Archives for May 2022

DALLAS, TX — Malone Frost Martin PLLC (MFM), a leading industry defense and compliance law firm, is very pleased to announce the addition of Chelsey Pankratz who will head up MFM’s new satellite office location in Jacksonville, Florida at 301 W. Bay Street, Suite 14147, Jacksonville, FL, US 32202.

Chelsey joins MFM with several years of industry experience working on behalf of accounts receivable management companies in a defense and compliance capacity.  She previously provided outsourced legal services to agencies in the Jacksonville area that included defense litigation, compliance advice, and policy creation. 

“I am thrilled to be joining the MFM team, and to help further serve our ARM industry clients here in Florida.” Said Chelsey Pankratz. 

“While the statutory construct of the laws that govern the ARM industry are not complex, the ARM business itself is complex.  Having attorneys like Chelsey that understand the complexity of the business is a differentiator for our clients. We are very excited to have Chelsey join our team and manage our new office in Jacksonville, Florida,” said Mike Frost, Partner at MFM.  

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“We have been wanting to open a Florida office for a long time, and we found the right fit with Chelsey,” said Xerxes Martin, Partner at MFM. “MFM looks forward to assisting our ARM industry clients with her Florida presence and experience.”

For more information related to the services provided by Malone Frost Martin PLLC please contact:

Mike Frost

Partner

Direct: (214) 346-2640

Cell: (319) 883-0306

mfrost@mamlaw.com

On May 9, 2022, the CFPB announced it issued an advisory opinion stating that in its opinion, the Equal Credit Opportunity Act (ECOA) applies to every aspect of dealing with a creditor, not just to the credit application process. The advisory opinion indicates ECOA protections apply to revocation, collection procedures, alteration or termination of credit, and anything else that takes place after credit has been extended.  

ECOA  bans credit discrimination based on race, color, religion, national origin, sex, marital status, and age. It also protects those receiving money from any public assistance program or exercising their rights under certain consumer protection laws. According to CFPB Director Rohit Chopra, the advisory opinion “makes clear that anti-discrimination protections do not vanish once a customer obtains a loan.”

To explain why anti-discrimination protections continue after a customer obtains a loan, the advisory opinion walked through the history of ECOA, Regulation B, and their amendments. Specifically, the opinion points out how ECOA and Regulation B refer to accounts in the past tense and refer to debtors. According to the CFPB, despite this “well-established interpretation,”  the advisory opinion is necessary because some creditors fail to acknowledge that ECOA and Regulation B plainly apply to events that take place after credit has been granted.

As a reminder, the CFPB also pointed out that in addition to protecting borrowers after applying for and receiving credit, ECOA requires lenders to provide “adverse action” notices to borrowers with existing credit. These notices should be sent when credit is denied, an existing account is terminated, or an account’s terms are unfavorably changed.

The full advisory opinion can be found here.

insideARM Perspective:

This advisory opinion should not be read in a vacuum. Considering the  CFPB’s other recent announcements that (1) its UDAAP authority allows it to review for discrimination and (2) that it has the power to supervise all nonbank financial institutions which pose a risk to consumers, the picture of where this CFPB is going is becoming more evident. It seems this version of the CFPB plans to laser focus on the effects practices and policies have on consumers, and if it finds the net effect of procedures to be unfair, it will take action.  

The issue, of course, is not that anyone wants to mistreat people or wants to discriminate. Any such entity doing so is a bad actor and should be treated as such. Instead, the issue here is that those subject to the CFPB’s scrutiny still don’t know the proverbial rules of the game. While the CFPB has made its desire to look at the net result clear, it hasn’t alerted those subject to its oversight of which processes they will be looking at, what they will consider unfair, or any other insight into their expectations regarding processes and policies. Without this insight, we will continue to see rule-making by enforcement, which is not good for the industry or the consumers the CFPB is there to protect.

