Archives for July 2020

Last week, the Consumer Financial Protection Bureau (CFPB) released its July 2020 Complaint Bulletin, which updated data on COVID-19-related consumer complaints. While complaints that meet the CFPB’s criteria for being COVID-related—using coronavirus keywords—seem to only account for 4% of the total complaints received in 2020, this might not tell the whole story.

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COVID-19-Related Complaints

The updated consumer complaints data says the CFPB received 8,357 complaints through its database between January 1 and May 31 that mention “coronavirus keywords.” 

Complaints related to mortgages were most prominent. Mortgage complaints made up 19% of the coronavirus keyword complaints. 55% of those complaints revolved around consumers struggling to pay their mortgages. 

Credit reporting was also a big ticket item, making up 18% of the coronavirus keyword complaints. The main issue, accounting for 55% of the COVID credit reporting complaints, had to do with incorrect information on credit reports. 

Debt collection complaints were in 4th place of COVID-related complaints, but 2nd place in overall 2020 complaints. The biggest issue for collections-related complaints was attempts to collect a debt not owed.

Overall Complaints 

The Bulletin shows that the average number of complaints received since the President declared a national emergency has skyrocketed above the baseline. The graph below shows the difference in weekly complaint volume of all complaints received compared to the baseline, which represents the average complaint volume prior to the national emergency declaration.

This indicates that the volume of complaints has increased significantly post-COVID. Yet, COVID-related complaints account for only 4% of the total complaints received this year. This seems a little odd. One possible explanation for this discrepancy might be that consumers had COVID-related complaints that simply did not include a coronavirus keyword, as defined by the CFPB. 

While the average volume of complaints across all products increased significantly, debt collection complaint volumes remained generally steady pre- and post-COVID. According to the chart below (highlight added for ease of reference), complaints that saw the largest increase include prepaid card, money transfer or virtual currency, credit reporting, and credit cards. 

The Federal Communications Commission (FCC) has now approved “two safe harbors from liability for the unintended or inadvertent blocking of wanted calls, thus eliminating a concern that kept some companies from implementing robust robocall blocking efforts.” The two safe harbors “are meant to provide further assurance to phone companies and allow them to strengthen their efforts in the battle against illegal and unwanted robocalls.” The FCC’s decision further implements provisions of the Pallone-Thune TRACED Act which became law last December.

The first safe harbor will protect phone companies that “use reasonable analytics, including caller ID authentication information, to identify and block illegal or unwanted calls from liability.” The second safe harbor “protects providers that block call traffic from bad actor upstream voice service providers that pass illegal or unwanted calls along to other providers, when those upstream providers have been notified but fail to take action to stop these calls.”

TCPAWorld previously analyzed this safe harbor proposal when it originally was released.

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The decision – approved unanimously by the five FCC commissioners – also seeks comment on further rule changes to “protect consumers from robocalls and better inform them about provider blocking efforts.” A Fourth Further Notice of Proposed Rulemaking included in the decision seeks comment on (a) “whether to obligate phone companies to better police their networks against illegal calls, and … require them to provide information about blocked calls to consumers for free” and (b) “notification and effective redress mechanisms for callers when their calls are blocked, and on whether measures are necessary to address the mislabeling of calls.”

TCPAWorld will be tracking the evolution of the notification and redress mechanism for callers who assert that their legitimate calls are being improperly blocked.

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.

ATLANTA, Ga. — Today, Capio announced a new strategic partnership with Seattle-based Attunely to further support its ongoing commitment to expand consumer offerings and enhance the overall patient experience. 

Under this new partnership, the companies will actively collaborate to leverage Attunely’s machine learning capabilities to better understand consumer needs and increase successful outcomes. In addition, both organizations believe the partnership will provide ongoing opportunities to identify and improve business efficiencies that better serve Capio’s provider clients. 

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“The global pandemic is changing the way healthcare is managed and delivered to patients. These unprecedented challenges, combined with the resulting economic impacts, have negatively impacted many of our consumers. Capio maintains our relentless commitment to providing the individual attention and offerings needed to successfully resolve outstanding healthcare accounts. We believe that Attunely and their leading machine learning technology, coordinated with the efforts of our internal teams, will be instrumental to achieving these successes,” said Mark Detrick, co-founder and CEO of Capio. 

