ATLANTA, GA — FLOCK Specialty Finance announces a strategic investment in technology and human capital related to data-driven insights and innovation.  “Our investment in an analytical platform is foundational to our commitment to provide best-in-class support to our customers and our investors.  The FLOCK analytics platform enables operational efficiencies, improved insights, and opportunities for data-driven innovation.  To support and implement this vision, we have made two new strategic hires,” Michael Flock, Founder and CEO stated.   

• Jennifer Priestley, Ph.D., Chief Data Officer.  Jennifer will have responsibility for the data platform which supports Flock’s business processes, analytics, and market insights.  She will oversee automation of operational processes as well as data security and cybersecurity protocols.  Her background as a Professor of Statistics and Data Science at Kennesaw State University for almost 20 years and developer of the country’s first Ph.D. program in Data Science has made her uniquely qualified to help FLOCK become a leader in translating data into information to drive value.  Prior to her career in academia, Jennifer held positions with VISA EU in London, MasterCard International, and Accenture.   Jennifer holds a B.S. from Georgia Tech, an MBA from Pennsylvania State University, and a Ph.D. in Decision Sciences from Georgia State University.  

• Will Bowers, Senior Data Scientist.  Will has nearly a decade of experience in data science.  His background and proven success in data engineering, analytics and business intelligence will contribute to the successful development of data-driven solutions for underwriting, portfolio management, and internal FLOCK financial processes. He was the Senior Manager of Performance Data and Analytics with Credigy before coming to FLOCK.  He holds a Bachelor of Arts degree from the University of Georgia.

“These strategic investments in our organization allow us to continue to drive value in the marketplace, bring deeper analytical insights, and enrich our customers’ use of capital.  FLOCK intends to become the nerve center of capital, data, and expertise for the middle market of debt buyers.  Our enhanced investment in human capital and in technology is evidence of our strategy,” Michael Flock added.

Please contact Jennifer at jpriestley@flockfinance.com, for information or questions related to Flock Specialty Finance’s data platform.

The U.S. Supreme Court has granted the certiorari petition filed by the CFPB seeking review of the Fifth Circuit panel decision in Community Financial Services Association of America Ltd. v. CFPB.  In that decision, the Fifth Circuit panel held the CFPB’s funding mechanism violates the Appropriations Clause of the U.S. Constitution and, as a remedy for the constitutional violation, vacated the CFPB’s payday lending rule (Rule).  The Court was unwilling, however, to expedite the case and hear it this Term as requested by the CFPB and instead will hear the case next Term.

The Court also denied the cross-petition for certiorari filed by Community Financial Services Association (CFSA) asking the Court to review the alternative grounds for vacating the Rule that the Fifth Circuit rejected.  The Court was also unwilling to add the alternative grounds to the CFPB’s petition as antecedent questions.  CFSA had asked the Court to consider the alternative grounds as antecedent questions as an alternative to granting its cross-petition.  A ruling by the Court in favor of CFSA on one of the alternative grounds might have allowed the Court to avoid reaching the constitutional issue.  

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The sole question presented by the CFPB’s petition is:

“Whether the court of appeals erred in holding that the statute providing funding to the Consumer Financial Protection Bureau (CFPB), 12 U.S.C. 5497, violates the Appropriations Clause, U.S. Const. Art. I, § 9, Cl. 7, and in vacating a regulation promulgated at a time when the CFPB was receiving such funding.”

Thus, by denying CFSA’s cross-petition and also rejecting CFSA’s request to consider the alternative grounds as antecedent questions to the CFPB’s petition, the Supreme Court is poised to decide the Appropriations Clause issue.

While the Court’s decision not to hear the case this Term means the Fifth Circuit decision will continue to be a cloud over all CFPB actions and could slow the pace of enforcement activity (particularly in pending cases where defendants can be expected to assert the Appropriations Clause issue as a defense), we do not expect it to impact the CFPB’s ongoing supervisory activity in any material way or deter Director Chopra from continuing to pursue his aggressive regulatory agenda. 

In collections, the biggest challenge is getting in contact with account holders and setting up a payment agreement to resolve outstanding debt, especially with consumers who have a low propensity to pay. But once the agreement is made, it’s smooth sailing. Right?

Not quite. 

The cost involved with processing payments can be significant for agencies, especially when they are not charging a fee, and if a fee was not expressly authorized in the original agreement that created the debt, it’s difficult to imagine how agencies can reduce costs in a compliant manner. 

