option of dressing down and wearing jeans to work for the entire month. The funds raised by the employees’ generosity are supplemented by the organization’s Matching Gift Program – symbolizing ConServe’s commitment to good corporate citizenship. This ongoing initiative is just one of the ways in which ConServe supports varied and diverse community agencies. To date the program has donated over $870,227 to local community organizations.

Visit us at www.conserve-arm.com

About the Rochester ICON Honors Award The award seeks to spotlight those individuals, over the age of 60, who have made a significant contribution within their industry and beyond. Specifically, presented by the Rochester Business Journal, the ICON Honors awards recognize Greater Rochester Area business leaders over the age of 60 for their notable success and demonstration of strong leadership both within and outside of their chosen field.

Learn more online at: www.rbj.net/events/icon-honors

If a debt collector’s letter includes an itemization of the balance, the debt collector better have procedures in place to ensure it adds up, according to the District of Connecticut in Garcia v. Law Offices of Howard Lee Schiff, No. 3:16-cv-791 (D. Conn. Dec. 14, 2018).

Factual and Procedural Background

The Law Offices of Howard Lee Schiff (Schiff) sent a collection letter to plaintiff on an account owned by Midland Funding, LLC. The letter indicated that the current balance is $565.46. However, the letter also stated that the balance at charge off was $663.94 and contained no explanation for the discrepancy between the two numbers. The debt itemization in the letter listed no interest or charges were accrued since charge off nor were any payments made. Evidence presented showed that Schiff’s programmer inadvertently failed to include payments that plaintiff made to Midland when putting together the automation of the letter content.

Plaintiff filed a Fair Debt Collection Practices Act (FDCPA) lawsuit against Schiff, alleging that the letter was misleading and confusing due to the two different listed balances. The parties filed cross motions for summary judgment.

The Decision

The court ultimately denied both motions for summary judgment. While Schiff presented evidence that plaintiff himself was not confused by the letter — in his deposition, he stated he understood that he owed the amount listed as the current balance — the court said that what matters is if the least sophisticated consumer would be confused by the letter, not plaintiff.

Applying the least sophisticated consumer standard, the court found that the letter would indeed be confusing. Listing two different balances without any other information explaining the discrepancy might confuse the least sophisticated consumer as to which balance is owed, impacting his or her decision on how to proceed with the account.

Editor’s Note: Oddly enough, the court did not take into consideration that the plaintiff knew — as would a least sophisticated consumer in this situation — that he had made a payment to the creditor that would explain the discrepancy.

After the court found that the letter violated the FDCPA, the court then turned to determine whether the bona fide error defense applied in this situation. Plaintiff conceded that the error was inadvertent, however the crux of plaintiff’s argument was that Schiff did not have reasonable policies and procedures in place to prevent the error. Plaintiff reasoned that since he received a letter with an error, then the procedures were insufficient.

The court found that the failure of the fail-safe in plaintiff’s situation does not necessarily preclude the bona fide error defense. However, the court pointed to testimony of a Schiff employee who stated that the error would not have been detected during the printing and mailing process. This, as well as the credibility of the Schiff employee, are up to interpretation and should be decided by a jury, not at the summary judgment phase, according to the decision.

For these reasons, the court denied the summary judgment motions.

insideARM Perspective

The more variable information required on a debt collection letter, the more likely that an error such as the one that occured here will occur. Certain state regulators, such as the New York Department of Financial Services, require that debt collectors itemize the balance in the initial letter mailed to consumers. To do this, debt collectors rely heavily on the information sent to them by the creditor. One minor oversight or minor error in code on behalf of the debt collector or creditor could lead this issue occuring.

While the bona fide error defense might defendant when all is said and done, it is usually reserved for a jury and, according to the court, is not appropriate for summary judgment. At the end of the day, this usually means the debt collector defendant will spend more on legal defense fees and costs — which it won’t recoup even if successful — to bring the case through trial.

