A process that started seven years ago seems to be nearing its conclusion. Yesterday, the Consumer Financial Protection Bureau (CFPB) posted its Spring 2020 Rulemaking Agenda. Buried under a long list of things on the CFPB’s plate is a note of tremendous importance for the industry: the long-awaited final rule for debt collection is scheduled for release in October 2020.

Interestingly, just last week the CFPB issued a notice in the Federal Register that it will be conducting “cognitive interviews” to test the effectiveness of and validate the performance of the CFPB’s model collection validation notice.

The main goal of the interviews will be to determine how consumers locate and use the information in the notice. The two specific issues the CFPB will focus on are:

(1) Whether the consumer can locate and use important information effectively, such as information about the debt, information about the consumer’s rights, and information about how the consumer may respond if they so choose; and

(2) How consumers view and respond to paper and electronic versions of the model validation notice.

The Federal Register notice did not include the specific model validation disclosure it will be testing, so it’s difficult to tell if it is identical to the model notice from the Notice of Proposed Rulemaking that was issued in May 2019 or if the CFPB made changes to that notice.

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The CPFB is requesting comments on this new round of testing. The comments are due by July 29. The questions to be commented on are those typically included for information collection, such as whether the information is necessary, the burden of collecting the information, ways to enhance the information collection process, and ways to minimize the burdens of the collection process.

insideARM Perspective

Since the cognitive interviews will likely start no earlier than August after comments are submitted, it makes me a little skeptical of the October 2020 final rule release date. This wouldn’t be the first time that some portion of the debt collection rule was delayed. However, I’ll choose to be an optimist. Getting these rules finalized is a great first step for the industry to finally having some modern clarity on what feels like an ancient statute.

Editor’s Note: This article is authored by Joann Needleman, Ann E. Lemmo, Alexander R. Green and originally appeared as an Alert on ClarkHill.com. It isrepublished here with permission.

The Consumer Financial Protection Bureau (CFPB or Bureau) has been a federal agency like no other. Born out of the last financial crisis, the Dodd-Frank Act envisioned the CFPB to be an independent agency, free of “political influence”. Congress thus authorized the CFPB to be led by a single director – as opposed to a board of multiple members – who possessed significant rulemaking and enforcement over 19 consumer protection statutes as well as unfair, deceptive and abusive acts and practices. Its single director structure – only removable for “inefficiency, neglect of duty or malfeasance” – as well as its funding outside the appropriation process, that provoked strong opinions from industry and advocates alike.  

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The Underlying Case

After years of political wrangling, the United States Supreme Court issued its long-awaited decision in the case of Seila Law, LLC v. CFPB. Seila involved a law firm from California that provided debt relief services to consumers. The CFPB served a civil investigation demand (CID) upon the law firm. When the law firm failed to respond to the CID, the CFPB filed a Petition to Enforce the CID in the Federal District Court in California. Seila argued that the CFPB did not have authority to issue the CID because the structure of the CFPB ofa single director who can only be fired for cause by the President, was unconstitutional and violated the separation of powers.

The District Court granted the CFPB’s Petition and rejected Seila’s constitutional argument. Seila appealed to the Ninth Circuit Court of Appeals, which affirmed the lower court’s decision. The CFPB defended its structure in the Ninth Circuit case. Seila, in an unusual move, then petitioned the Supreme Court to review the decision. While this petition was pending, the CFPB changed its longstanding legal position and agreed with the Trump Administration’s Department of Justice (DOJ) that its own structure violated the separation of powers. Due to the change in the CFPB’s position, the underlying parties were no longer adverse and the CFPB appointed outside counsel as amicus curiae. 

The questions presented by the Court were twofold:

1. Whether the vesting of substantial executive authority in the CFPB, an independent agency led by a single director, violates the separation of powers; and
2. If the CFPB is found unconstitutional on the basis of the separation of powers, can 12 U.S.C. § 5491(c)(3) be severed from the Dodd-Frank Act?