Any entity subject to the CFPB’s oversight should heed these warnings, watch developments closely, and ensure they are prepared to handle compliance proactively. We will continue to keep you informed about the CFPB’s actions. 

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Looking for guidance on how the CFPB’s new oversight initiatives can affect your CMS?  Subscribe to Research Assistant – insideARM’s source for premium, practical compliance guidance and in-depth, weekly peer group discussion.

When the CFPB announces new expectations, it’s a good time to think about the gaps in your CMS, too. Find out how to start your own assessment with the on-demand  Research Assistant webinar, A Complete Guide to Risk and Gap Assessments – How to Get Started. Get it here.

On May 12 at 2pm ET, learn how Risk and Gap Assessments can help you find large gaps and manage all the relevant laws in the new Research Assistant webinar, A Complete Guide to Risk and Gap Assessments Part II. Register here.  

On April 7, the Consumer Finance Protection Bureau (CFPB or Bureau) filed an amicus brief in an appeal, pending before the Court of Appeals for the Eleventh Circuit in which the Bureau argued that the Fair Credit Reporting Act (FCRA) does not exempt furnishers from investigating disputes based on legal questions as opposed to factual inaccuracies. Section 1681s-2(b)(1) of the FCRA states that a furnisher of consumer information must conduct an investigation of disputed information upon receiving notice from a consumer reporting agency (CRA) that the consumer has disputed the accuracy of the information. Many courts have interpreted this to require furnishers to reasonably investigate factual questions, but not disputed legal issues (e.g., whether a consumer is liable for a reported debt). By contrast, the CFPB’s brief asks the Eleventh Circuit to “clarify that furnishers are required to conduct reasonable investigations of both legal and factual questions posed in consumer disputes.”

The subject plaintiff allegedly suffered identity theft that she discovered in 2016. The identity thief — an employee of the plaintiff — opened a credit card in the plaintiff’s name, and over the course of several years, accumulated over $30,000 in debt, while also making some payments from business bank accounts controlled by the plaintiff. When the plaintiff became aware, she notified the issuing bank, and the account was closed. The employee was ultimately convicted of identity theft. The bank, however, continued to furnish information about the outstanding debt to the credit bureaus. The plaintiff filed multiple disputes with the credit bureaus regarding the debt, which were then transmitted to the bank. Although the bank acknowledged that the plaintiff’s employee had opened the credit card account without the plaintiff’s consent, it concluded that the plaintiff was nevertheless responsible for the debt due to her negligent supervision of her employee and failure to object to continuous payments from bank accounts controlled by the plaintiff. Thus, the bank “verified” the debt and continued to furnish the information.

After the plaintiff filed suit, the bank moved for summary judgment, asserting multiple arguments, including that the plaintiff’s dispute turned on the disputed legal question of the plaintiff’s liability for the account rather than on a factual inaccuracy, as well as that the FCRA does not impose a duty on furnishers to investigate the accuracy of legal questions raised in consumer disputes. The district court granted summary judgment to the bank, concluding that it had “conducted a reasonable investigation as required under the procedural requirements of the FCRA.” In reaching this conclusion, the district court described the investigation duties imposed on furnishers under the FCRA as “procedural” and “far afield” from legal “questions of liability under state-law principles of negligence, apparent authority, and related inquiries.” Citing the First Circuit’s decision in Chiang v. Verizon New England, Inc., 595 F.3d 26 (1st Cir. 2010), the district court concluded that “a consumer cannot prevail on an FCRA claim by raising disputed legal questions as part of the dispute process instead of pointing to factual inaccuracies contained within the credit report.”