“Attunely has deep experience building powerful optimization technologies tailored to our customers’ consumer strategies,” notes Scott Ferris, founder and CEO of Attunely. “Capio has been the leading purchaser of healthcare receivables for the past decade, and we are thrilled to partner with them on this important initiative.” 

About Capio

Capio assists healthcare providers and physician organizations increase cash flow, while also lowering their bad debt expense. To date, Capio has acquired and provided consumer services to over $35B in patient accounts receivable via partnerships with more than 525 provider clients across the United States. To learn more about Capio, please visit http://www.capiopfw.com.

 About Attunely Inc.

Attunely is a proven, compliant, and trustworthy machine learning platform that makes the recovery of receivables easy, seamless, and profitable. To learn more about Attunely, please visit http://www.attunely.com

There have been several court decisions to come down the pipeline regarding legal-related language and disclosures in collection letters. For example, the Southern District of New York recently dismissed a complaint where the crux was letter language that stated, “[Creditor] will send your account to an attorney for possible legal action” if a payment arrangement is not made. Even the Northern District of Illinois (N.D. Ill.) granted summary judgment for a debt collector whose letter stated “If the Account goes to an attorney, our flexible options may no longer be available.” However, it sounds like early dismissal of such cases—as we saw in New York—might not be as easy in N.D. Ill. 

Editor’s Note: Want a full rundown of how the courts ruled on the issue of threats of litigation, with concise summaries of the decisions? Check out the iA Case Law Tracker. 

What happened?

In Soyinka v. Franklin Collection Serv. (N.D. Ill. Jul. 15, 2020), a collection agency sent a dunning letter to a consumer that stated, “If you are not paying this account, contact your attorney regarding our potential remedies, and your defenses, or call (###) ###-####.”

The letter doesn’t even mention litigation, and debt collectors are allowed to inform consumers of potential remedies, so any Fair Debt Collection Practices Act (FDCPA) claim alleging a false threat of litigation should be dismissed right off the bat, right? 

Wrong, according to the judge in Soyinka.

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The Court’s Decision

One of the main reasons the court denied the collection agency’s motion to dismiss is that in this jurisdiction, the question of whether a statement is false, deceptive, or misleading is a question of fact—meaning, a question for the jury. A motion to dismiss occurs far too early in the litigation process to warrant this treatment. (However, as mentioned above, the cases can be disposed of at summary judgment in favor of debt collectors.)

Despite that, the court delved into the facts. It found that “if only” the letter said “pay, contact your attorney, or call,” then there would be no problem. However, by including a settlement offer to “resolve” the account immediately before telling a consumer to contact their attorney about remedies and defenses, the letter may very well have crossed the line in this judge’s eyes:

The letter starts by offering a “settlement” to “resolve this matter.” Immediately after making that offer, the letter advises Soyinka, if she is not going to pay, to “contact your attorney regarding our potential remedies, and your defenses.” In combination, these sentences could communicate to an unsophisticated consumer the message that if she does not pay, then she will be sued. To begin, “settlement” is broadly understood by the public as a legal agreement used to avoid litigation. And similarly, even an unsophisticated consumer knows that “remedies,” “defenses,” and “attorney” are all terms used in litigation, and encountering them immediately after reading about a “settlement” offer could lead the consumer to believe that a lawsuit is coming—time to lawyer up. It is true that these terms could also be used to describe negotiation without resort to a lawsuit, but an unsophisticated consumer might not be able to figure that out. In cases of ambiguity—such as here—the case law says that the case must move on.

(Internal citations omitted.)

The court did note that two previous cases in the Seventh Circuit against this particular debt collector found nothing wrong with similar language, but pointed out that those letters did not use terms like “offer” and “settle.”

