As we reported here, late last year, the Consumer Financial Protection Bureau (CFPB) signaled that it planned to increase scrutiny of the Buy Now, Pay Later (BNPL) industry and issued its first report about BNPL. Yesterday, the CFPB issued a report exploring the financial profiles of BNPL borrowers. According to the CFPB, on average, BNPL borrowers were much more likely to be highly indebted, revolve on their credit cards, have delinquencies in traditional credit products, have lower credit scores, and use high-interest financial services such as payday, pawn, and overdraft compared to non-BNPL borrowers. However, many of these differences pre-dated borrowers’ BNPL use and the increased availability of BNPL products might offer a less expensive borrowing option for many of these users.

BNPL products are a form of credit that allows a consumer to split a retail transaction into smaller, interest-free installments and repay over time. The typical BNPL structure divides a $50 to $1,000 purchase into four equal installments. While BNPL credit is generally interest free, providers make money by charging fees to both sellers and consumers who don’t pay on time. Launched in the mid-2010s as an alternative form of short-term credit for online retail purchases, BNPL loan usage increased ten-fold during the pandemic. Offerings marketed as BNPL have since grown to include a varied range of credit products, but for purposes of this report, BNPL refers exclusively to zero-interest, pay-in-four (or fewer) installment point of sale loans — the same product parameters that were the focus of the CFPB’s December 2021 BNPL market monitoring orders and subsequent September 2022 report.

For this report, the CFPB used consumer responses to the 2022 Making Ends Meet survey as well as an anonymized sample of credit bureau records. Among other takeaways from the report, the CFPB found:

• On average, 17% of consumers borrowed using BNPL at least once in the prior year. Black, Hispanic and female consumers and those with household income between $20,001-50,000 were significantly more likely to use BNPL products compared to white, non-Hispanic and male consumers, or those with household income below $20,000.

• BNPL borrowers have lower average credit scores than consumers who did not borrow using BNPL. They were also 11 percentage points more likely to have a delinquency of at least 30 days on their consumer report.

• Users of BNPL products exhibit measures of financial distress that are significantly higher than non-users. For example, BNPL borrowers have higher credit card debt and utilization rates, a higher likelihood of having an overdraft, a higher likelihood of revolving on at least one credit card (meaning that they carried over a credit card balance from one billing cycle to the next), and higher utilization rates of alternative financial services that charge high interest rates.

However, the report concluded by noting that the majority of BNPL users have access to traditional credit. In fact, for users with revolving credit card debt where the interest rate starts immediately, credit cards purchases are much more expensive. Zero-interest BNPL loans appear to be a less expensive borrowing option, not the only option for the majority of users.

In the CFPB press release announcing yesterday’s report, Director Chopra’s remarks unmistakably signal his intent to regulate BNPL with the same rigor that he has applied to more traditional products: “Since Buy Now, Pay Later is like other forms of credit, we are working to ensure that borrowers have similar protections and that companies play by similar rules.”

The U.S. Court of Appeals for the Sixth Circuit recently reversed a trial court’s dismissal of a consumer’s federal Fair Debt Collection Practices Act claim, and held that the FDCPA claim actually fell within the statute of limitations.

In so ruling, the Sixth Circuit held that, because the FDCPA creates an independent statute of limitations for each discrete violation of the FDCPA, and even though the alleged FDCPA violation occurred in a collection lawsuit that was filed more than one year before the filing of the FDCPA action, the specific alleged FDCPA violation at issue occurred later in the collection lawsuit and within the FDCPA’s one-year statute of limitation.

A copy of the opinion in Bouye v. Bruce is available at:  Link to Opinion.

The consumer financed a furniture purchase through a retail installment contract (“RIC”). The RIC was sold to a financing company. The consumer defaulted, and the financing company, through its attorney, sued in state court to recover the debt and attorney’s fees.

The RIC attached to the complaint did not establish a transfer to the financing company. The court ordered the financing company to file proof of assignment, and the company filed an updated RIC that listed the previous creditor’s store manager as assigning the debt to the financing company. The trial court then granted the financing company summary judgment, but the state appellate court found that the financing company had not sufficiently demonstrated a valid transfer. The state appellate court remanded the case, and the financing company eventually filed a voluntary dismissal.

Then, 380 days after the financing company originally filed its lawsuit in state court, the consumer sued the financing company’s attorney in federal court under the FDCPA, alleging that the attorney doctored the RIC mid-litigation to make it look like the assignment was proper.