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So, what can you do? Can you charge a fee to offset this expense? What about compliance? The best question you can ask yourself is, “do we have the right payment processing partner to help show us the way?”

Fortunately, with the right payment processing partner, the modern iteration of the No-Cost-to-Biller fee model allows agencies to save money on processing fees in a manner compliant with the FDCPA, CFPB, Card Brands, state law, etc.

What is a No-Cost-To-Biller fee model, and how can it help my business?

At a high-level, the No-Cost-To-Biller fee model applies the principal transaction amount to the agency, and with consumer consent, a fee may be assessed by the third-party technology platform which enables the convenience of processing the payment. With the right fintech partner, this model can be deployed in several iterations to fit a merchants payment ecosystem, while ensuring compliance with the appropriate regulations. In all cases, the payment processor collects the principal and uses the model to offset costs.

Where there is a restriction (either due to a state regulation or client restriction), no fee is applied, and the merchant is charged the processing fee directly.

Is it compliant?

Yes, with the correct fee model.

There are several key considerations to ensure compliance, but this model is nuanced and every rule cannot be conveyed in one article. Here are several key principles which need to be embedded in any merchant’s payment ecosystem: 

Consumer Consent

Consumer consent is critical. Agencies are responsible for providing consumers with disclosures that contain the necessary items for compliance. With proper disclosures, an agency can then obtain consumers consent to move forward in the process. It’s also important to ensure the agency does not receive revenue from the fee, but only uses it to offset costs. This has been a hot topic lately, but it has always been a rule for any vendor who has expertise in this field. 

Adherence to Regulations

When reviewing individual states’ statutes, one must recognize where a consumer resides at the time of payment, and adhere to individual state statutes. This can get tricky, as you need to keep in mind fee rules set by the Card Brands do not supersede state law. In fact, all of the salient compliance pillars, i.e. the FDCPA, CFPB, Card Brands, State Law, etc. need to be adhered to in every transaction.  All of these items (and more) need to be integrated into your authoritative database so rules are followed programmatically.

There is a lot of nuance involved with employing a No-Cost-To-Biller fee model. The best way for debt collectors to ensure compliance while offsetting costs is to find a payment processor who has done their legal due diligence, is able to provide guidance on the subject and is a true expert in this area. 

To learn more about how to stay compliant with the law, watch our one-hour webinar: Breaking Down the CFPB’s Opinion on Convenience Fees, featuring experts Rick Perr (Co-Managing Partner, Philadelphia, Kaufman Dolowich & Voluck LLP) and Rob Kennedy (Vice President of Sales, North America, Nuvei).

In a recent decision, a Michigan district court found that because there was a genuine issue of fact as to whether the defendant debt collector notified the consumer reporting agency (CRA) to remove a disputed debt notification from the plaintiff’s tradeline, the case could proceed to trial.

In Evans v. Merchants and Medical Credit Corp., the plaintiff received a letter from the defendant attempting to collect on an unpaid debt. The plaintiff provided notice to the defendant that the debt was disputed. The following year, when the plaintiff attempted to obtain a home equity loan the dispute flag on her consumer report caused her application to be denied. The plaintiff’s attorney then informed the defendant that the plaintiff no longer disputed the account.

The defendant removed the dispute flag from the plaintiff’s account in its system, but the debt continued to be reported as disputed by the CRA. The CRA’s records showed that it had not received a request from the defendant to remove the code from the tradeline.

The plaintiff filed a lawsuit against the defendant in the District Court for the Eastern District of Michigan, alleging violations of the Fair Debt Collection Practices Act (FDCPA), and other state statutory claims.

The plaintiff filed for summary judgment, and the defendant counter-filed a motion to dismiss or, in the alternative, for summary judgment. Because the court found that there was a genuine issue of fact as to whether the defendant notified the CRA to remove the dispute notification, the court denied both motions, finding that “both sides have offered sufficient evidence upon which a reasonable jury could find in their favor.” The court went on, “whether [the defendant’s] procedures are reasonably adapted to avoid the error that occurred here is a question of fact for the jury to decide.”

The defendant also argued that the plaintiff lacked standing to sue; however, the court found that the denial of her home equity loan application was a sufficient injury to confer standing.