The court also found that a back-page disclaimer that an attorney has not yet reviewed the account does not change the fate of this motion to dismiss.

insideARM Perspective

One interesting factor that this court decision misses the mark on is the requirement that the threat be imminent for the claim to be viable under the FDCPA. Notably, the collection letter did not include a due date for the settlement offer, which means there was no hard deadline in the letter. And the legal language itself does not indicate any scintilla of imminence. The only potential time frame in the letter would be the 30-day window for the consumer to take advantage of his or her validation rights—but even the typical validation notice disclosure does not contain a reference to litigation. Even the consumer’s allegations, according to the court’s dicta, reference that legal action “is a possibility” with no reference to time frame or imminence. 

In fact, eight different judges in N.D. Ill. disposed of claims alleging threats of litigation exactly for this reason—lack of imminence—at different stages of litigation (motion to dismiss, motion for judgment on the pleads, and summary judgment). The iA Case Law Tracker shows 8 different court decisions that match these parameters, all of which side with the debt collector on the threat of litigation issue.

This decision seems to be an outlier, and that is unfortunate.

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ARLINGTON, Va. —  Convoke, a leader in SaaS solutions for the debt collection market, today announced the most recent software update to its debt collections compliance and management hub. Each year, Convoke develops and releases several updates to its platform to support its clients’ evolving needs.

Convoke’s platform is used by large credit issuers in the United States to monitor the activities of their third party collection partners to ensure fair treatment of consumers throughout the collection process, thereby protecting both brand and reputation.  As a result of financial hardships faced by consumers during the COVID-19 pandemic, coupled with the significant reduction of travel during the pandemic, the Convoke platform has become an even more vital tool to provide credit issuers insight into the activities of their third party collectors.  The level of oversight made possible by the Convoke platform can be achieved in an environment where travel is heavily curtailed.  In addition to protecting brand and reputation and allowing oversight of the treatment of consumers without the need to travel, the Convoke platform contributes to the maximization of recoveries.

“All of the changes introduced in this new software release are the direct result of feedback from Convoke’s customers about the problems they encounter with the collection and vendor oversight process,” said David Pauken, CEO of Convoke.  “We value our customers and listen attentively in order to engineer solutions that help them to do their work most completely and productively.  We are pleased to continue to partner so closely with all of our customers to provide solutions to their problems.”

About Convoke

Convoke is a leader in SaaS solutions for the debt collection market.  It enables credit issuers to manage third party debt collections, providing unsurpassed visibility into collection actions.  Convoke’s online platform is a central, validated and persistent hub that records, organizes and stores information and activities, facilitates, tracks and automates interaction with third parties, and provides powerful auditing, management and reporting tools.  Convoke is headquartered in Arlington, VA.  For more information on Convoke, please visit www.convokesystems.com.

MOUNT LAUREL, N.J. — Ceteris is pleased to welcome Chief Sales Officer Tim Smith to the company. With more than 25 years of broad-based experience in the Business Process Outsourcing space across business development, client engagement and operational strategy, Ceteris is confident that Tim’s expertise and successes will make an immediate impact. Tim’s high energy, positive attitude, and strategic vision combined with his diverse background, and record of successes in multiple markets, fits perfectly with the Ceteris vision and values. 

Jonathan Pike, CEO of Ceteris, said, “We are thrilled to welcome Tim to Ceteris as our new Chief Sales Officer and member of our Executive Team. Tim’s wealth of experience in all facets of business development and operational strategies is a key addition to assisting our team obtain aggressive revenue goals and initiatives. Ceteris remains committed to providing end-to-end industry leading account receivable management solutions and assisting our clients manage their customers in a positive, empathic manner especially during these unprecedent times; Tim’s addition demonstrates this commitment.” 

Throughout Tim’s career, he has also overseen and executed on compliance/regulatory assessments, mergers and acquisitions, joint venture/strategic partnership arrangements, and operational assessments. He holds a bachelor’s degree in SUNY College at Buffalo, Executive MBAs from Michigan State in Process Re-Engineering and University of Queensland in Organizational Leadership. 

About Ceteris Portfolio Services, LLC

Ceteris Portfolio Services (CPS) is a premiere nationwide ARM firm providing end-to-end accounts receivable management solutions to assist clients in managing their debt. CPS currently services consumer and commercial businesses engaged in heavily regulated, high-volume industries including banking, automotive finance, credit card, equipment leasing, student lending, medical services, telecommunications, utilities, retail, and publications. CPS partners with clients by creating unique solutions to significantly reduce their operating costs enabling them to focus on their core line of business while improving their revenue and profitability. By offering a variety of operational and financial solutions based on the asset class and/or industry, we can create predictable cash flows – even with unpredictable assets. 