Upon the attorney’s motion, the federal trial court dismissed the complaint as untimely under the FDCPA’s one-year limitations period. The consumer filed a motion for reconsideration, and the attorney filed a motion for attorney’s fees. The trial court denied both motions, and the parties timely appealed.

Meanwhile, the consumer and the financing company entered into a settlement agreement that released the company, later clarifying in an addendum that the company’s attorney was not released. Three months before the court denied the motions for reconsideration and attorney’s fees, the attorney learned of the settlement agreement.

Before the parties briefed the merits of their appeals, the attorney moved to dismiss the consumer’s appeal for lack of jurisdiction based on the settlement agreement. The consumer argued that the attorney had forfeited this argument or, alternatively, that the agreement did not go to the Sixth Circuit’s jurisdiction to hear the case. And, producing the addendum to the agreement as well as the attorney’s employment contract with the financing company, the consumer also argued that the attorney was not an intended third-party beneficiary of the settlement agreement.

The Sixth Circuit denied the attorney’s motion to dismiss the consumer’s appeal, holding that the settlement agreement did not moot the appeal because, in the context of the case, the agreement did not go to the Court’s jurisdiction to hear the case. The Court then allowed the parties to proceed with their briefing on appeal.

The consumer argued that her claim fell within the FDCPA’s one-year statute of limitations. The attorney challenged the consumer’s Article III standing to bring the lawsuit because, according to him, she was only pleading a statutory harm related to the state-court lawsuit and, therefore, could not meet the injury-in-fact requirement. The attorney also argued that the consumer’s claim was time-barred and that she released her claim against him through the settlement agreement.

As you may recall, to establish Article III standing, a plaintiff must have suffered an injury-in-fact that is fairly traceable to the defendant’s conduct and would likely be redressed by a favorable decision from a court. Rice v. Vill. of Johnstown, 30 F.4th 584, 591 (6th Cir. 2022). For the injury-in-fact requirement, a plaintiff’s allegations must establish that she has experienced an injury that is “concrete, particularized, and actual or imminent.” Barber v. Charter Twp. of Springfield, 31 F.4th 382, 390 (6th Cir. 2022).

Here, the Sixth Circuit concluded that the consumer was not merely pleading a statutory violation because she also alleged that she suffered an injury from defending against a state lawsuit that the financing company had no right to bring in the first place. Thus, in the Court’s view, that harm established a concrete injury that met the injury-in-fact requirement. See Hurst v. Caliber Home Loans, Inc., 44 F.4th 418, 423 (6th Cir. 2022).

Regarding the statute of limitations question, the Sixth Circuit noted that every alleged discrete FDCPA violation has its own statute of limitations. Slorp v. Lerner, Sampson & Rothfuss, 587 F. App’x 249, 259 (6th Cir. 2014). “[T]he date on which the violation occurs” determines when the one-year statute of limitations starts running. § 1692k(d).

The Court then found that the consumer’s complaint did allege a timely FDCPA violation: that the attorney filed an updated RIC and moved for summary judgment on that basis, allegedly affirmatively misrepresenting to the trial court that the assignment of the debt occurred before the financing company filed suit against the consumer.

The attorney argued that the alleged FDCPA violation was a continuing effect of the financing company’s initial filing of the state lawsuit and was therefore time-barred because the consumer did not file within a year of the company’s initiation of the state suit. See Slorp, 587 F. App’x at 259.

However, the Sixth Circuit held that the consumer’s single claim was independent of the financing company’s initial filing of the lawsuit — not a continuing effect of it — because it was a standalone FDCPA violation. The allegation was that the consumer introduced an RIC with a false assignment of debt that occurred after the lawsuit was filed. The Court reasoned that if it was only to consider the date the company filed suit, without regard to subsequent FDCPA violations within that lawsuit, it would create a rule that disregards the fact that § 1692k(d) creates an independent statute of limitations for each discrete violation of the FDCPA. See Bender v. Elmore & Throop, P.C., 963 F.3d 403, 407 (4th Cir. 2020).

The attorney also argued that the consumer released her FDCPA claim in the settlement agreement. The Sixth Circuit noted that the attorney first invoked that agreement in support of his jurisdictional argument that the agreement mooted the consumer’s suit. At that time, the Court rejected the attorney’s jurisdictional argument in its earlier order denying the motion to dismiss the appeal.