The FTC recently sent its annual letter to the CFPB reporting on the FTC’s activities related to the Equal Credit Opportunity Act (ECOA) and Regulation B.  The new letter reports on the FTC’s activities in 2022.  The Bureau includes the FTC’s annual letter in its own annual report to Congress on the ECOA.

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The FTC has authority to enforce the ECOA and Regulation B with respect to nonbank financial service providers within its jurisdiction.  The letter notes that, consistent with the Dodd-Frank Act, the FTC continues to coordinate certain ECOA enforcement and other activities with the CFPB pursuant to a memorandum of understanding with the Bureau.

With regard to fair lending enforcement, the letter highlights the settlements in two FTC enforcement actions against two groups of auto dealerships, Passport Automotive Group and Napleton Auto Group, in which the FTC alleged the dealerships violated the ECOA and Regulation B by discriminating against Black consumers (and, in the case of Passport, also Latino consumers), charging them higher financing costs and fees.  The FTC’s lawsuit against Napleton was filed jointly with the Illinois Attorney General.  In its lawsuit against Passport, the FTC alleged that the alleged discriminatory conduct also constituted unfair discrimination in violation of Section 5 of the FTC Act.

With regard to fair lending research and policy development, the letter discusses (1) a report to Congress issued by the FTC in 2022 that discussed risks arising from the use of artificial intelligence by big tech platforms and other users, including the risk that AI can result in discrimination against protected classes of individuals; (2) a conference co-hosted by the FTC in 2022 that included a discussion on designing compensation in the auto loan market and concerns arising from discretionary markups; (3) the FTC staff’s continuation of its work as a liaison to the American Bar Association’s Standing Committee on Legal Assistance for Military Personnel which supports initiatives to deliver legal assistance and services to servicemembers, veterans, and their families, and (4) the FTC’s continuation of its (a) service as a member of the Interagency Task Force on Fair Lending along with the CFPB, DOJ, HUD and the federal banking agencies, and (b) participation in the Interagency Fair Lending Methodologies Working Group which consists of staff members from the FTC, CFPB, DOJ, HUD, federal banking agencies, and the Federal Housing Finance Agency.

With regard to fair lending consumer and business education, the letter discusses the FTC’s “efforts to provide education on significant issues to which Regulation B pertains.”  The efforts described consist of guidance for consumers on credit discrimination, data released by the FTC on harm to people living in majority Black communities arising from fraud and other consumer problems, alerts to consumers about the 2022 auto dealer enforcement cases, and guidance to business on the settlements in those cases.

DENVER, Colo. — Harvest Strategy Group, Inc. (Harvest) announces the addition of Marc Savage to its Board of Directors.  

“We are excited to have Marc join our board.  Marc’s deep knowledge of technology and diverse background gives him great insights into strategic solutions,” said Harvest President & CEO Brad McCurnin.  “His role on the Harvest board supports our long-term technology roadmap.” 

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Savage brings over 25 years of technology management experience and will further support Harvest’s direction of being a leader in technology for compliance, reporting, and operational efficiencies.  Savage has a long history of serving the technology needs of the accounts receivable management industry and is the founder and CEO of Emprise Technologies, a Toledo, OH based technology company.  

“I am excited to serve the Harvest organization in this capacity.  Harvest has a long history of innovation and growth, and I look forward to contributing to that continued success,” said Savage.  

“The importance of technology in service delivery cannot be overstated.  Marc’s experience strengthens our board in this important area.” reports Martin Ravin, Executive Chairman.

About Harvest Strategy Group

Harvest Strategy Group, Inc. (Harvest) is a recognized leader in national accounts receivable management services, delivering best-in-class results for the nation’s largest banks, finance companies and credit unions. Harvest’s mission is to execute custom recovery programs on behalf of its clients to maximize revenue, while protecting their brand with proven regulatory compliance and vendor oversight processes. Harvest’s leading recovery performance is fueled by ProScoreTM, its proprietary portfolio scoring and segmentation model. For more information, visit www.harveststrategygroup.com or call (303) 531-0631.

The New York Department of Financial Services and the New York City Department of Consumer and Worker Protection are simultaneously engaged in amending their consumer debt collection rules. While the DFS rulemaking has been underway for nearly two years, the DCWP began its efforts last fall.

The DFS amendments would be a significant overhaul of its existing regulations and would cover new debt types. And, any time coverage of debt types is expanded, the scope of covered persons can increase. An unexpected twist in New York City’s proposal is the elimination of creditors from its coverage.