CPS is committed to providing a positive customer experience to our clients and their customers that is unmatched in the industry. We maintain one of the lowest complaint rates in the industry through the combined implementation of industry-leading technology services and investments in compliance, world-class talent and ongoing training lead by a senior leadership team widely known as subject matter experts in the industry. For more information please visit www.ceterisholdco.com/CPS.

Editor’s Note: This article was originally published on the Maurice Wutscher blog and is republished here with permission.

Joining similar rulings by the Eighth and Tenth Circuits, the U.S. Court of Appeals for the Fourth Circuit recently held that each violation of the FDCPA gives rise to a separate claim governed by its own statute of limitations period.

A copy of the opinion in Bender v. Elmore & Throop, P.C. is available at:  Link to Opinion.

On April 16, 2016, the homeowner plaintiffs received a notice from a law firm retained by their homeowners association (HOA) stating the homeowners failed to pay $77.09 in HOA assessments and a demand for $1,000 to satisfy both the HOA assessments and the costs and attorneys’ fees.

The homeowners disputed the debt and mailed a letter to the law firm with copies of cancelled checks. The law firm acknowledged that the disputed payments had been received, but asserted that the homeowners still owed the costs and attorneys’ fees.

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The homeowners and law firm exchanged several letters with the homeowners denying making any late payments and the law firm insisting that late fees, costs, interest, and attorneys’ fees were owed.

On May 18, 2016, following another demand for payment, the homeowners delivered a letter to the law firm “requesting that [it] stop contacting us about this claim” and stating that the [homeowners] would consider “any further attempt to collect a debt against us or record a lien on our property [as] harassment[.]”

In January 2017, the homeowner hand-delivered a payment at the annual HOA meeting and was told to leave. The homeowner later received a notice that he had been banned from the HOA’s premises for one year.

In February 2017, the homeowners received another letter from the law firm acknowledging receipt of the January 2017 payment, but noted as outstanding the accumulated fees and costs associated with the original disputed payment from 2016.

On March 10, 2017, the homeowners responded to the February letter, writing that “in our correspondence to you on this matter, we had requested that you stop contacting us about that claim . . . As both my wife and I dispute the debt referenced in your most recent letter, I am now requesting once again that you stop all communications with my wife and myself concerning this debt.” The homeowners received additional correspondence from the law firm on March 14, 2017, including an updated ledger of the homeowners’ account showing that a fee had been added for preparation of the February letter.

In January 2018, the homeowners requested to attend the annual meeting and was told by the law firm that the homeowner would not be allowed to attend, and that “this whole thing would not have happened if you would just pay your bills.”

On Feb. 6, 2018, the homeowners received an updated ledger from the law firm and although this correspondence purported to provide the homeowners with “verification of your account as you requested,” the homeowners deny having made any such request for verification.

On April 5, 2018, the homeowners filed a complaint against the law firm brought under the federal Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.  In their complaint, the homeowners alleged that the law firm violated various provisions of the FDCPA by engaging in unfair debt collection practices and by improperly communicating with the homeowners after they had disputed the debt and had made a written request that the law firm cease further communications. The law firm responded by seeking dismissal of the complaint as untimely or, in the alternative, for summary judgment.

The trial court granted the law firm’s motion to dismiss the complaint based on the statute of limitations holding that the entire complaint was time-barred because the more recent violations that the homeowners alleged were of the “same type” as other violations that occurred outside the one-year limitations period.

The homeowners appealed.

The sole question on appeal was whether the trial court erred in concluding that all the homeowners’ claims were barred by the FDCPA’s statute of limitations.

The homeowners argued that the trial court erred in dismissing all their claims as time-barred because two of the alleged violations occurred less than one year from the date they filed suit. According to the homeowners, under the language of 15 U.S.C. § 1692k(d), a new statute of limitations arose with each “violation” of the FDCPA.

In response, the law firm argued that the first alleged violation of the FDCPA occurred outside the limitations period and all later communications by the law firm arose from its attempt to collect the same debt.