Nevertheless, the Sixth Circuit remanded this case for the trial court to evaluate in the first instance any merits argument based on the settlement agreement. Additionally, the Court vacated the trial court’s order denying attorney’s fees since the litigation below was allowed to continue.

The Consumer Financial Protection Bureau (CFPB) continues to spread its proverbial wings. This time, in a move that may ultimately affect training, equipment, and supervision of remote employees across the ARM industry, the CFPB is teaming up with the National Labor Relations Board (NLRB). 

Citing an overlap of potentially harmful conduct that may pose risks to consumers and workers, on March 7, 2023, the CFPB announced via press release that it entered into a Memorandum of Understanding (MOU) with the NLRB. The MOU will allow the two agencies to share information without losing confidentiality protections.

The CFPB’s objective is to enhance the enforcement of federal consumer financial protection laws and, specifically, its focus on restoring competition to consumer financial markets. CFPB Director Rohit Chopra stated, “Many workers discover that getting a job can mean piling up debt instead of making a living.” Director Chopra aims to “end debt traps that stop workers from leaving one job for another.”

The CFPB cited two examples of financial dangers faced by working consumers:

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• Employer-driven debt: Accepting a job can place workers in what the CFPB calls a “doom loop of debt.” The CFPB’s position is that taking on personal debt for employer-mandated training or equipment more expensive than equipment on the open market saddles workers with significant debt and discourages them from changing jobs. 

• Employer surveillance and selling personal data: The CFPB noted that surveillance tools, such as those used to track worker productivity, can continue to track people outside of working hours. Further, the companies that own the surveillance tools might sell workers’ data to financial institutions, insurers, and other employers. According to the CFPB, these types of actions may violate the Fair Credit Reporting Act (FCRA) and other consumer financial protection laws. 

The announcement can be found here.

The MOU in its entirety can be found here.

InsideARM Perspective:

The CFPB’s decision to wade into employee relations under the umbrella of consumer protection will undoubtedly be the source of future can they/can’t they debates. Though it’s unclear how the CFPB jumps from protecting consumers to protecting workers, the MOU implies that the CFPB believes it has this authority. As we have learned time and time again over the past few years, if the CFPB believes it can, it will. 

So what does this announcement mean for the ARM industry?

The announcement did not define “significant debt” or explain whether the CFPB considers all costs associated with training or equipment problematic. It likewise did not provide much detail regarding whether surveillance tools or a perceived lack of clarity to employees about those tools amount to potential FCRA violations.  

To ensure they are prepared for the future, though. this may be a good time for ARM entities to look at employee practices through the lens of this announcement. Some questions to ask internally might be: 

• How are your remote employees supervised?
  
• Do tracking programs shut off at the end of the work day?
  
• Does info gathered through surveillance get shared with anyone? 
  
• Are your policies sufficiently documented to show that the goals of protecting consumer data and surveilling employees are met without simultaneously exposing your employees’ personal data?
• Do you pay less for employees in training?
  
• Do you charge employees for any equipment? If so, how does that price compare to a big box store? 
  
• Are policies for charging employees documented to show fairness and justification?

Whether this announcement amounts to anything remains to be seen, however, ARM organizations should continue to pay attention. We will provide updates should the CFPB make future announcements on this topic.

A judge in the U.S. District Court for the Central District of California recently ordered the defendants in CashCall, Inc. (which included CashCall Inc.’s CEO Paul Reddman) to pay $134 million in restitution and $33 million in civil penalties. The decision comes after the Ninth Circuit affirmed the district court’s 2016 award of summary judgment to the CFPB, finding the defendants had violated the Consumer Financial Protection Act [CFPA].  

Specifically, the district court held that the defendants had engaged in deceptive practices by making unsecured high-interest loans to consumers through a tribal lending program in an effort to avoid state usury and licensing laws. The district court held, and the Ninth Circuit agreed, that the attempts to make the loans subject to the law of the Tribe was invalid at inception because “the Tribe had no substantial relationship to the transactions,” thereby subjecting the loans to the laws of the consumer’s resident state. The Ninth Circuit also affirmed the district court’s ruling that CashCall’s CEO was individually liable under the CFPA because he participated directly in and had the ability to control the corporate defendants’ conduct.