Roberts’ Opinion 

Chief Justice John Roberts wrote for the majority who was joined by Justices Alito, Thomas, Gorsuch and Kavanagh. In answering the first question, the majority concluded that the current structure of the CFPB was a violation of the separation of powers and “lacks a foundation in historical practice and clashes with constitutional structure by concentrating power in a unilateral actor insulated from Presidential control”. Article II of the United States Constitution allows the President unrestrictive removal power for members of the executive branch. This include cabinet members and most agency heads. The cases of Humphrey’s Executor v. United States, 295 U.S. 602 (1935) and Morrison v. Olson, 484 U.S. 654 (1988) found that Congress in very limited circumstances could limit the President’s removal power. In Humphrey’s, the Supreme Court found that FTC Commissioners could be removed for cause because they were multimember bodies with quasi-judicial or quasi-legislative functions. The Commissioners were not and did not exercise any executive power. In Morrison, the Court recognized for-cause removal for an independent counsel appointed to investigate and prosecute crimes against government officials. This for-cause exception rested upon the fact that an independent counsel was an inferior officer with limited duties and more policy making or administrative authority. The majority found that the CFPB did not fit into either exception.

Turning to the second question, Dodd-Frank Act states that if “any provision of this Act… is held to be unconstitutional, the remainder of this Act… shall not be affected thereby”. 12 USC § 5302. Despite its constitutional defect, the court did not strike down the agency. However, the Court did remand the case back to the Ninth Circuit to determine whether the CID can still be enforced because it was ratified by then Acting Director, Mick Mulvaney. 

Concurrence and Dissent as to Severability

Justices Thomas and Gorsuch concurred that a Humphrey’s Executor interpretation should be limited to allowing multimember expert agencies that do not wield substantial executive power. 

However, Thomas believes Roberts could have gone further and completely left Humphrey’s Executor in the history books because the Constitution does it state that Congress can delegate legislative power or authorize judicial power outside of Article III. While Thomas believes Roberts could have stamped Humphrey’s Executor as completely irrelevant, he still believes the opinion today effectively curtails the unaccountability of the agencies and hopes that in the future the court will be able to reconsider Humphrey’s Executor in toto.

Thomas dissents from Roberts opinion regarding severability and ratification. Where Roberts leaves readers wondering about the future of the case, Thomas provides a clear solution. Thomas puts forth that the issue of this case could have been simply solved without remand. Thomas argues that ratification and severability are irrelevant when focusing on the constitutional injury of the case – enforcement of a CID by an insulated Director – and attempt to resolve it. 

Thomas believes determining ratification is unnecessary. 

Dissent and Concurrence as to Severability  

Justice Kagan, joined by Justices Ginsburg, Breyer, and Sotomayor, dissented from the majority’s opinion, indicating that they would have upheld the structure of the CFPB to maintain the agency’s independence. In the dissent, the Supreme Court’s block of more-liberal justices explain their belief that Congress is generally free to constrain the President’s power to remove officers in the Executive Branch. While dissenting from the majority’s opinion, the Supreme Court’s block of more-liberal justices concurred in the judgment as it relates to the issue of severability. As explained in the dissent, “[t]he outcome today will not shut down the CFPB: A different majority of this Court, including all those who join this opinion, believes that if the agency’s removal provision is unconstitutional, it should be severed.”

The Future of the CFPB

The legal saga of the CFPB can now best be described as a long road to nowhere. A determination by the Supreme Court of constitutionality is usually a pivotal event in American jurisprudence. The Supreme Court’s holding here was not that moment in history, nor did it put to rest future legal challenges to the Bureau’s authority from all sides. Parties who have current enforcement matters before the Bureau may argue that ratification cannot be the magic wand that can cure a constitutional defect, especially in instances when the Director lacked the authority to act at the time it was initially done. Those financial institutions who agreed to significant consent orders are probably feeling buyer’s remorse. Finally, expect additional legal challenges, beyond what is afforded in the Administrative Procedures Act, for pending rulemakings this year.  

