NEWARK, Del. — SIMM Associates is proud to continue its sponsorship of DFRC Blue-Gold Golf Classics tournaments which were held on August 28th and September 21st 2020. Every year, with the support of more than 100 sponsors, 250 golfers participate in the two Blue-Gold All★Star Golf Classics. DFRC is a well-respected Delaware foundation dedicated to raising funds and consciousness in support of programs that enrich the lives of Delawareans with intellectual disabilities. Established in 1956, the private, nonprofit organization is dedicated to identifying and funding programs based on community need. Since inception, DFRC has distributed over $6 million dollars into Delaware programs.

“For 65 years DFRC has worked tirelessly to support programs that encourage individuals with intellectual disabilities to live their best life” said Co-Founder and Chief Operating Officer Jeff Simendinger. “We’re extremely proud of our sponsorship affiliation with DFRC and look to continue our involvement for many years to come.”

DFRC’s signature fundraising events are the annual Blue-Gold All★Star Football Game, Holidazzle, Blue-Gold All★Star Golf Classics, the Blue-Gold All★Star Run/Walk and the Blue-Gold Sussex County Auction. Each event provides opportunities to promote understanding of people with intellectual disabilities. The Blue-Gold All-Star game is the longest-running game in the country to benefit the same charity. DFRC is committed to complete transparency and has earned the Guide Star seal of approval. 

ABOUT SIMM ASSOCIATES, INC.

SIMM is a full service nationally licensed ARM company providing collection solutions to the student lending, consumer lending, credit/retail card, healthcare, auto finance, credit union and debt buying industries. SIMM provides best in class deceased care solutions that encompass decedent verification, estate location scrub, proprietary Probate Tracker SM claim filing process and an empathetic survivor recovery solution all performed with brand sensitivity and regulatory compliance in mind. SIMM has passed the US Department of Education’s stringent requirements and currently is a subcontractor for the existing Private Collection Agency contract. Its headquarters is located in Delaware in a 32,000 sq. ft. state of the art call center. SIMM holds the following certifications: PCI Level 1, ISO 27002 and SSAE16 Type II. SIMM services customers throughout the United States including Puerto Rico. 

The progeny of Avila v. Riexinger & Associates continues to spawn, even though debt collectors are routinely winning these cases. Two of the most-recent decisions on these claims came from some of the most problematic jurisdictions for debt collectors: the Third Circuit and the Eastern District of New York. Both courts ruled in favor of the debt collector.

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Third Circuit Doubles Down in Dotson v. Nationwide Credit, Inc.

In this decision, the Third Circuit affirmed the district court’s dismissal of the case. The case revolved around a collection letter sent by the defendant while attempting to collect a debt on behalf of Chase Bank USA, N.A. The letter stated that “[t]he Account Balance as of the date of this letter is shown above.” 

Plaintiff sued, alleging a claim we’ve all seen before: that stating the balance due “as of the date of this letter” could confuse a consumer into thinking the debt will change in the future when the debt is, in fact, static. The claim was dismissed by the district court, which found that:

[The letter] actually guards against potential confusion about the amount owed by clearly specifying the date on which the debt was calculated, preventing any misunderstanding that could arise if, for example, a payment crossed in the mail with the collection letter.”

The Third Circuit agreed with the district court and echoed the Second Circuit’s reasoning in Taylor v. Fin. Recovery Servs. when it found that the letter accurately stated the balance owed.

Pre- and Post-Charge-Off Collection Letters in Sharon v. CAC Fin. Corp.

In this case, the Eastern District of New York granted the defendant’s motion for summary judgment on an interest disclosure claim. The facts of this case are best portrayed in a timeline:

• 2016: The plaintiff falls behind on her credit card payments.
• April 2016: The creditor places the account with a collection agency (not defendant) listing the outstanding balance as $1,751.
• August 2016: The creditor charges off the account and placed it with defendant for collections.
• Sept 2016: Defendant sends its collection letter listing the outstanding balance as $2,018.79. Per the DFS regulation, the defendant also listed as follows: “POST C/O INTEREST” and “POST C/O FEES” as zero and “POST C/O AMOUNT” as $2,018.79. 