On appeal, the CFPB filed an amicus brief, arguing that furnishers are statutorily obligated to investigate both legal and factual questions raised in consumer disputes. The CFPB’s brief acknowledges that several federal courts have distinguished between “factual” and “legal” questions in determining the obligation of CRAs to investigate disputes under 15 U.S.C. § 1681i and that other decisions, including Chiang and unpublished decisions of the Eleventh Circuit, likewise recognize such a distinction in the context of furnisher investigations under Section 1681s-2(b)(1). Nevertheless, the CFPB argues that these cases in the furnisher investigation context were “incorrectly decided” because the FCRA does not make any such distinction. The CFPB argues that unlike CRAs, furnishers are qualified and obligated to assess issues, such as whether a debt is actually due or collectible, and routinely do assess such issues. The CFPB also goes further and suggests that even in the context of CRA investigations under Section 1681i, a formal distinction between legal and factual investigations is inappropriate and argues that a CRA has a duty to conduct a “reasonable investigation” of a legal dispute even if it does not have a duty to provide a legal opinion on the merits of the dispute. Finally, the CFPB urges the court to reject a “formal distinction” between factual and legal investigations because of the practical difficulty in distinguishing between them.

The CFPB’s arguments urge a decision contrary to the decisions of several federal courts that have distinguished between legal and factual questions in the context of both CRA and furnisher investigations under the FCRA.[1] If the Eleventh Circuit accepts these arguments, it would create a circuit split with the First Circuit, and it would create significant uncertainty for furnishers attempting to comply with the FCRA by placing upon them a more onerous obligation than other courts have adopted. Further, a decision accepting the CFPB’s arguments could draw into question the distinction between legal and factual issues in the context of CRA investigations under Section 1681i as well, creating an even deeper split from existing precedent. The amicus brief is another example of the CFPB’s recent efforts to shape the state of the law governing the consumer reporting industry through both rulemaking and litigation.

[1]E.g., Leones v. Rushmore Loan Management Servs., LLC, 749 F. App’x 897, 901-02 (11th Cir. 2018) (distinguishing between factual inaccuracy and disputed legal questions in context of furnisher investigations); Chiang v. Verizon New England, Inc., 595 F.3d 26, 38 (1st Cir. 2010) (Like CRAs, furnishers are ‘neither qualified nor obligated to resolve’ matters that ‘turn[ ] on questions that can only be resolved by a court of law.’); Mohnkern v. Equifax Info. Servs., LLC, No. 19-CV-6446L, 2021 U.S. Dist. LEXIS 218532, at *15 (W.D.N.Y. Nov. 10, 2021) (adopting Chiang‘s approach after surveying the case law and finding it “represent[s] the prevailing view when courts deal with the type of claim asserted against furnishers like plaintiffs’ here).

In a new blog post published on the Consumer Law & Policy Blog, Professor Jeff Sovern advocates very strongly in support of interpreting the “unfairness” prong of UDAAP to encompass discrimination in connection with credit and non-credit consumer financial products and services offered by banks and other persons covered by the Consumer Financial Protection Act (CFPA).  He supports his position by relying on the plain language of “unfair” (which is not inextricably tied to credit products) and the common sense notion that companies should not be able to discriminate in any fashion in connection with offering of consumer financial products or services.

Professor Sovern’s argument misses the point.  The consumer financial services industry is not seeking a “pass” when it comes to any form of discrimination.  Instead, the industry simply wants to know what are the “rules of the road.”  The Equal Credit Opportunity Act is a very specific anti-discrimination statute that proscribes certain types of credit discrimination.  It has been implemented through a detailed regulation (Reg B) that has been on the books for many decades.  It only prohibits discrimination on certain bases: race, color, religion, national origin, sex, marital status, or age (provided that the applicant has the capacity to enter into a binding contract); the fact that all or part of the applicant’s income derives from any public assistance program; or the fact that the applicant has in good faith exercised any right under the CFPA or any state law upon which an exemption has been granted by the CFPB.

As an initial matter, I find considerable merit in the argument that if Congress considered discrimination to be “unfair,” it would have been unnecessary for Congress to enact laws such as the Equal Credit Opportunity Act to specifically prohibit discrimination.  According to Professor Sovern, this argument is flawed because the ECOA does more than just prohibit discrimination in credit transactions, such as providing injured consumers with a private right of action, and therefore would have been needed even if Congress considered discrimination something the CFPB could address through its UDAAP authority.  It would have been needed, says Professor Sovern, because the CFPA does not provide consumers with a private right of action for UDAAP claims and “Congress wanted injured consumers to have a private claim” which is provided in the ECOA.