Today’s ruling was not a win for the CFPB either. The stain of a constitutional defect will not be forgotten or go away quietly. As an independent agency, the CFPB was supposed to be apolitical, outside of the influence and policy of the executive branch. Since its inception the Bureau has never operated in that manner. Both the prior administration and the current administration have exerted their influence, their policies and their priorities over the Bureau.  Chief Justice Roberts gave only a tepid nod to Congress to fix the agency and consider a multimember commission. It is doubtful that Congress will take any cues from the Court thus ensuring that the CFPB, no matter what administration it serves, will operate in a partisan manner for many years to come, hurting both industry and consumers.  

This video is part of the iA Think Differently series. Written by or recorded with members of the iA Innovation Council, the series showcases thought leadership in analytics, communications, payments, and compliance technology for the accounts receivable management industry.

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Today I’m talking with Dan Womack, Senior Director of Engineering and Product Management at Ontario Systems, and also a longtime member of the iA Innovation Council. Ontario Systems is one of the largest collections platform providers in the industry. Most likely know them best from FACS and Artiva and The Collection System (TCS). Many also know them because of Rozanne Andersen and their team of compliance specialists who are an integral part of the product development process.

He told me that much of what they’re seeing in the market now isn’t so much ‘thinking differently.’ Dan says what he has seen over the years is that the collection space has been primarily an evolution industry, not a revolution industry. So he is mostly seeing a desire to go faster on things that had already been in the works: different communication channels, different segmentation methods, different automation capabilities, different technologies that can be deployed in automation, and machine learning.

Dan has a pretty big job at a company that is relied on by many in the industry. Listen in to hear what keeps him up at night.

[Editor’s note: If you are interested in topics like strategy, testing, and scenario planning, you should not miss insideARM’s next conference, iA Strategy & Tech – a completely virtual event – July 21-23. It’s a masterclass in collections strategy.] 

Transcript

The iA Innovation Council is a collaborative working group of product, tech, strategy, and operations thought leaders at the forefront of analytics, communications, payments, and compliance technology. Group members meet in person (and lately, virtually) several times each year to engage in substantive dialogue and whiteboard sessions with the creative thinkers behind the latest innovations for the industry, the regulators who audit and establish guardrails for new technology, and educators, entrepreneurs and innovators from outside the industry who inspire different thinking. 

2020 members include:

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WILMINGTON, Del. — Phillips & Cohen Associates, Ltd., the leading specialist recoveries management business servicing creditors in the US, Canada, UK, Ireland, Australia, New Zealand, Spain, Portugal and Germany has announced plans to expand into the servicing of potentially vulnerable consumers. 

The business, which has been consistently recognized for its compassionate engagement model during its 23-year history, is reacting to client demand for this new service alongside increasing market demographic need. For those unfamiliar with the Vulnerable Sector in the UK, regulatory requirements are for organizations to identify consumers whose personal circumstances warrant additional care & to implement specific treatment paths to ensure these consumers are treated fairly.  

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As one of a number of ventures to initiate the service, Phillips & Cohen Associates has been selected by UK Debt solutions provider, TDX Group, to help launch their V+ service, an innovative approach which will seek to combine proactive data analytics and best of breed communication strategies to provide superior levels of service to potentially vulnerable consumers.  PCA were selected because of its long-standing reputation for dealing with consumers in an empathetic & positive manner.

Nick Cherry, Chief Operating Officer added, “As a business, PCA has always prided itself on the ability to engage with consumers at the most sensitive of times.  We believe in treating people with dignity and respect, and this makes dealing with potentially vulnerable consumers a natural extension of our existing niche services.”

Adam S. Cohen, Co-Chairman/CEO commented, “Based on our unique credentials, vulnerability is a market which our clients have been encouraging us to enter for some time and we are gratified to continue to be recognized as a market leader in standards of consumer engagement.  Sadly, the pandemic has impacted more households in all countries than was previously conceivable, and we feel that now is the right time for PCA to help to ensure that families receive the appropriate levels of support which they need to recover.” 

About Phillips & Cohen Associates, Ltd.

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

Yesterday, the U.S. House of Representatives passed H.R.5332, Protecting Your Credit Score Act of 2019, which seeks to help consumers gain easier access to their credit information as well as establish new oversights over credit reporting agencies. The bill, introduced by Rep. Josh Gottheimer (D-NJ-5), would amend the Fair Credit Reporting Act and require the Consumer Financial Protection Bureau (CFPB) to take certain steps in regards to credit reporting agencies.