Plaintiff, represented by attorney Adam Fishbein, filed an FDCPA claim alleging that defendant’s letter is misleading and that it confused the defendant about whether or not the balance was increasing. The primary argument is that the letter sent by the defendant contained a higher outstanding balance than the letter she received earlier in the year from the previous debt collector. The defendant argued that, since the account was charged off, the balance was static throughout the period in which it tried to collect the debt. (This follows the Second Circuit’s guidance as outlined in De Rosa, which was against this same defendant.)

In her decision on the motion for summary judgment, Judge Donnelly relies on Taylor v. Fin. Recovery Servs., finding that the prior Second Circuit decision “resolves this case decisively against the plaintiff.” The decision states:

The parties agree that Synchrony charged-off the plaintiff’s account on August 16, 2016, and that the defendant sent its first collection notice to the plaintiff two weeks later. Even if the plaintiff’s account might have been collecting interest before Synchrony charged-off the account, or when another collection agency was trying to collect the debt, the debt stopped collecting interest and fees on August 16, 2016. At that time, the balance due was $2,018.79—the amount the defendant listed in its September and October collection letters. That amount did not change while the defendant attempted to collect the debt, and the defendant’s letters accurately stated the balance, interest and fees the plaintiff owed.  

insideARM Perspective

There you have it, folks. Two more cases to add to your war chest in case you continue seeing interest disclosure cases come across your desk. The iA Case Law Tracker—which gives you data on court decision trends in seconds—lists 112 court decisions that discuss the interest disclosure issue. In 78 of those decisions, the court ruled in favor of the debt collector. In New York and Illinois—two jurisdictions that were flooded with these claims—debt collectors are overwhelmingly winning these claims.

Want to follow these links to view brief summaries of those decisions? Subscribe to the iA Case Law Tracker today, or sign up for a free trial to take a test run.

SACRAMENTO, Calif. — On Monday September 29, 2020, the Federal Trade Commission (FTC) along with State and Federal Law  Enforcement Partners announced, Operation Corrupt Collector, a nationwide law enforcement and  outreach initiative to protect consumers from phantom debt collection and abusive and threatening  debt collection practices. This crackdown encompasses more than 50 enforcement actions against debt  collectors brought by the FTC, three federal partners, and partners from 16 states. 

The Receivables Management Association International (RMAI) applauds the FTC and state and local  governments for their commitment to enforcing the law against companies who are blatantly breaking  the law to collect debts consumers do not owe or engaging in abusive and threatening practices. Illegal  activity by a few tarnishes the reputation of the thousands of debt buyers and debt collectors who work  with consumers every day in full compliance with the law to pay their just debts. RMAI thanks the FTC  and those state and local governments for their efforts to rid the industry of any bad actors and address  the complaints of consumers related to debts they either did not owe or abusive and threatening  collection practices.  

In addition to the enforcement actions, state and local consumer protection agencies across the country  are joining the FTC in rolling out new information to help consumers know their rights when it comes to  debt collection and what steps to take if they receive a call trying to collect on a debt that they do not  recognize. Click here to learn more about Operation Corrupt Collector. 

About RMAI

RMAI is the industry leader in setting standards for the debt buying and debt collection. Since 2013,  RMAI has held its membership to certification standards which equal or exceed the minimum required  to comply with the law. Treating consumers with dignity and respect, substantiating debt prior to  collection, and fostering support for an industry which is designed to complete the consumer credit  cycle are the underpinnings of its certification standards.

As debt collectors began to wonder whether they’d be able to comply with New York City Department of Consumer Affair’s (DCA) new Limited English Proficiency rule, the regulator has finally posted the final piece of the puzzle just as its enforcement grace period against debt collectors was about to expire. Yesterday, DCA at long last posted the glossary of commonly-used collection terms and their translations. 

Among several requirements, the new rule requires debt collectors to provide a link to DCA’s website — www.nyc.gov/dca — and inform consumers that they can find such a glossary there.

The big concern for debt collectors was whether the glossary would be posted at all; and, until it was posted, there was a concern that it was impossible to properly comply with the rule and protect against legal risk. A debt collector could include the link to the website to comply with the rule, but if the glossary was not present, then it provided legal exposure to debt collectors for potentially providing misleading or deceptive communications to consumers.