The Fourth Circuit first acknowledged that under the FDCPA, claims must be brought “within one year from the date on which the violation occurs.” 15 U.S.C. § 1692k(d). Moreover, the Court noted, nothing in the FDCPA suggests that “similar” violations should be grouped together and treated as a single claim for purposes of the FDCPA’s statute of limitations. To the contrary, the Court has long held that a “separate violation” of the FDCPA occurs “every time” an improper communication, threat, or misrepresentation is made. United States v. Nat’l Fin. Servs., Inc., 98 F.3d 131, 141 (4th Cir. 1996). Accordingly, the Court concluded that Section 1692k(d) establishes a separate one-year limitations period for each violation of the FDCPA.

In coming to its ruling, the Fourth Circuit noted this interpretation avoids creating a safe harbor for unlawful debt collection activity where no matter how frequent or abusive such collection efforts became, the debtor would be left entirely without a remedy simply because the debtor did not timely pursue the first violation.

Finally, the Court observed that two other federal appellate courts have also concluded that the FDCPA’s limitations period runs anew from the date of each violation. See Demarais v. Gurstel Chargo, P.A., 869 F.3d 685, 694 (8th Cir. 2017); Llewellyn v. Allstate Home Loans, Inc., 711 F.3d 1173, 1188 (10th Cir. 2013). As these courts have recognized, it simply “does not matter that the debt collector’s violation restates earlier assertions — if the plaintiff sues within one year of the violation, [the suit] is not barred by § 1692k(d).” Demarais, 869 F.3d at 694; see also Llewellyn, 711 F.3d at 1188.

Accordingly, the Fourth Circuit vacated the trial court’s judgment and remanded the case for further proceedings.

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Let’s first tally where we are. 

Last Friday afternoon, The U.S. Department of Education’s Office of Federal Student Aid (FSA) canceled a second of three solicitations that were part of its Next Generation Processing and Servicing Environment (NextGen) student loan servicing system overhaul. This cancelation is for Solicitation Number 91003119R0005, the Enhanced Processing Solution.

Back in early April, FSA canceled Solicitation Number 91003119R0007, the Optimal Processing Solution (OPS).

What’s left? Solicitation Number 91003119R0008, the Business Process Operations Solution. On June 24th FSA announced it had signed contracts with five companies through the NextGen Business Process Operations solicitation to correspond with customers and partners via phone, chat, social media, postal mail, and email and to support the back-office processing associated with those contacts. The five companies are: Edfinancial Services LLC, F.H. Cann & Associates LLC, MAXIMUS Federal Services Inc., Missouri Higher Education Loan Authority (MOHELA), and Texas Guaranteed Student Loan Corporation (Trellis Company). 

A little context, please.

This January 2019 article provides details on the latest NextGen plan, with the three solicitations (there was actually an earlier plan which was canceled – you can read about that here and here). Here’s an overview:

RFP R00005 – Enhanced Servicing Solution (EPS) – This was the immediate term solution used by ED to justify its cancellation of the unrestricted PCA Solicitation. Proposals were due by February 25, 2019.  This is the solicitation that was canceled last Friday. 

RFP R00008 – Business Process Operations Solution (BPO) – FSA said that after the Enhanced Servicing Solution has been awarded, a timeline would be set for this Solicitation – there was no initial due date, except that bidders were required to complete a Past Performance Reference Questionnaire by March 1, 2019. This is the solicitation for which the five companies mentioned above received contracts in late June.

RFP R00007 – Optimal Processing Solution (OPS) – This was to be the long-term system solution that carried a two-year implementation period. The due date for bids was March 25, 2019. This is the solicitation that was canceled in April.

When the Optimal Processing Solution was withdrawn in April 2020, ED said it was necessary to enable the Department to rescope the solicitation’s requirements in order to allow it to “bring onboard technology that will appropriately implement the provisions in the Fostering Undergraduate by Unlocking Resources for Education Act (FUTURE Act) (H.R. 5363). The FUTURE Act will have a significant impact on federal student aid business processes through new data sharing agreements, technologies, and protocols with the Internal Revenue Service.”