The difficulty I have with Professor Sovern’s reasoning is that if UDAAP covers discrimination more broadly than the ECOA, why wouldn’t Congress have wanted injured consumers to also have a private right of action to use UDAAP to challenge any discrimination they could not challenge under the ECOA?  In other words, it seems to me that the absence of a private right of action in the CFPA for UDAAP claims provides strong support for the position that UDAAP does not cover discrimination.

But even assuming arguendo that the interpretation of UDAAP advocated by the CFPB and Professor Sovern is correct, what would that mean?  It is unclear whether the ECOA covers discrimination based on marketing or whether it applies only once someone has applied for credit.  Would UDAAP now fill that void?  And what about the further question of whether the disparate impact theory applies to ECOA and, if not, whether it nevertheless would apply to UDAAP.  Those are just a few of the questions the CFPB’s and Professor Sovern’s interpretation raises for consumer credit.

The CFPB’s and Professor Sovern’s interpretation raises even more questions in the context of discrimination involving non-credit products such as deposits, prepaid cards, and remittances.  For example, many banks have a policy of not opening deposit accounts for someone who does not reside within the bank’s market area.  Would that be considered a UDAAP violation?  While there is a well-established body of law pertaining to the application of ECOA, there is absolutely no body of law pertaining to how the unfairness prong of UDAAP applies to non-credit products.  Although the CFPA became law in 2011, I’m not aware of a single instance in which the CFPB has used its UDAAP authority to proceed against a person based on non-credit discrimination.  Furthermore, I’m not aware of the FTC using its UDAP authority under Section 5 of the FTC Act (which was enacted more than 100 years ago) to ferret out discrimination dealing with either credit or non-credit products.

Given the complexity of the questions the CFPB’s expansion of UDAAP raises, it seems obvious that this type of a drastic change should be done through a rulemaking and not through an amendment to an examination manual.

Just like everyone else, you’re being flooded with credit reporting disputes. Disputes volumes continue to exhaust dispute processing operations. And volumes and complaints continue to rise. In 2021, the CFPB received more than 500,000 credit or consumer reporting complaints as compared to 319,000 in 2020 (roughly 57% increase).

If done right, you can use our 3 key elements to increase disputes management efficiency.

Increase Operational Efficiency by up to 30% with a Seamless Approach

Consumer reporting disputes are rolling in fast. Your team is moving through cases, sorting documentation from multiple sources, and doing their best to avoid discrepancies or data mistakes that could lead to unhappy customers and complaints to regulators. You’re wondering how to streamline the disputes process so that you can manage more volume without overtaxing your agents.

The good news is that we’ve seen many ways dispute management teams can make their operations more efficient. Several tactics are cost-effective and won’t burden existing IT infrastructure.

But there are three key areas that will help you gain traction and up to 30% efficiency. We’ve recommended this seamless approach to clients from dozens of engagements in disputes management.

1. Disputes processing effectiveness
2. Data quality management
3. Forecasting and planning

1. Maximize Disputes Processing Effectiveness

Your dispute processing effectiveness is a good indicator of operational efficiency. There are two ways to ensure that end-to-end, your disputes processing is as effective as it can be.

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First, deploy a dispute case management system. Your system should allow for automated uploads of indirect disputes from e-OSCAR® and input of direct disputes manually or automated from other systems. Additionally, the system should populate dispute cases with data from all relevant systems of record. That way, all borrower disputes are visible in a single system, eliminating the need for cross-referencing in multiple systems. The workflow solution also eliminates time-consuming manual input, while reducing errors with efficiency improvements that can range from 10-50% depending on your current situation.

The success of your case management system relies on how you use it.

So, second, after you deploy your system, turn your focus to the tools within the system to further efficiencies.