On remand from the Ninth Circuit, the district court was instructed to: (1) impose a tier-two civil penalty award (rejecting the initially assessed $10 million tier-one penalty) for every day after the point at which it determined the defendants’ violation was at least reckless; and (2) reconsider the availability of restitution.  Accordingly, the district court performed the same exercise it had when assessing a tier-one penalty (applying the maximum available for each day of violation) by using the maximum tier-two per diem amounts from the date identified and calculated a civil penalty of $33,276,264.  

The district court also held that an award of restitution was appropriate and sufficiently calculable by the evidence the CFPB provided, but declined to award the $197 million in restitution requested by the CFPB.  In so doing, the district court did not allow restitution as to interest and fees for any consumer “who paid CashCall less than the consumer received in principal,” characterizing such restitution as a “windfall” that would “overcompensate them for their loss.”  Over the defendants’ objection, the district court adopted the CFPB’s calculation of restitution, absent such “windfall” interest and fees, and awarded $134,058,600 in restitution.

The defendants also unsuccessfully tried to raise the argument, previously rejected by the Ninth Circuit as untimely raised, that the CFPB’s enforcement action should be enjoined because the agency’s funding contravenes the Constitution’s separation of powers by violating the Appropriations Clause, encouraging the district court to follow the Fifth Circuit’s ruling in Community Financial Services Association of America, Limited v. Consumer Financial Protection Bureau.  

The district court denied the defendants’ request, holding that the Ninth Circuit determined that the constitutional challenge “can be and has been forfeited,” and the law of the case doctrine precluded the district court’s review of the issue. Notwithstanding this determination, the district court went on to posit that, if properly presented with the issue, it would reject the Fifth Circuit’s ruling as inconsistent with “’every other court to consider’ the validity of the CFPB’s statutory funding provisions.”

SACRAMENTO, Calif. — The RMAI Certification Council announces the adoption of version 11.0 of the Receivables Management Certification Program (RMCP) after a lengthy development and review process. Several significant enhancements were added to the program in version 11.0, including:

• Expanding the program to include commercial debt.
• Creating a specialty certification for process servers.
• Requiring a Pre-Certification Audit for debt buyers, collection agencies, and collection law firms that seek initial certification on or after March 1, 2024. Applications received prior to this date will not require a Pre-Certification Audit.

“RMAI is excited to expand our highly respected certification program to include commercial debt,” said Anne Thomas, President of the Receivables Management Association International (RMAI). “The association’s goal has been and continues to be to provide a single compliance footprint from origination through payment, collections, litigation, and account closure.”

“After a decade of protecting the receivables industry and consumers through advancing comprehensive and uniform standards of best practice, it seemed to be an appropriate time to do the same for commercial loans as we launch into our second decade of certification.”

From Version 1.0 to Version 11.0, the program has expanded over the years from 19 standards to 63 standards, and from certifying only debt buyers to certifying debt buyers, collection agencies, law firms, brokers, process servers, and vendors.

For more information on RMAI certification for receivable businesses and individuals, please visit the RMAI website at www.rmaintl.org/certification. For more information on version 11.0, view our program overview.

About Receivables Management Association International

Receivables Management Association International (RMAI) is a nonprofit trade association representing more than 600 businesses that support the purchase, sale, and collection of performing and nonperforming receivables on the secondary market. The RMAI Receivables Management Certification Program and Code of Ethics set the global standard within the receivables industry due to the rigorous uniform standards of best practice which focus on protecting consumers.

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

On February 13, the Second Circuit Court of Appeals affirmed the decision of an Eastern District of New York court and found that the defendant law firm, Mandarich Law Group, LLC (Mandarich), had conducted a meaningful attorney review of the plaintiff debtor’s account prior to mailing her a debt collection letter on the firm’s letterhead. The three-judge panel set forth the decision in a summary order, which does not have precedential effect.

The putative class action arose out of a debt collection letter Mandarich mailed to the plaintiff in March 2019. The plaintiff alleged the letter included language that overshadowed the statutorily-mandated validation notice and falsely represented or implied that an attorney had meaningfully reviewed the letter in violation of multiple provisions of the Fair Debt Collection Practices Act (FDCPA). 

As it relates to the meaningful-attorney-involvement claim, the plaintiff alleged that the use of the firm’s letterhead suggested an attorney was involved in the collection of the debt when in fact no attorney had reviewed the account prior to mailing the letter and the letter did not disclose that no attorney was involved in a review of the account. 