Both would introduce new disclosure requirements and additional restrictions on communications – particularly electronic communications.

The DFS proposed amendments are available here. The DCWP proposed amendments are here.

Final Amendments May Be Different

Both agencies have only proposed amendments. The comment period on the DFS amendments is still underway, while comments and a public hearing on the DCWP amendments were completed last December. It could be months before we see a final rule from either agency, and either may make significant changes to what we have today. To be sure, DFS first proposed its amendments in 2021 and has made significant changes to arrive at the current version released in December 2022.

Effective Dates

As to the effective date of the amendments, it depends on when the agencies publish their final rule amendments. DFS is proposing 180 days following the adoption of its amendments. Since DFS typically conducts a thorough review of submitted comments, the earliest I would expect publication of their amendments is mid-March, meaning that whatever is finally adopted would not be effective, at the earliest, until sometime in September. My guess is that it will take a bit longer for DFS to finalize its amendments.

DCWP could provide little more than 30 days before its amendments take effect. At the earliest, we could see the final amendments sometime later this month or mid-March.

Here is a look at some of the most significant amendments.

Covered Debt — DFS Adds Medical Debt, Sale Of Goods, Judgments  

First, both regulations remain limited to consumer debt, which is incurred primarily for personal, family, or household purposes. DFS’ existing regulation covers debt “wherein credit has been extended to a consumer.” The proposed amendment would strike this limitation. Existing DFS regulations exclude most debt arising out “of a transaction wherein credit has been provided by a seller of goods or services . . .” and the amendment would strike this exclusion too. The result of these changes would be to capture medical debt and indirect motor vehicle loans, among other debt types.

Another material change proposed by DFS is to include judgments within covered debt.

I expect these proposals will be part of the final amendments.

Covered Persons — DCWP’s
Creditor Exclusion, Potential Creditor Inclusion Under DFS Tighter Attorney
Regulation

At least a dozen other states and locales (including New York City and New York State) include creditors within their debt collection laws or regulations. New York City proposes to exclude creditors which bucks the trend seen in other locales, like the District of Columbia. Effective Jan. 1, DC’s debt collection law was expanded to include more types of creditors (“first party collectors”), even those collecting their own “past due” debt. DCWP’s proposed creditor exclusion would be the first time I can recall any covered entity being removed from a debt collection regulation. You would have expected consumer advocates to push back. In 2014, the National Consumer Law Center submitted comments to the Consumer Financial Protection Bureau, urging it to include first-party collectors within certain provisions of Regulation F.  Surprisingly, comments from the National Consumer Law Center to DCWP had no objection to the creditor exclusion, nor did comments from several other consumer advocacy groups. I expect the creditor exclusion to remain in the DCWP final amendments.

Both DCWP and DFS propose amendments that tighten regulation over attorneys collecting debt, a trend observed in recent activity in both the District of Columbia and California.

DFS also proposes amendments that might capture creditors who acquire portfolios of debt containing non-performing loans. While I do not believe this was intended, the troublesome language has not changed since DFS first proposed it in 2021.

Initial Disclosures

DFS overhauls its requirements for initial disclosures and expressly provides they must be delivered “in writing” and prohibits electronic delivery. DCWP also makes slight revisions to its initial disclosure requirements to better align with DFS’ proposed amendments and federal law. As to electronic delivery of the initial disclosures, DCWP proposes that it can be made “in accordance with § 5.77(b)(5).” However, proposed § 5.77(b)(5)(i) requires that a debt collector “must provide a written validation notice to the consumer … prior to contacting a consumer by electronic communication.”

DFS also proposes that its initial disclosures provide “instructions on how to dispute the validity of the debt.” There are innumerable ways a consumer could dispute a debt under both the proposed DFS regulations and federal law, making this requirement nonsensical and dangerous for both debt collectors and consumers.

Verification/Substantiation

One of the most significant proposed amendments by DFS is to trigger a debt collector’s requirement to provide verification (or “substantiation” as DFS calls it) in response to a dispute, regardless of whether that dispute is made verbally or in writing. It also shortens the time to provide substantiation from 60 to 45 days. Specifically, DFS’ proposed language triggers substantiation when a debtor disputes “the validity of a debt or the right of the debt collector to collect on a debt.” The inclusion of “right to collect” here is at odds with the proposed initial disclosure requirement of informing a consumer only how they can “dispute the validity of debt” noted above.