The summary of the bill provides that it would: 

• Allow consumers to receive their credit score when they request a free annual credit report.
• Direct credit reporting agnecies to create a central online portal where consumers can dispute errors, place or lift security freezes, and access free credit reports and credit scores. 
• Require the CFPB to establish a public registry of credit reporting agencies.
• Require credit reporting agencies to provide available information to consumers about the purpose behind a credit report pull.
• Grant the CFPB statutory authority to supervise credit reporting agencies, establish a credt reporting ombudsman within the CFPB, and establish data security requirements for credit reporting agencies.
• Require the Government Accountability Office to conduct a report on the feasibility of credit reporting agencies replacing Social Security numbers with another type of federal identification.
• Allow courts to award injuctive relief so that they can compel credit reporting agencies to comply with credit report protections.

The bill is now off to the Senate. 

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insideARM Perspective

It’s interesting that we now have a piece of legislation that seeks to establish a registry of credit reporting agencies, as a similar avenue might also be a helpful avenue for debt collection agencies and firms.

In debt collection, one concern that pops up is how to handle fraudsters and scammers, who harm both consumers and legitimate debt collectors that try to be in compliance with laws and regulations. Unforutnately, the scorpion dance of authenticating a consumer on a phone call—which is required by laws and regulations governing prohibitions of third-party disclosure—makes it difficult for consumers to distinguish between legitimate debt collectors and fraudsters. 

A CFPB registry of legitimate debt collectors could solve this problem. Consumers who are uncertain if the company on the phone is a legitimate collector can quickly check the registry to see if the agency is listed for their peace of mind.

This idea has been floating around for a while, and now is as good a time as any to revisit it.

On Thursday of last week, the Attorney General of Washington State filed a lawsuit against Convergent Outsourcing, Inc., which alleges that the debt collector engaged in unfair and/or deceptive practices under the state’s Consumer Protection Act and Collection Agency Act. The allegations revolve around letters sent to consumers for the time-barred debts.

The complaint, which can be found here, alleges that the defendant sent over 75,000 collection letters on time-barred debts that specifcially used the terms “settlement” and “settle.” The letters, the AG claims, did not include a time-barred debt disclosure. 

The reasoning behind the claim is as follows:

Because in common usage, the term “settlement” refers to an agreement to avoid or resolve a lawsuit, Convergent’s practice of offering to “settle” time-barred debts without disclosing that the debts were legally unenforceable had the capacity to deceive consumers into believing they could be sued on the debts if they did not pay, or created that deceptive net impression.

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By including the terms “settlement” and “settle” in the letters without a time-barred debt disclosure, the AG accuses defendant of “impliedly threatening that consumers could be sued if they did not pay.”

The complaint states that 3,000 of the consumers who received the letters sent payments on these accounts. 

insideARM Perspective

This complaint brings to light a certain issue: can debt collectors use the term “settle” on time-barred debt accounts or not? The anwer to this question seems to generally be “no,” but it gets murky when you dig into what the different jurisdictions have to say. We ran a quick search of the iA Case Law Tracker for a deeper dive on this issue (literally took two clicks and a couple minutes of reading to get this info—this tool is awesome). Strap yourselves in, everyone, it’s going to be a wild ride…

Here, the Wash. AG seems to imply that the term “settle” is not appropriate without a time-barred debt disclosure. The 11th Circuit and W.D. Texas seem to agree. 

But would the term “settle” be fine if a time-barred debt disclosure is provided? E.D. Missouri says yes, even if the time-barred debt disclosure doesn’t provide a revival dislcosure. But that calculation gets murky, if you ask D. Maryland, depending on which state’s statute of limitations laws apply, and the answer is not always clear.

And let’s not forget the whole “will not sue” versus “cannot sue” conundrum. D. Utah expressed that providing a settlement offer might be fine with a time-barred debt disclosure, but they said that a time-barred debt disclosure that states “will not sue” could be an FDCPA violation because it implies that not suing is a choice. At the same time, the CFPB’s proposed disclosure from its time-barred debt SNPRM includes the “will not sue” language.