Mandarich moved for summary judgment on all of the plaintiff’s claims, which included the submission of an affidavit from an attorney at the firm that personally reviewed the plaintiff’s account using the firm’s specialized computer platform and in accordance with the firm’s “Attorney Meaningful Involvement Procedure” prior to the mailing of the letter. Through the review process, the attorney concluded that Mandarich’s client owned the plaintiff’s account, that the plaintiff had incurred the debt, that the account did not appear to be the subject of a bankruptcy proceeding, and the debt did not arise out of fraud. The district court granted summary judgment in favor of Mandarich in January 2022 and the plaintiff appealed shortly thereafter.

On appeal, the plaintiff argued that the Mandarich attorney that reviewed her account did not “meaningfully” review it because most of the review was either performed by non-attorneys or was automated. The plaintiff further argued that the entire review process could have taken less than one minute and that the Mandarich attorney did not establish a specific plan to sue in the event the plaintiff failed to pay the debt. The Second Circuit summarily rejected these arguments. 

Following its prior decision in Miller v. Wolpoff & Abramson, L.L.P., 321 F.3d 292 (2d Cir. 2003), the court noted that it never established a specific minimum period of time that is required to constitute meaningful attorney involvement. Nor has the court established a bright-line test to determine whether an attorney was sufficiently involved in the review of an account. Rather, the Second Circuit has directed courts to weigh various factors, including what information was reviewed, the time spent reviewing the file, and whether any legal judgment was involved in the decision to send the collection letters. Under this criteria, the appellate court agreed with the district court and found that the Mandarich attorney had meaningfully reviewed the plaintiff’s account.

LAKE FOREST, Ill. — Transworld Systems Inc. (TSI), the largest provider of analytics and technology-enabled Accounts Receivable Management (ARM) and Customer Experience/Business Process Outsourcing (CX-BPO) in the United States and Canada, announced today that it has received a Training APEX Award from Training Magazine for the third consecutive year. The Training Apex Award recognizes organizations with the most successful learning and development programs worldwide. 

The TSI Training Program was ranked as the second best training and development program globally, and is the only ARM or CX-BPO company to place among the top 10 for the third consecutive year. This achievement highlights TSI’s steadfast dedication to continuous employee learning and development, its agility and innovation in delivering its training via digital engagement, and its passionate commitment to the current and future success of its people. For over 20 years, Training Magazine has recognized organizations that provide best-in-class employee training and development. 

“TSI is proud and honored to be recognized with the APEX Training Award for the third year in a row.  As a business process outsourcing company, TSI’s  ability to develop and retain talent is a differentiator, and it supports our commitment to delivering the best customer experience possible,” said Joseph Laughlin, Chief Executive Officer.

About Transworld Systems Inc.

TSI is the largest technology-enabled provider of Accounts Receivable Management (ARM) and Customer Experience/Business Process Outsourcing (CX-BPO) solutions in the United States. The Company’s solutions include debt collections, customer relationship management, business process outsourcing, and healthcare revenue cycle management. Additionally, TSI owns UAS, a technology-enabled primary loan servicer for student loans. TSI differentiates itself with its collection analytics, digital collections technology, global scale and an industry-leading Compliance Management System. Its clients include Fortune 100 corporations, financial institutions, hospitals, government agencies, property management and small and medium-sized businesses. To learn more, please visit tsico.com.

MADISON, Wis. — On a recent Saturday morning, with the weather wind chill registering a balmy 7 degrees, 15 members of the State team jumped in a Madison, Wis., lake. The team was once again “Freezin’ for a Reason,” raising money for Special Olympics!

Through the generous donations of our team members, clients, and partners as well as a 100% match from State, our team raised nearly $15,000 to support these exceptional athletes. Team Captain Jake Richards challenged the team that he would jump wearing a tutu if we hit our fundraiser goal. We did – so he did! 

State team member, and first-time jumper, Tierra noted that she was jumping in honor of her mother whose life was focused on working with special needs children and adults until she passed a few months ago. Returning jumper Adrienne shared, “I am Polar Plunging in honor of my husband. He has cerebral palsy, so this cause is close to our hearts.”

The team included Tim Haag, State president and Mike Frost, chief compliance officer. Also jumping were Sales Account Executives Bob Lamaster and Phil Rohs. Even the next generation was included as Phil’s son insisted on joining dad the morning of the jump.