DFS’ proposal also allows a triggering dispute to occur at any time but limits the debt collector’s duty to substantiate to “only once during the period that the debt collector owns or has the right to collect the debt.”

The DFS proposal is a significant departure from its existing rule and the requirements imposed on debt collectors under the federal Fair Debt Collection Practices Act.

For debts that cannot be verified “within 30 days of receiving the dispute or a request,” the DCWP proposal would require a debt collector to provide a consumer with an “Unverified Debt Notice” stating that “the debt collector is unable to verify the debt and will stop collecting on the debt, and provide the reason that the debt could not be verified.”

Communication Restrictions — NYC’s Extraordinary Communication Cap Proposal

Both agencies propose significant restrictions on electronic communications and DFS expressly requires consumers to opt-in, in writing, before a debt collector makes an electronic communication. DFS proposes that the opt-in take the form of “revocable consent in writing.” 

The proposals from DCWP go even further. The New York City agency proposes to limit all communications and attempted communications (like limited content messages) to no more than “three times during a seven-consecutive-calendar-day period, or once within such period after having had an exchange with the consumer in any medium in connection with the collection of such debt.” This cap is not limited to telephone calls but includes letters and any other communication “medium.” What DCWP intends to cover by referencing “an exchange” is unclear. On the flip side, DCWP proposes to exclude from this cap “any communication, attempted communication or exchange between a consumer and the debt collector which is initiated by or at the request of a consumer or in response to a communication from the consumer, or any communication which is required by law.” Again, the meaning of “exchange” is unclear.

It is also unclear whether DCWP intends the cap to be per consumer or per debt. In other words, it is not clear whether a debt collector having multiple debts to collect from the same consumer is limited to communicating three times during the seven-day period as to all debts. Some commentators suggested that DCWP’s cap could be interpreted as restricting three communications each week to each medium – meaning, three phone calls, three letters and three emails, for example. That sounds like a strained interpretation, and I expect DCWP to address these issues in its final rule.  

DFS does not propose a hard cap on communications but will continue prohibiting excessive communications. It does propose a presumption of compliance with telephone calls if the calls are limited to “one completed telephone call and three attempted telephone calls per seven-day period per alleged debt.” It would exclude telephone calls required by DFS rules or other law, “or when such communication is made in response to the consumer’s request to be contacted …”

“Time-Barred” Debt

Both proposals revise existing “time-barred” debt disclosures to align with recent changes in New York law. Both propose the new disclosures be made in all communications to collect time-barred debt.

While neither prohibits communicating with a consumer orally or in writing to collect such debt, DFS added a prohibition against collecting time-barred debt “exclusively by telephone or by other means of oral communication.” As DFS explained in an “Assessment of Public Comment,” this would “not bar oral or phone communication entirely.”

No Private Right of Action

Neither regulation has a private right of action, and none are proposed.

ARM Industry Response

Industry trade associations composed of the Receivables Management Association International, ACA International, the New York Creditors Bar, and the New York Collectors Association have engaged DFS on its proposals since 2021 and continue to do so with their written comments to be delivered soon. The same trade associations provided testimony at the Dec. 19, 2022, DCWP hearing.

Seven Points to Remember

1. There are no final amendments from either agency.

2. If or when the agencies will publish final rules is unknown.

3. Both regulations propose greater restrictions on consumer debt collection communications than existing law.

4. Neither contains a private right of action.

5. New York City may exclude creditors, but certain creditors may be pulled into DFS’ regulations if they acquire portfolios of consumer debt.

6. If the DFS proposals are adopted in their present form, third-party debt collectors and debt buyers collecting consumer debt in New York State:
   
   –  will need a top-down reassessment of their existing collection operations to comply with the amendments; and

   –  may find it difficult, if not impossible, to use Regulation F’s Model Validation Notice.

7. If both DFS and DCWP amendments are adopted largely as proposed, covered entities collecting debt in New York City will need to marry their operations to the two regulations, and sort out the several conflicts between the two. DFS proposes that local laws (like DCWP’s) are effective if such law provides “greater protection” than DFS’ regulations. Particularly, New York City would have additional disclosure requirements and introduces different restrictions on debt collection communications.