Focus on implementing a dispute queue structure and consolidating duplicate disputes within your system. Both will help you and your team “trim the fat” – cutting down on excess and redundant work. Look out for a future blog that details how to do both of these things.

2. Data Quality Management to Confirm Accuracy of Furnished Data

The importance of furnishing data quality and accuracy can’t be understated. When furnishing accurate data to CRAs, you have peace of mind that you’ve reduced your compliance risk and overall disputes volumes.

Adding systematic reviews of data and coding into your data quality management routines will confirm your furnished data is accurate. We tell clients they should be performing routine comprehensive data assessments and we suggest conducting Metro 2® code mapping reviews to certify alignment between system of record and furnished data.

3. Forecasting and Planning to be Prepared for any Volume

The last recommendation to boost disputes management efficiency is to make sure you understand your process and the way your team operates by consistently evaluating your internal dispute processing.

Analyze volumes and processing time by dispute type. For example, the most voluminous dispute type might be “account isn’t mine,” or your team might take the most time to resolve late payment disputes. Or, dealing with a multitude of repeat disputes could be dragging down your efficiency.

Whatever the case, knowing what you’re working with sets you up to forecast volumes and evaluate the efficacy of current processes. Calculate whether your methods as they stand can keep up with current demand, or if they’re being stressed. Use this to review processing changes and assess further efficiency opportunities.

With this evaluation, you can segment disputes to establish more streamlined processing and consider new strategies for handling different types of disputes. Additionally, an overall assessment facilitates understanding of processing gaps to identify issues early on and ensures compliant processing.

A Kentucky district court judge recently granted in part and denied in part a defendant’s motion for summary judgment in a Telephone Consumer Protection Act (TCPA) case, Barnett v. First National Bank of Omaha. The court held that the plaintiff’s request to have information sent to him via the mail instead of over the phone, along with the plaintiff’s refusal to talk to a collector when the defendant called after choosing mailed delivery, gave rise to a genuine issue of fact as to whether the plaintiff revoked consent to be contacted, even without explicit revocation. In Barnett v. First National Bank of Omaha, the court examined consent and revocation under the FCC regulations that implement the requirements of the TCPA.

There, the plaintiff obtained a credit card from the defendant, using his cell phone as a way for the defendant to contact him. In 2019, the plaintiff was unable to make his minimal monthly payment, and the defendant started contacting him via its telephone system to discuss his missed payments, eventually contacting the plaintiff 574 times, an average of 3.2 times per day. At some point, the plaintiff requested the defendant to mail him his billing statements and started hanging up the phone on defendant’s representatives.

The plaintiff filed suit in the Western District of Kentucky, alleging the defendant violated the TCPA (47 U.S.C. § 227) and the Kentucky Consumer Protection Act (KCPA) (Ky. Rev. Stat. § 367.170) by contacting him via an automated telephone dialing system before and after he allegedly revoked consent to be contacted. The plaintiff also brought an intrusion upon seclusion claim against the defendant. The defendant filed a motion for summary judgment.

Relying on the Supreme Court’s holding in Facebook v. Duguid to find that the defendant did not use an automated telephone dialing system, the court granted the defendant’s motion on that issue and then focused its analysis on whether the calls made to the plaintiff occurred after consent had been revoked.

The defendant argued that the plaintiff never specifically revoked consent to be contacted after he listed his cell phone number on his credit card application. The plaintiff argued that he revoked consent when he (1) told the defendant not to call him and (2) asked the defendant’s representatives to mail his statements or hung up on them when they called. The defendant countered that the plaintiff had never provided “clear revocation” of his consent.

While the court noted that the TCPA is “silent on whether and how a consumer may revoke previously-granted consent,” the court ultimately, looking at the “totality” of the circumstances, found that the arguments of the parties clearly demonstrated remaining disputed issues of fact for a jury.