This is especially important to keep in mind if the Bureau of Consumer Financial Protection’s (BCFP or Bureau) third party debt collection rules come out. The Bureau now has a new Director and the fate of the rules is yet to be determined. However, the outline of the proposed rules followed NYDFS’s example for debt itemization. If implemented, the requirement would be nation-wide rather than limited to certain jurisdictions, increasing the likelihood of an inadvertent errors simply by increasing the quantity of letters that will require itemization.

The court seems to suggest that a way to prevent these errors — and thus having sufficient processes to prevent it in order to invoke the bona fide error defense — would require some form of data validation to ensure the balance itemization adds up. Sounds like it’s time to take a look at those policies and procedures to make sure something like this is in there.

Let’s face it: Your company doesn’t value today’s technology.

And you don’t need me to prove this. Ask yourself one simple question, “What percentage of your payers self-pay online or through a mobile device?”

At a conference earlier this year, I sat at a table where one c-level exec was boasting that his company now collects 20% of their payments via an online payment page. The rest of those sitting at the table, myself included, were shocked by this proclamation. While the others seemed to be fantasizing about what their organization’s bottom line would look like if 20% of their payments were made online, sans-agent, I was sitting there reeling from a much different kind of shock: Fail.

A US study released in 2017, examining Q3 of 2016, found that 56% of all bills in the US are paid online. For Gen Xers and Millennials, as a standalone group, the rate is over 60%!

So who are you in this scenario? Are you the “boastful executive who unknowingly embarrassed himself in front the millennial” or are you closer to the 2016 US benchmark? Do you even know where you fall?  

There are a number of reasons why the accounts receivable industry is behind. A single article won’t give you all the answers and, frankly, my answers may not be the ones you’re ready to hear. However, you should pay attention because the ARM industry is looking for fresh perspective and ripe for disruption; new players will take the place of those unwilling to change.

It takes more than just knowing buzz words, like “AI” or “machine learning,” or the desire to send a text message to a consumer. It takes accepting that what you’re doing now is outdated, and understanding where you need to invest next, that will keep your business not just alive but thriving into the future.

Just like hotels never anticipated Airbnb; just like the taxi industry didn’t conceive of Uber; and just like the advertising industry was turned upside down by Google — if your company doesn’t start understanding and investing in transformative technology then it will be replaced by one that does.

In the following weeks and months, I will share a series of articles that will prove adopting new technology should be your #1 initiative –- even if that means making uncomfortable change.

ST. PAUL, Minn. — Minneapolis/St. Paul Business Journal has named IC System’s CFO and Executive Vice President Kurt Heinbigner an outstanding financial executive in the Twin Cities.

Mr. Heinbigner was awarded as part of the large private company CFO category alongside two other recipients selected by Minneapolis/St. Paul Business Journal. More than 20 honorees in all have been selected from companies ranging from small businesses to government institutions to nonprofits.

The award was started in 2007 to highlight exceptional financial leaders. “CFOs are a crucial part of a company’s leadership team, but they often labor in relative obscurity outside their offices,” wrote Mark Reilly, Managing Editor on the Business Journal’s announcement.

Those awarded were recognized at a luncheon held at the Hyatt Regency Minneapolis on November 15, 2018. The honorees were also featured in a special publication from Business Journal. “It was a great event,” remarked Chris Morris, IC System’s Vice President, Healthcare Services, who attended the luncheon to support his colleague. “It was awesome to see Kurt recognized for his incredible contributions to IC System over the years.” Mr. Heinbigner has worked for IC System in the collection industry since 2000.

“Over the years, Kurt has changed my perception of what a CFO does,” said Joe Erickson, IC System’s Director of Human Resources. “Originally, my perception was that a CFO is primarily a numbers person. Kurt has taught me otherwise. As a CFO, he’s considerate and compassionate, and he uses large doses of common sense. He’s a great tactician and teacher. This award was not given to Kurt because he’s simply a good numbers guy; it was given to him because of everything else he does for IC System.”  