What does FSA say about their cancellation of the Enhanced Processing Solution?

An FSA representative contacted insideARM last weekend, just after it posted the official cancellation, to say:

“After more than 12 weeks of good faith negotiations, the Department is unable to reach an agreement with the vendor selected following the rigorous contracting process to award a contract for the EPS solicitation. The Department continues its commitment to delivering on the vision and goals of Next Gen FSA. FSA has determined that a different acquisition strategy will be more effective in obtaining the desired servicing system solution. Accordingly, late this afternoon, we canceled the existing solicitation, #91003119R005. We’ll be introducing a new solicitation to continue the Next Gen strategy in the coming months.”

What else is going on?

As it relates to solicitation R0005, the Enhanced Processing Solution (EPS), insideARM has learned that the selected vendor was PHEAA (Pennsylvania Higher Ed). They have a loan servicing subsidiary that is a legacy loan servicer.

Current legacy contracts for loan servicing are extended to December 2021 while FSA revisits the drawing board.

EPS stated that the awarded vendor had 24 months to convert all the loans from the legacy loan servicing vendors to the new EPS system. If FSA ran a new competition for loan servicing in October, administered the submission, and made an uncontested award to a new servicing vendor, would the loan conversions from the legacy vendors be done before the legacy contracts expired?

As it relates to solicitation R0008, the Business Process Operations Solution, sources tell insideARM that more than the five awards were initially made. But the way this solicitation was structured, companies only learned the pricing once they received an award. Several turned down the contract, saying that the pricing was unrealistic for the services required. 

Navient, one of the original awardees, filed a protest on June 29, 2020, over the way this process was handled. Here is a summary of their claims:

• FSA failed to amend the RFP after making material changes to the terms and conditions;
• FSA proffered a contract to Navient with terms that materially differed from the RFP terms; 
• FSA unreasonably included in the proffered contract arbitrary and unconscionable terms that unduly restrict competition, exceed FSA’s minimum needs, and failed to provide Navient with a reasonable time to respond; and
• FSA awarded contracts with the intent to make material changes after award, failed to conduct a reasonable price realism analysis for the awardees (or arbitrarily waived price realism for the awardees ), and otherwise treated offerers in a disparate manner. 

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What does all of this mean to borrowers?

We don’t know for sure. FSA’s goal is a good one: to provide a more efficient and effective customer experience to students, parents, and borrowers. Their stated intention is to require vendors to provide contact center operations and back-office processing activities encompassing the full student aid lifecycle, from disbursement to payoff, in a manner consistent with leading financial services providers and other industry leaders. What’s being questioned is the execution. 

Given the little we know about pricing for the BPO contract from the Navient complaint, one wonders whether borrower servicing will be impacted. In other words, will the awardees be forced to modify services in order to not lose money on the contract?

Another potential issue is the loss of institutional knowledge held by the major servicers that did not end up with a contract. There are more than 50 repayment programs out there. And they are quite complicated. Even when Congress discontinues a program, borrowers already in the program still continue with it. So, servicers must continue to honor those programs, plus learn to handle the new ones. This is not a trivial consideration. Nothing about federal student loan servicing is simple and straightforward.

So, what does all of this mean to federal student loan debt collectors?

Well, following the long saga of litigation over the large Private Collection Agency (PCA) solicitation that concluded almost exactly one year ago with FSA coming out the winner, the small PCAs were left holding the whole bag. Many wondered whether NextGen would be the death knell of PCAs altogether, as FSA implemented its “enhanced servicing” plan primarily using loan servicers (like Navient) rather than PCAs.

The small PCAs received a 5-year contract extension in September 2019, so that ends in 2024. I suspect FSA will issue a new solicitation for small PCAs in 2022 or 2023 so that they are covered going forward. 

Given the numerous restarts of NextGen, it’s unclear what the need will or won’t be by 2024. Under the best of circumstances, a systems project of this magnitude takes several years to complete. FSA had expected to be up and running in just two.

Also, if the November election brings significant change to Congress and/or the Administration, this could also bring a new approach to federal student loan servicing. For one, we know that Democrats have an interest in at least some form of student debt forgiveness. 