The court’s decision in Barnett provides insight into how courts may consider disputes over consent, absent express revocation under the TCPA. Even if a plaintiff does not expressly revoke consent to be contacted, this does not automatically guarantee a defendant will prevail on summary judgment.

PALM SPRINGS, Calif — Provana, provider of the industry’s first unified platform for compliance and performance management, today announced a strategic partnership with TJ44 Consulting LLC, a compliance consultancy founded by Tara Trantham, who was previously Chief Legal Officer and Chief Compliance Officer at Southern Management Corporation, in addition to General Counsel and Senior Vice President at World Acceptance Corporation (WRLD). 

The new solution combines Tara’s legal and compliance acumen, built across years working directly with the Consumer Financial Protection Bureau (CFPB), and Provana’s comprehensive compliance management suite, IPACS. The announcement was made from the American Financial Services Association’s (AFSA) Independents Conference & Expo in La Quinta, California.

Coming at a pivotal moment, on the heels of the CFPB’s announcement that it will exercise its dormant authority to examine non-bank lenders and financial services companies, the joint solution aims to help a broad scope of now regulated organizations achieve compliance rigor.

“In today’s ever-changing regulatory environment, it is incredibly valuable to understand what’s happening with state-level regulators as well as state and national industry associations to stay ahead of impactful law changes,” said Tara Trantham, Founder and CEO of TJ44 Consulting LLC. “I’m thrilled to bring my experiences from working on Capitol Hill to Provana so we can help agencies and fintechs alike establish an effective compliance solution.”

Sean Clark, SVP of Platforms at Provana, added, “Tara’s deep, hands-on experience of working intimately with regulators in Washington, D.C. is invaluable for organizations of all types who are grappling with the regulatory changes coming from the CFPB. We’re excited to incorporate Tara’s knowledge into our tech platforms to help more clients automate and uphold top-notch compliance programs.”

About Provana

Provana’s SaaS-based digital operating platform is the first of its kind, giving leaders control over process-intensive operations. We serve law firms, insurance companies, accounts receivable agencies and networked enterprises in the US market that are tightly regulated by the CFPB and other authorities. Built on decades of experience in machine learning, natural language processing and business process management, Provana helps customers manage sensitive interactions, analyze unstructured data, process personal information, and ensure compliance. Provana is backed by a NYC-based Fintech PE, most recently raising funds in November 2020. Learn more at www.provana.com.

About TJ44 Consulting, LLC

Built on decades of litigation experience with the CFPB, SEC, DOJ, OCC and FBI, TJ44 Consulting LLC – Compliance and More on Demand has established itself as the foremost authority on compliance, risk management and creditors’ rights. With over 50 combined years of experience in financial services, consumer credit and collection, auto and mortgage landing, TJ44 offers complete back-office solutions, risk identification and management services, bankruptcy services, and more.

A New York federal judge on April 28 temporarily enjoined three New York sheriffs from refusing to enforce judgment executions which seek to collect judgment interest “calculated with the interest rate in effect at the time the judgment was obtained.”

The temporary injunction applies to the sheriffs of Chautauqua, Erie, and Niagara counties.

A copy of the opinion in Greater Chautauqua Federal Credit Union et al. v. Marks et al. is here: Link to Opinion.

On Dec. 31, 2021, New York legislation was signed into law lowering judgment interest on “consumer debt” from nine to two percent. The law takes effect on April 30.

While this poses no concern for covered judgments entered after April 29, the law also applies to unsatisfied judgments retroactively “from the date of the entry of judgment on any part of a judgment entered before [April 30, 2022].”

While accrued but unpaid interest at nine percent will have to be recalculated at the new rate of two percent, other interpretations suggest that even paid interest on unsatisfied judgments is subject to reduction.

Three New York credit unions filed an action in federal court alleging the law is an unconstitutional taking and requested a preliminary injunction to prevent its enforcement.

Only Three County Sheriffs Enjoined

There are 62 counties with 62 sheriffs in New York. This order enjoins only three. The enjoined sheriffs are in three contiguous counties in western New York along Lake Erie and includes Buffalo, New York.