In his current role, Mr. Heinbigner oversees the accounting, financial planning, analytics, human resources, internal audit, marketing, procurement, and property management departments. Prior to joining IC System, Mr. Heinbigner was employed in senior management roles with a large national healthcare provider and a national consumer products manufacturer.

“I am extremely honored to receive this distinction,” said Mr. Heinbigner of the award. “I am also grateful to the Erickson family, the owners and operators of IC System, for giving me the opportunity over these last 18 years to play such an integral role in developing the business and culture of IC System. This is an extremely proud moment.”

About IC System

IC System is one of the largest receivables management companies in the United States. Celebrating its 80th year, IC System is a family-owned, privately held accounts receivable management firm in its third generation of family ownership. IC System provides customized debt recovery solutions for healthcare, dental, small business, government, utilities, and telecommunications industries on a nationwide scale. Follow IC System on Twitter at @icsystem or on Linkedin.

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All right TCPAland, its official. The FCC has adopted and implemented its new rules regarding the creation of a *cough* reassigned number *cough* database. The rule is designed to cut down on wrong number robocalls and is available here. 

Here is TCPAland.com’s official top 10 take aways that you need to know about the database right now:

1. “Reassigned numbers database” is a huge misnomer and it will not be a failsafe solution for detecting wrong or recycled numbers—only the dates of disconnect. The database is extremely lean in terms of the information that will be collected from carriers. (Indeed, information security is a major priority in this order.) The database will not include subscriber information. Indeed it will not include any information other than the date of a “permanent disconnect”—defined as the date “the provider permanently has reversed its assignment of the number to the subscriber such that the number has been disassociated with the subscriber”— and the number itself. So it cannot be used as a device to determine whether the number actually belongs to the party you are trying to reach. If a customer provides a wrong number, therefore, or an agent fat fingers an entry there is nothing to be done. The database will not help you and the safeharbor (see below) will not protect you. (From this day forward the database will be known as the “Permanent Disconnect Database” or “PDD” on TCPAland.com. Feel free to adopt our lingo alongside Bad Reyes and “opt-our evaders.”)

2. The database will require significant leg work by callers in order to use it. Again, the data included in the database is extremely lean—just the number and the date of a permanent disconnect. In order to make use of the database, therefore, callers must supply to the Administrator the phone number being queried and a date. The date to be supplied by the caller is “either the date they contacted the customer or the date on which the caller could be confident (what does that mean?) that the consumer could still be reached at that number.” That means callers must maintain comprehensive lists of numbers with a rolling “last good” date for each number for use in a batch process to the database administrator. Businesses must develop processes that allow them to operationalize the “yes”, “no”, or “no data” record they receive from the Administrator. (Here “yes” is bad—it means that a number was permanent disconnected since the “last good” date.) Businesses must also develop risk assessments as to what “confidence” means in this context so they can build a “last good” database consistent with their risk appetites.

3. Don’t keep dates of your last contact with consumers? You better start. The FCC does not parse words here: “All legitimate callers should have the telephone number associated with the consumer the y are attempting to reach and either the date they contacted that consumer or the date on which the caller could be confident that the consumer could still be reached at that number.” Yeah. So, probably better to be a “legitimate” caller.

4. The database will be updated once a month and numbers cannot be reassigned but every 45 days. The database will be updated on the 15^th of each month. The FCC has also required carriers to give at least 45 days after permanent disconnect to reassign the number. Assuming a caller scrubs on the 16^th of the month and receive a “no”, the number could not possibly be reassigned until at least the 45^th day after that scrub, assuming all goes according to plan. That should allow callers to avoid calling reassigned numbers with a month scrub but I feel like there’s a logic gap in here some place to consult an engineer before building your scrub process.