On the other hand, a debt collector might have decided to forego providing the link, thus not complying with the rule, in order to protect against the legal exposure of misleading or deceptive communications in what is one of the most litigious jurisdictions for FDCPA claims. 

Thankfully, debt collectors don’t have to pick and choose. Now that the glossary is available, the loop is closed.

Some things to keep in mind:

1) The regulation doesn’t say to provide the link of the glossary. Per the reg, your New York City letters only need to have the following:

(viii) a statement that a translation and description of commonly-used debt collection terms is available in multiple languages on the Department’s website, www.nyc.gov/dca.

However, it is not immediately apparent, at least to this least sophisticated consumer, where the glossary is from the link above in the regulation. Safety says: follow the regulation as written, because sometimes links change and if you use the glossary link itself, rather than the www.nyc.gov/dca link in the regulation, and then NYC DCA changes that link, you might find yourself in dutch with the City.

2) Per the regulation, you are not required to provide communications in anything other than English; and if you only provide notices and communications in English, that needs to be mentioned in your disclosure on your letters and on your site. If you do offer written and oral communications in other languages, though, those languages need to be listed in the letter. And if you have the ability to translate written documents or handle other languages in a phone call, that needs to be made explicit to consumers, too.

3) Also per the regulation, that link to www.nyc.gov/dca also needs to be on your website. It can be on a consumer-reachable disclosures page. You will also have to list the languages your agency supports on your site, too.

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insideARM Perspective

While DCA was likely well-meaning and genuine in its attempt to help consumers who may need language services, the procedure of how this rule came about has been poorly managed and frustrating for collectors.

First, DCA announced the rule and held public hearings in the Spring while all companies—including debt collectors—were in the middle of the COVID-19 pandemic scramble in an unprecedented effort to transition to a remote workforce while at the same time being available to help consumers who were sending inbound phone calls to debt collectors at unprecedented rates. As one would suspect, this rule missed everyone’s radar—there were zero comments received from industry or consumer advocates on the rule.

Then, DCA provided a grace period for enforcement because, once the dust settled and industry had a chance to review the rule, there were many questions left unanswered about how, exactly, to comply with the rule. In response to this, DCA released an FAQ document and annual report template.

However, even that was not complete, as there was one big piece of the puzzle missing: the glossary of commonly-used collection terms and their translations. DCA announced an extension to their grace period so they could get this up, which we now see was done mere days before debt collectors are expected to fully comply with the new rule. Talk about a nail-biter.

Again, the industry can appreciate DCA’s intent behind the rule. There are many consumers who would greatly benefit from language access services. However well-meaning the intent was, the way this rule came about was a mess and now we wait and see whether it will have any unintended consequences.

insideARM previously wrote about both California’s legislation to create debt collection licensing requirements as well as the state’s efforts to create a state consumer protection agency (affectionately dubbed the “Mini-CFPB”). These two efforts are now a reality, as California’s Governor Gavin Newson signed and approved both pieces of legislation on September 25, 2020. Here’s what you need to know about each.

Debt Collection Licensing

The Debt Collection Licensing Act (SB 908)calls for the licensure, regulation, and oversight of debt collectors by the Commissioner of Business Oversight from the Department of Business Oversight (DBO). It would require debt collectors located in California and those who collect debts from California residents, regardless of office location, to obtain a license. It would also require such businesses to comply with regulatory oversight, including examination and reporting, of DBO.

According to the Legislative Council’s Digest:

This bill would require each licensee to, among other things, file reports with the commissioner under oath, maintain a surety bond, and pay to the commissioner its pro rata share of all costs and expenses reasonably incurred in the administration of these provisions, as estimated by the commissioner. The bill would authorize the commissioner to enforce these provisions by, among other things, adopting regulations, performing investigations, suspending a license, issuing orders and claims for relief, and enforcing the provisions, as specified.

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The Act prohibits certain acts and practices. Some of these are nothing new to debt collectors, such as not using profane language, annoying consumers by causing their phones to ring repeatedly, or communicating so frequently with consumers to the point where it constitutes harassment.

A new addition to the prohibitions includes sending communications–either written or digital–without displaying the California license number in at least 12-point type.