With a little over 19 million New Yorkers, the affected counties are home to just over 1.3 million people. The court, though, required that its order be served on all New York sheriffs.

Retroactive Reduction Likely Unconstitutional 

At this stage of the litigation, the court was asked only to determine whether the plaintiffs, the three credit unions, are likely to prevail on their claims. The court found that the retroactive judgment interest reduction is likely an unconstitutional “regulatory taking.”

First, it determined that interest on unsatisfied judgments is the property of the judgment creditor and so it is “constitutionally protected.”

Second, although the law is not akin to a condemnation or appropriation of property, its effect is “so onerous that its effect is tantamount to a direct appropriation. . .”

The case will continue to be litigated and the injunction will continue until the court (or an appellate court) decides otherwise.

A Confusing Law that Deserves Judicial Review 

There are several ways to interpret the retroactive judgment interest reduction under this recently adopted law and judgment creditors are struggling to determine its scope. While covered judgments paid and satisfied prior to April 30 are not subject to adjustment, unpaid judgments present a more complex problem.

The text of the law is subject to at least two conflicting interpretations on how paid interest on unsatisfied judgments must be treated. While the law does not require a creditor to return interest paid at the nine percent rate, new sections (a)(ii) and (c) of CPLR § 5004 are confusing and unclear as to how such paid interest on unsatisfied judgments is to be treated beginning April 30.

BIRMINGHAM, Ala. — ARM Compliance Business Solutions is excited to announce that Tonia Brown has joined the company as a Senior Compliance Advisor. In this role, Tonia will navigate ARM Compliance Business Solutions clients through the ever-changing regulatory compliance requirements of consumer financial laws by enhancing their Compliance Management System through policy development and implementation, training development, service provider oversight, audit controls, and risk assessments. 

Tonia joins the company with over 15 years of industry experience in both first-party and third-party revenue cycle management. Prior to joining ARM Compliance Business Solutions Tonia was the Executive Vice President at Automated Collection Services, Inc. (ACSI), a Tennessee debt collection agency, where she was responsible for Corporate Compliance, Clients Services and Human Resources.

In her 13 years at ACSI she was responsible for all aspects of ACSI’s corporate administration services including higher education, healthcare, government, and financial/private sector including, regulatory compliance and quality control auditing activities, dispute and complaint resolution, Consumer Helpline, training, internal and external audits, and client contract audits. Tonia holds certifications as a Compliance & Ethics Professional (CCEP), Society of Corporate Compliance & Ethics Healthcare Compliance (CHC), and Credit and Collection Compliance Officer (CCCO). She is an active member of ACA International and Receivables Management Association International and currently serves as Middle TN & Southern KY Better Business Bureau Treasurer.

“I am absolutely delighted to have Tonia on my team,” said Sara Woggerman, President of ARM Compliance Business Solutions. “Her experience specifically in the healthcare revenue cycle adds immediate value to our clients in this market at a time when regulatory scrutiny is elevated.” “Tonia has an incredibly calming presence when collaborating with clients to overcome their unique challenges and I am excited to see her grow at ARM Compliance Business Solutions.”

“I have spent the last several years watching and learning from Sara and knew her to be a solid leader with her eyes always on the ever-changing regulations in our industry, said Tonia Brown.” “Working with her through ARM Compliance Business Solutions was a no-brainer for me. “I am thrilled to be a part of her team!”

About ARM Compliance Business Solutions, LLC. 

ARM Compliance Business Solutions, LLC. was formed in 2020 to provide professional advisory services to the accounts receivables management industry through its delivery of compliance risk assessments, outsourced compliance services, service provider oversight, and executive-level training. ARM Compliance Business Solutions is a recognized leader in compliance and operational strategies to improve the consumer experience and enhance business practices for their clients. For more information, visit www.armcbs.com or contact Sara Woggerman at sara@armcbs.com.