5. A very limited safeharbor is provided. As I famously wrote a few days ago the original proposed Report and Order did not contain a safeharbor. But then the Press Release announcing the database dropped and I threw a party for Commissioner O’Reilly. But now that I’ve read the safeharbor I want my balloons and streamers back. The final Report and Order does provide a safeharbor but it is very limited. Here’s what it does: if the caller can prove it had express consent to call a number and received a “no” after supplying “either the date they contacted the customer or the date on which the caller could be confident that the consumer could still be reached at that number” then the safeharbor shields the caller from liability if the database returned an inaccurate result. There is no safeharbor, however, if a caller does not use the most recent update available. So the caller has to be scrubbing every 30 days in order to feel confident that the safeharbor will apply. The FCC also expressly refuses to extend the safeharbor to individuals that are currently using vendor solutions tracking recycled numbers or subscriber databases. So use the FCC’s official database or no safeharbor for you. Also I would urge you to consult an attorney regarding the actual language of the safeharbor before relying on it. There’s a trap there but I cannot share it publicly. (Believe me, you don’t want me to share it publicly.)

6. The 15^th of the month now has new importance for call center personnel: The Order requires carriers to supply data—again, just phone numbers and dates of permanent disconnects— to the Administrator once a month and on a specific date—the 15^th of each month. Pretty obviously callers will want to set their scrubs to run on either the 15^th or 16^thof each month to get the most accurate information possible. Nonetheless, those running scrubs later in the month should be fine—again numbers can only be reassigned every 45 days—but the early bird scrubs the worm. You know what I mean.

7. The database is designed to supplement and not supplant existing commercial solutions. Again, because the database is so limited it cannot—for instance—tell you whether or not a number has been reassigned or was a “wrong” number at the time it was supplied or input by an agent. So commercial databases purporting to validate subscribership may remain a useful part of your TCPA compliance regime.

8. This thing will be cheap to use. The FCC estimates and expects that the charge will be “under one cent.” See par. 72. It also predicts nearly 2.5 billion queries per year. The Administrator will also be required to have a web portal available for single queries and also a batch process available for large call center operators.

9. The Order really explains the breadth of the recycled number problem today. As the FCC explains matters: i) 37MM numbers are available for reassignment each year; ii) there is nocurrent minimum as to how long a carrier has to hold a number before reassigning it; iii) one commenter stated that numbers can be reassigned within two days of a disconnect (meaning that there is no real chance of preventing wrong number calls to recycled numbers in the current environment). As the FCC puts it: “a number used by one consumer today can be reassigned to another consumer almost immediately.” That’s pretty scary and weird if you think about it.

10. It will be at least a year before the database is rolled out—but there’s no deadline. Although most carriers are immediately required to begin tracking and maintaining records regarding “permanent disconnects” an Administrator has not yet been chosen for the project of overseeing the database. The FCC’s Order states that it expects to start the bidding process “within the next twelve months.” Eesh. It could be a while folks. Indeed as Commissioner Rosenworcel wrote in her separate statement: “There is no deadline for its implementation, no date by which we can ensure its operation, and no time by which we can ensure consumers relief.” So, there you go.

Now I’m off to record our final Ramble podcast of the year! It’ll drop next Tuesday and yes, of course I will be breaking down the permanent disconnect database on the show.

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Editor’s note: This article is provided through a partnership between insideARM and Womble Bond Dickinson. WBD powers our TCPA case law chart and provides a steady stream of their timely, insightful and entertaining take on this ever-evolving, never-a-dull-moment topic. WBD – and all insideARM articles – are protected by copyright. All rights are reserved.

COLUMBUS, S.C. and WESTMONT, Ill. — AMCOL Systems, Inc., a nationally recognized leader in patient experience and revenue cycle optimization services, and RevMD Partners, LLC., an industry leading technology enabled revenue cycle services company, have entered into a strategic partnership for joint product development and marketing initiatives which is effective immediately. The partnership allows both companies to broaden their product offerings on the near term while combining expertise to develop further automation, technology and service solutions for healthcare providers over the intermediate and long term. Both companies have decades of experience in the healthcare revenue cycle space exclusively, specializing in patient financial clearance, insurance resolution, self-pay early out services, and bad debt collections.

“This partnership is especially exciting as both companies have enjoyed great success since their inceptions and are 100% dedicated to the long term success of healthcare providers. Together, we have a deep understanding of the industry and are uniquely suited to produce innovative solutions to efficiently drive improved revenue cycle performance for healthcare systems,” says Chip Hellmann, President and CEO of AMCOL Systems.