The good news for debt collectors is that the Act requires DBO to create a Debt Collection Advisory Committee to advise the Commissioner on matters related to debt collection. The committee would consist of 7 members, one of which must be a consumer advocate. Committee members shall be appointed by the Commissioner and shall serve 2-year terms.

The Act also gives authority to the Commissioner to adopt regulations necessary for the DBO to be prepared to perform its regulatory duties by January 1, 2022. This means that we very well may see proposed rulemaking within the next year. 

State Consumer Protection Agency

California Consumer Financial Protection Law (AB 1864)is a piece of legislation introduced by Assemblymember Monique Limón, who has been a long-standing advocate for a mini-CFPB in California. Back in April 2019, Asm. Limón appeared in a press conference with Richard Cordray, former director of the Consumer Financial Protection Bureau, discussing the need for such a state agency.

According to the Legislative Digest for the legislation:

This bill would rename the “Department of Business Oversight” as the “Department of Financial Protection and Innovation,” which would be charged with execution of the above-specified laws. The bill would also put this department in charge of various other laws relating to providing financial products and services in this state. 

. . . 

he bill would require the department to regulate the provision of various consumer financial products or services and to exercise nonexclusive oversight and enforcement authority under California consumer financial laws and, to the extent permissible, under the federal consumer financial laws. The bill would make it unlawful for covered persons or service providers, as defined, to, among other acts, engage in unlawful, unfair, deceptive, or abusive acts or practices with respect to consumer financial products or services, or offer or provide a consumer a financial product or service that is not in conformity with any consumer financial law.

. . .

The bill would grant the department, among other duties, the power to bring administrative and civil actions, issue subpoenas, promulgate regulations, hold hearings, issue publications, conduct investigations, and implement outreach and education programs. The bill would also require the department to promulgate specified regulations and to promulgate rules regarding registration requirements applicable to a covered person within certain timeframes and subject to specified conditions.

There you have it, folks. Now we wait to see how both of these new laws are put into practice by the state.

Today, the FTC—in tandem with Federal and state regulators and attorneys general—announced a sweeping law enforcement action dubbed Operation Corrupt Collector. The action targets collectors who engage in unauthorized collection of debt or collection of state debt, including the use of abusive collection practices. The broad sweep includes 50 enforcement actions brought by the Federal regulators and 16 states.

The group of regulators and AGs held a press conference today about Operation Corrupt Collector. The conference included comments by Andrew Smith, Director of the FTC’s Bureau of Consumer Protection, and Leticia James, Attorney General of the state of New York. Smith noted that such corrupt collection practices harm legitimate debt collectors who are trying to do things by the book.

The conference announced two recently-filed cases by the FTC, which are described in the FTC’s press release. The first, against  National Landmark Logistics, LLC, which alleges:

[T]he defendants used robocalls to leave deceptive messages claiming consumers faced imminent legal action about debts. When consumers returned the calls, the defendants falsely claimed to be from a mediation or law firm, again threatened legal action, and used consumers’ personal information to convince consumers the threats were real. The complaint alleges that, in many instances, consumers did not owe the debt being collected on or the defendants had no right to collect it. 

The second, against Absolute Financial Services, LLC, alleges:

[T]hat the company used the defendants in the National Landmark Logistics case (above) to place deceptive robocalls alleging that consumers owed debt and faced legal action if they did not reply. Once consumers called the defendants after receiving the message, the defendants often falsely claimed to be representing a law firm or threatened consumers with arrest if they did not immediately pay the debt. According to the complaint, the defendants used consumers’ personal information (provided by the National Landmark defendants) to convince consumers that the debt was legitimate.              

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insideARM Perspective

Assuming these allegations are true, insideARM applauds these regulators and Attorneys General for cracking down on these types of practices. As Smith mentioned, these types of egregious actions—such as threatening arrest, inflating amounts owed, and illegally posing as attorneys—harm legitimate debt collectors who are trying to do things by the book. Debt collection is an important piece of the consumer credit puzzle. Bad actors cause consumers and regulators to be skeptical of legitimate debt collectors, making their job more difficult. Actions that pluck bad actors out of the market help both consumers and legitimate collectors.  

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.