This is not an exhaustive outline of all the revisions contained in both proposals, and there are plenty more than written about here. After all, these are just proposals, and the final amendments are yet to be published.

The New York Department of Financial Services (NY DFS) has continued its years-long process to update its debt collection regulations. According to the Consumer Relations Consortium (CRC), however, the current version of the proposal conflicts with existing law, oversimplifies the statute of limitations, and harms consumers by depriving them of their preferred communication channel and prohibiting the use of the charge-off date on certain types of accounts. 

The NY DFS originally proposed amendments to the debt collection regulations in late 2021. In February 2022, the CRC submitted a comment addressing the issues with the proposal, and in late December 2022, the NY DFS released an updated proposal. 

To highlight the unintended consequences of the updated proposal, on February 13, 2023, the CRC submitted a comment prepared by Legal Advisory Board members John Rossman of Moss and Barnett and Abigail Pressler of Ballard Spahr. CRC member, Kelly Knepper-Stephens of TrueAccord also contributed. 

The CRC’s comment raised the following concerns:

Conflict with existing law

the ADA- compliant letter format included in the proposed amendment conflicts with existing New York Law. Specifically, the proposed regulations require debt collectors to provide notice in a format requested by the consumer. However, a separate New York law (NY GBL 601-b) requires the consumer may request certain notices in a reasonably accommodating format selected by the principal creditor or debt collector. The CRC recommended that the NY DFS address this conflict in future updates to the proposal. 

The Statute of Limitations is complex

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If left unchanged, the proposed amendment would require debt collectors to advise consumers of “the applicable statute of limitations for the debt, expressed in years.” The CRC pointed out that this is a legal question that requires contract review and conflict of law analysis to determine at the individual account level. The CRC then referred NY DFS to a study by the Consumer Financial Protection Bureau (CFPB) that suggested an alternative statute of limitations disclosure; one which does not require legal analysis on every account. 

Prohibiting use of charge-off date harms consumers 

Though the current version of the New York debt collection regulations require debt collectors to provide debt itemization “as of charge-off” the proposed amendment limits the use of the charge-off date only to revolving or open-end credit accounts. For all other types of accounts, collectors would be required to use the last payment date if it is available. In its comment, the CRC explained that charge-off date is the best option for consumers because it is a static, well-defined date, and is more recent than the last transaction. Further, because this proposal is in direct conflict with Regulation F and with the current rule, there is an increased risk of consumer confusion. 

Digital communications limits harm consumers

The current iteration of the proposed amendment restricts digital communication methods. In its comment, the CRC described why these types of restrictions harm consumers.  The CRC explained that Digital communications channels increase consumer protection. Email addresses are not reassigned, therefore using email has far less risk of third-party disclosure. Digital communications are written, documented, and can be searched, ensuring consumers have records of all their communications regarding the debt. Further, the more channels available to reach consumers, the greater the likelihood they will receive crucial disclosures. 

Most importantly, consumer behavior indicates they want to communicate via digital channels. They want consistency and they want to be able to communicate in the same manner which they did with the creditor. Restricting electronic communication means there is no “easy path” for those who want to take care of their debt; they will always, at some point, need to get on the phone with someone. This prevents consumers from resolving their debts early and leads directly to credit score degradation and increased litigation. 

The CRC’s full comment can be found here. 

About the Consumer Relations Consortium 

The Consumer Relations Consortium (CRC) is an organization comprised of more than 60 national companies representing the diverse ecosystem of debt collection including creditors, data/technology providers and compliance-oriented debt collectors that are larger market participants. Established in 2013, CRC is evolving the debt collection paradigm by engaging stakeholders—including consumer advocates, Federal and State regulators, academic and industry thought leaders, creditors and debt collectors—and challenging them to move beyond talking points and focus on fashioning real-world solutions that actually improve the consumer experience. CRC’s collaborative and candid approach is unique in the market.  CRC is managed by The iA Institute.

About the Legal Advisory Board

The Legal Advisory Board (LAB) is an exclusive membership group of outside counsel with expertise in the accounts receivable industry who have each pledged their time and resources to support the mission of the CRC. The LAB is limited to ten law firms and is comprised of fourteen total attorneys. Throughout the year, the LAB serves as a legal resource to the CRC membership and assists in fulfilling the mission of promoting forward-thinking approaches to the issues raised by regulatory policy and technology innovation in the accounts receivable industry.