About State

State improves the financial picture for healthcare providers by delivering increased financial results while ensuring a positive patient experience. Rooted in a tradition of ethics, integrity and innovation since 1949, State uses data analytics to drive performance and speech analytics with ongoing training to ensure patient satisfaction. A family-owned company now in its third generation of leadership, State assists healthcare organizations with services spanning the complete revenue cycle including Pre-Service Financial Clearance, Early Out Self-Pay Resolution, Insurance Follow-Up and Bad Debt Collection. To learn more visit: www.statecollectionservice.com.

Whether the US economy is currently in a recession or is rapidly approaching one continues to be a debate for economists. Some speculate that we are already in a recession that will end quickly, and in a soft landing. Others think there are much rougher waters ahead. 

Labor market and consumer spending metrics continue to be strong but there were some alarming trends in credit risk in late 2022:

Increased Delinquencies Across Verticals

With the exception of student loans, where delinquencies have been mostly non-existent because of pandemic-era deferral programs, delinquency numbers are trending up. For credit cards, the uptick is 50% year over year, which seems steep. In fact, the rates are creeping up above the average pre-pandemic rates, but they are “still within the pre-pandemic trendlines,” according to 2nd Order Solutions’ 2022 Q4 Credit Risk Review.

Delinquencies on secured loans, like auto and mortgages, are rising slowly, and continue to be below pre-pandemic levels, however, consumers are contending with higher interest rates especially for auto financing. According to the Credit Risk Review, there were a record number of $1,000+ monthly payments for car loans in Q4 2022. 

It’s also concerning that, even though consumers are not dealing with student loan delinquencies, the population of consumers with student loans is experiencing a “stark increase in delinquencies” across other asset classes. With the student loan deferral program set to end in June 2023, it will be critical to monitor how those consumers pay their other debts, like credit cards and auto loans.

Prepayment Rates are Down

Both auto and personal loan prepayment rates are down significantly. For both verticals, lower income consumers and subprime borrowers are showing the largest decline, with rates below pre-pandemic levels.

This is concerning because, according to the Credit Risk Review, prepayment rates are a bellwether of consumer financial health. Not only are the rates down, but they are dropping rapidly. It’s an indicator that, while consumers can currently make their payments as agreed, that may not last long, and could lead to even more delinquencies.

Consumers are Borrowing More

The skyrocketing rise of home values in the last few years led many consumers to leverage their home equity in order to combat inflation and pay down other outstanding balances. In Q3 2022, there were 317.6K HELOC originations. Compare that to Q3 2021, where there were 210.2K HELOC originations. There was also a record rate of card origination volumes in Q4 2022, although the rates fall in line with pre-pandemic trendlines. Consumers are consistently relying more heavily on borrowing than in the last few years, and the increased rate of borrowing is indicative of financial stress for the average consumer.

You can get the full Risk Review from 2nd Order Solutions Here.

How these trends affect collections & recovery isn’t certain, but one thing is clear. If you’re not preparing now for an increase in charged-off collections, you will be caught off guard in the next 12-24 months. Check out our guide to third-party collections here.

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CHICAGO, Ill. –Commercial Collection Agencies of America recently announced that the Independent Standards Board, which creates, renews, and amends the Association’s certification program, has added a new requirement to the certification program effective January 1, 2023.  

Agencies certified by the Association were required to adopt a written information security policy as of the beginning of the year.  The Data Security Standard, put forth by the board, comprehensively enumerates eleven (11) areas of compliance and was introduced early in 2022 to allow agency members time to prepare for the adoption and implementation.  

Each agency member meets the certification requirements annually to earn and maintain a Certificate of Accreditation and Compliance.  The program, considered the platinum standard in the industry, is comprised of the most rigorous requirements across a number of planes.  Although most of the certified agencies of CCA of A already had such a policy in place, the independent board recognized the importance codifying the requirement of securing data held within an agency and formalized it in the already unparalleled program offered by CCA of A. 

“The work of the Standards Board is aimed at ensuring that the CCA of A certification program continues to be the platinum standard. The addition of the Data Security Standard requiring adherence to a written information security policy incorporating best practices further enhances the quality certification program upon which the credit community has come to rely,” commented Standards Board Chair, Christine Hayes Hickey.      

A list of certified agencies can be found at: www.commercialcollectionagenciesofamerica.com.

To contact the Commercial Collection Agencies of America, email Executive Director, Annette M. Waggoner at awaggoner@commercialcollectionagenciesofamerica.com