As you’ve likely heard by now, President Trump has nominated the Hon. Amy Coney Barrett to fill the U.S. Supreme Court seat vacated in the wake of Justice Ginsburg’s passing. Judge Barrett currently sits on the United States Court of Appeals for the Seventh Circuit, where she has already had the opportunity to rule on one critical TCPA ATDS case—Gadelhak v. AT&T Services, No. 19-1738 (7^th Cir. Feb. 19, 2020). 

In Gadelhak, Judge Barrett—writing for the Court—found that the TCPA’s ATDS definition covers only equipment that utilizes a random or sequential number generator to produce numbers to be called, either immediately or from storage. This ruling dramatically limits the applicability of the TCPA in private lawsuits against so called robocallers. 

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While it is impossible to know for sure, it seems likely Justice Ginsburg would have favored a broader reading of the TCPA’s ATDS definition in favor of private lawsuits designed to thwart unwanted calls—just as she did in the Supreme Court’s earlier decision in Mims. 

Should Justice Barrett eventually replace Justice Ginsburg on the bench, callers will likely gain an ally in the pending SCOTUS review of the TCPA’s ATDS definition in Facebook in the form of a Judge (or Justice) that has already delivered a critical ruling narrowly reading the TCPA.

The timing here is interesting: Trump and Senate Republicans have vowed to see Judge Barrett elevated before the election, which means she should be available to help preside over the oral argument in Facebook set on December 8, 2020.

While the rules require a Supreme Court Justice to recuse themselves from an appeal in a case they presided over below, there does not appear to be anything in the rules that would require Justice Barrett from participating in the Facebook appeal, should she so choose.  The legal issue to be determined in Facebook is certainly the same as the issue determined by Judge Barrett in Gadelhak, but the two cases are not technically related.

We’ll keep an eye on developments with Judge Barrett’s nomination from a TCPA perspective. 

Having a hard time keeping up with important industry-related court decisions and legal/compliance issues?
The iA Case Law Tracker makes it easy and helps you do it in less time than it takes to pour your morning cup of coffee.

In our “new” normal of virtual communication and countless Zoom meetings, a lot of people struggle with being the best and most authentic version of themselves. In this 30 minute session, Executive Media Coach and Emmy winner, Katy Temple, arms you with tangible takeaways that will immediately make you better “on camera.”

insideARM’s Amy Perkins and Katy Temple look at 5 tips that will help you look your best, and get your message across effectively. They look at:

1) First Impressions: “A lot of people have said, well, I think people will understand [the mess, the clutter] because everyone’s going through so many things, and we understand that on one level. But the other part about that is: this is the new normal, and it could last forever for a lot of businesses.”

2) The Camera is Your Friend: No, really. “Think about it as somebody who loves you, who wants to see you succeed, who is the vessel to get your message out and your passion out.”

3) Energy: “The reality about a camera and energy is that it sucks the energy out of you. And that’s real. I mean, part of this challenge is that we’re trying to get used to the way that the camera is picking us up. Not maybe necessarily how we really feel that we are. And so that’s kind of a new skill that you want to excel at.”

4) Body Language: “When I’m talking about the studio or the messaging or the energy it’s got to merge with who you are; authenticity is key to body language.”

5) Class Participation: “Practice, be prepared and know what you want to say so that you’re ready to go when the camera’s on you. And it’s just another reminder to not forget to prepare, especially when we’re all just challenged, communicating and being engaged virtually right now.”

If you’re looking for more insight just like this, consider signing up – or signing your team up – for Women in Consumer & Commercial Finance (December 8-10). Genuine networking opportunities and real, honest career advice is in short supply. Don’t let 2020 pass without giving your career some attention. Sign up today.

Six months in to one of the worst pandemics/shut-downs any of us has ever lived through, and is there a light at the end of the tunnel? Or is that just an oncoming train? What an exciting time to be alive!

Here’s a rundown of state actions that may effect your business:

New York & New Jersey: If you have offices/employees in those states, know that their governors have added Arizona, Minnesota, Nevada, Rhode Island and Wyoming to the list of states where people need to quarantine for 14-days if they’ve visited there.

How this might effect you: If you have clients in those states, and you were thinking about sending people out there (sales people, auditors, etc.), you might think about not doing that, or know that when your employee returns to New York or New Jersey, they’ll need to quarantine for 14-days before they can be out and about.

California: Sick leave benefits have been extended from six to eight weeks.