Another also is that a “CARES Act 2” may potentially include an extension on federal student loan payment forbearance (the current forbearance expires September 30, 2020). 

The CARES Act also prohibited Private Collection Agencies from sending collection letters or making outbound collection calls to defaulted federal student loan borrowers, which means PCAs may not reach out to borrowers to inform them of programs (like Income-Driven Repayment) and opportunities (like the ability to have $0 payments through September 30th count towards fulfilling repayment program requirements).  The only way a borrower could learn about them is if they happen to read the FAQs on the Federal Student Aid website.

So, many of these small agencies are hanging on by a thread. They aren’t receiving new accounts. They’ve stopped nearly all outbound contact. They likely won’t receive new accounts for a while because of the forbearance on accounts not in default. Yet they are expected to remain ready to go indefinitely. These are not simple call center jobs to fill. They are complex roles requiring extensive training (remember the 50 repayment programs?). You can’t just turn the spigot on and off and expect the water to be clean and the flow to be strong. 

WILMINGTON, Del. — Phillips & Cohen Associates, Ltd. (PCA) is excited to announce a critical enhancement to its Debt Settlement Solutions Platform with Opportunity Scrub℠.  The newly branded, no-cost feature helps creditors and debt buyers identify, evaluate and optimize debt settlement account value within their portfolios. Known globally for its award-winning decedent debt and estate servicing, Phillips & Cohen Associates has been a leader in the US debt settlement arena for over 20 years.  In line with its ongoing commitment to innovate in this growing industry segment, Phillips & Cohen Associates has created one of the nation’s largest repositories for identifying consumers engaged in a debt settlement program.  Opportunity Scrub℠ will quickly and securely enable clients to scrub up to 50 million of their accounts at no cost to identify the true impact of the debt settlement segment of their portfolios. 

Adam Cohen, Co-Chairman/CEO said, “Unlike basic scrubs or portals that simply highlight debt settlement accounts, Opportunity Scrub℠ is just the beginning of the process.  Once identified, we will provide customized options for the best path to recovery, including indicative debt sale pricing from our Invenio Financial unit as well as multiple recovery strategy options from the PCA agency team.  The analysis is comprehensive, customizable and cost-free.”     

“Utilizing Opportunity Scrub℠ is an incredible gateway to analysis from our 23-year history in this industry segment”, said Matthew Phillips, Co-Chairman/CEO.  He added “our pricing models are top of the market and our agency strategies for pre and post charge-off are the result of many years competing and leading in this space.”

To take advantage of the new Phillips & Cohen Associates Opportunity Scrub℠ please contact either: 

• Phillips & Cohen Associates: Morgan Leija | Mleija@phillips-cohen.com |302-382-5208
• Invenio Financial: Jenna Wilmes | Jwilmes@inveniofinancial.com | 218-522-0212

About Phillips & Cohen Associates, Ltd. 

Phillips & Cohen Associates, Ltd. is a specialty receivable management company providing customized services to creditors in a variety of unique market segments. Phillips & Cohen Associates, Ltd is domestically headquartered in Wilmington, DE, with additional offices in Colorado and Florida as well as international offices in the UK, Canada, Spain, Germany and Australia. For more information about Phillips & Cohen Associates visit www.phillips-cohen.com. PCA provides Equal Employment Opportunity for all individuals regardless of race, color, religion, gender, age, national origin, disability, marital status, sexual orientation, veteran status, genetic information and any other basis protected by federal, state or local laws.

About Invenio Financial, LLC

Invenio Financial, the debt buying partner of Phillips & Cohen Associates Ltd., has built an award-winning reputation in the accounts receivable management industry through its proven, compassionate recovery processes since 2004. Its headquarters located in Wilmington, Delaware with services covering the US, as well as, additional offices in Germany covering European services. Invenio Financial has been an industry leader in specialty portfolio management partnering with banks, credit card issuers, auto lenders, debt buyers and utility providers to evaluate their inventory and find underserved portfolio segments. Its proprietary analytics will find unexplored segments of specialty accounts creating new, incremental value. Invenio Financial is willing to discuss all types of partnership opportunities including specialized acquisition and master servicing. For more information about Invenio Financial visit www.inveniofinancial.com.