Tim McCarthy, Managing Partner at RevMD agrees. “We are extremely excited about our partnership with AMCOL. Together we will now be able to roll out some unique technology-driven solutions that will not only help our clients drive out unnecessary manual costs, but also dramatically accelerate the performance of their receivables. This partnership allows us to get these solutions to the market sooner so our clients can capitalize on the improved results immediately. We are going to introduce resolution alternatives no other vendor has offered.”

About AMCOL Systems, Inc.

Founded in 1976, AMCOL Systems is a distinguished provider of Self-Pay Collection, Bad Debt Recovery, and Insurance Claims Resolution services exclusively for the Healthcare Industry. AMCOL’s mission is to be trusted advisors who deliver tailored, patient-centered financial solutions to benefit their partners and their communities. For additional information about the company, contact Sandi Owen at 803.227.3191.

About RevMD Partners, LLC.

RevMD Partners, a leader in healthcare revenue cycle services, utilizes best-of-practice workflows and state-of-the-art supporting technology to drive increased recoveries for their provider clients. Guided by this core set of values: respect, integrity, accountability, and commitment; results are achieved through a genuine desire to employ these core values each day in an effort to make a difference in the lives of those with whom they work.  For additional information about the company, contact Nick DiGiovanni Jr. at 630.882.3690.

COPLEY, Ohio — DebtNext Software, a hosted inventory management and operations software provider, welcomes Louis Thomas as its new Sales Executive.  In his new role, Louis will manage the sales efforts as the Company expands into new industry verticals and will join DebtNext in its Northeast Ohio headquarters located in Copley, Ohio.

Louis brings over 10 years of sales and business strategy experience within the High-Tech Industry. For the past decade, Louis has worked in various sales and sales management roles and was most recently responsible for business development at a boutique engineering firm. Due to his unique experience, Louis has developed innovative strategies that expand market share an increase revenue. Louis has been honored with awards numerous times for his consistent high performance, dedication to clients and outstanding achievements. His education background includes a Bachelor of Business Administration with a specialization in Marketing from Cleveland State University.

“We’re very excited to have Louis joining our team as a leader in helping us continue to grow our client base and strengthen our product offering”, said Paul Goske, President of DebtNext Software.  “Louis brings a great deal of experience in articulating software value propositions to his clients and we’re looking forward to him continuing in that capacity as we enter into new markets”.

About DebtNext Software

DebtNext Software has been delivering robust solutions for their clients’ recovery management needs since its founding in 2003. Their industry leading Platform is currently used by some of the nation’s largest utility, telecommunications and financial services companies to help manage and optimize the placement of their accounts receivables with third party collection vendors. DebtNext Software is headquartered in Copley, Ohio. For more information, visit www.debtnext.com, or email sales@debtnext.com.

On Friday, President Donald Trump announced that Mick Mulvaney will serve as the White House Acting Chief of Staff, replacing John Kelly. This announcement came within a week of Mulvaney stepping away from his role as Acting Director of the Bureau of Consumer Financial Protection (BCFP or Bureau) after the Bureau’s new permanent director was confirmed.

Mulvaney served as the Bureau’s Acting Director for a little over a year following the resignation of Former Director Richard Cordray in November 2017. Cordray ran for governor of Ohio following his departure, but was not elected. On December 6, 2018, the Senate confirmed Kathy Kraninger as the new Director of the Bureau and was sworn into the role on the following Monday.

insideARM Perspective

After stepping into the Acting Director role at the BCFP, Mulvaney wasted no time and immediately initiated a comprehensive review of the Bureau’s functions. Over the past year, the Bureau issued several Requests for Information on various topics such as its investigative and supervision processes, the controversial complaints portal, and the rulemaking process. While the industry waits to see what Director Kraninger will do with the information gathered, Mulvaney will watch from afar as he steps into his new role at the White House.