How this might effect you: If you’re a California employer, it would be a good time to talk with an employment attorney to make sure your crossing the t’s and dotting the i’s on paid leave.

Illinois: A state moratorium on shutting off state-regulated utilities that was due to expire at the end of Septemer 2020 is now extended through the end of October 2020.

How this might effect you: If you’re collecting on utilities in Illinois and were set to hit “go” on October 1, don’t.

New York: The governor has signed an executive order extending NY’s moratorium on evictions and foreclosures to October 20.

How this might effect you: Similar to above, if you collect on evictions and you collect on evictions in New York and thought you were good to go, you aren’t. 

As more information comes in, we’ll publish additional content.

Agencies that collect debts in New York and New Jersey are likely no strangers to the law firm Barshay Sanders PLLC and their recent frequently-filed claim that the format of a collection letter—font size, location of the notice of validation rights, the use or lack of transitional language—overshadows the consumer’s validation rights under the Fair Debt Collection Practices Act (FDCPA). The courts have been ruling on these claims over recent months, and there seems to be a consensus: the claim fails. 

Statistics of the Letter Format/Overshadowing Claim

According to the iA Case Law Tracker, New York courts have ruled 15 times on this claim filed on behalf of the consumer by Barshay Sanders. In all but one decision, the debt collector succeeded on either a motion to dismiss or a motion on the merits. Of these 15 decisions:

• 14 were in New York, 1 was in New Jersey;
• 12 were decided on a motion to dismiss;
• 1 was decided on a motion for judgment on the pleadings; and 
• 2 were decided on motions for summary judgment.

The sole case where the debt collector’s motion to dismiss was denied occurred in New Jersey. In that case, while the first paragraph on the first page of the collection letter contained the validation notice under a large, bold heading (“DEBT VALIDATION NOTICE”), the bottom of the letter pointed to more rights on the back of the page that had second “DEBT VALIDATION NOTICE” heading with nothing underneath. Judge Vasquez found that this could confuse the least sophisticated consumer about whether validation notice on the front of the letter included all of his rights.  

These Claims Routinely Fails in New York

Notably, New York judges have routinely rejected these overshadowing claims every single time when they have come up for a decision. Typically, the claim asserts that the letter’s format—such as the font size, location of the notice of validation rights, the use or lack of transitional language, and so forth—cause the consumer’s validation rights to be overshadowed by the remainder of the letter. The courts have routinely found that the least sophisticated consumer would not be confused about their rights in what is likely a typical letter sent by collection agencies. Usually, the validation rights are in a stand-alone paragraph and in the same font size as the rest of the letter.

The most recent example of this claim failing is from yesterday’s decision in Schik v. Miramed Revenue Grp. In this case, the plaintiff alleged that the letter contains bolded boxes that bring a consumer’s attention to the amount due, request for payment, and where to mail payments. This could, allegedly, cause the least sophisticated consumer to not notice the paragraph containing his validation rights. The letter in question can be found here.

The court was not convinced:

Looking at the Collection Notice in its entirety, the Court strongly disagrees with Plaintiff. Plaintiff argues her rights are difficult to read. However, while the rights are in a smaller typeface than other language in the Collection Notice, they are easy to read. Further, they are the same size as, and located between, other language instructing Plaintiff how to pay, set up a payment plan, or pursue a settlement, casting doubt on Plaintiff’s assertion that they appear boilerplate, like “fine print,” or unimportant. Plaintiff’s assertion that the rights may be overlooked is similarly without merit. They are written in the middle of the page. Other courts have held rights can even be placed on the back of the letter, so long as they are not overshadowed or contradicted by other material. 

(Internal citations omitted.) The court granted the motion to dismiss.

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insideARM Perspective

This type of analysis is crucial when considering litigation defense strategies for FDCPA claims. The iA Case Law Tracker (CLT) makes the task of doing this type of research ridiculously easy—it took me all of about 5 minutes to run a search for these specific claims and read through the decision summaries in the CLT. (This same task would have taken hours using traditional legal research methods.) In addition, the weekly trends and analysis report—available to CLT subscribers only—gives you the first notice when patterns in court decisions like this become apparent. It is an indispensable tool for in-house legal departments and outside counsel defense firms. You can subscribe here.