What about if the term “settle” is not used to reference a settlement offer, but instead just informs the consumer that their account “will be considered Settled in Full” after a final payment is processed? C.D. California says that’s fine.

N.D. Alabama kinda agrees with the Wash. AG, but found that the terms “resolve” and “satisfaction” when related to a settlement offer are a-okay. But are those terms okay in other jurisdictions? Who knows.

What a hot mess.

Updated 6/29/2020 at 4:07PM to reflect that the Supreme Court requested the appellate court review whether the government’s petition to enforce the CID should be denied.

The question of whether the Consumer Financial Protection Bureau’s (CFPB) structure is constitutional or not has been floating around the judicial system for a couple of years now. As of today, we finally have an answer. Today, the U.S. Supreme Court (SCOTUS) issued an opinion finding the CFPB’s structure unconstitutional in the Seila v. CFPB.

The main issues raised regarding the constitutionality of the CFPB’s structure revolve around the separation of powers clause. Specifically, the question of whether having a single director removable by the President only for cause is problematic considering the CFPB’s unique independence as a federal agency. SCOTUS decided it was a problem indeed, but one that can be remedied through severability—meaning the rest of the rules surrounding the CFPB’s function and structure can remain intact.

The opinion poignantly concludes:

We therefore hold that the structure of the CFPB violates the separation of powers. We go on to hold that the CFPB Director’s removal protection is severable from the other statutory provisions bearing on the CFPB’s authority. The agency may therefore continue to operate, but its Director, in light of our decision, must be removable by the President at will.

The decision discusses the differences between the Federal Trade Commission, where for-cause removal of commissioners was allowed by SCOTUS in a prior court decision, and the CFPB:

Unlike the New Deal-era FTC upheld there, the CFPB is led by a single Director who cannot be described as a “body of experts” and cannot be considered “non-partisan” in the same sense as a group of officials drawn from both sides of the aisle. Moreover, while the staggered terms of the FTC Commissioners prevented complete turnovers in agency leadership and guaranteed that there would always be some Commissioners who had accrued significant expertise, the CFPB’s single-Director structure and five-year term guarantee abrupt shifts in agency leadership and with it the loss of accumulated expertise.

Specifically regarding the lack of accountability in the single-director structure, the opinion states:

The CFPB’s single-Director structure contravenes this carefully calibrated system by vesting significant governmental power in the hands of a single individual accountable to no one. The Director is neither elected by the people nor meaningfully controlled (through the threat of removal) by someone who is. The Director does not even depend on Congress for annual appropriations. See The Federalist No. 58, at 394 (J. Madison) (describing the “power over the purse” as the “most compleat and effectual weapon” in representing the interests of the people). Yet the Director may unilaterally, without meaningful supervision, issue final regulations, oversee adjudications, set enforcement priorities, initiate prosecutions, and determine what penalties to impose on private parties. With no colleagues to persuade, and no boss or electorate looking over her shoulder, the Director may dictate and enforce policy for a vital segment of the economy affecting millions of Americans.

The Seila case arose from a consumer law firm that received a Civil Investigation Demand (CID) from the CFPB. One of the arguments raised is that Seila’s injury is not traceable to the constitutional defect. The SCOTUS disagreed, and remanded the case with instruction to review whether the Government’s petition to enforce the CID should be denied.

insideARM Perspective

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This is a huge decision. While the fix may seem simple—just change the removal structure—that actual issue is much deeper. Since the CFPB’s CID in Seila is remanded to review whether the CID should be set aside, what happens to all other CIDs that were issued prior to this decision? What about the CFPB’s prior enforcement actions and rulemaking efforts? Seems like the next few months will help us answer the big “what if” question that’s been on our minds ever since the constitutionality issue was first raised.

Despite indicating that it is still set to publish its final debt collection rules sometime this year, the Consumer Financial Protection Bureau (CFPB) published a notice in the Federal Register today that it will do further testing of its model validation notice. This round will including conducting “cognitive interviews to assess the effectiveness and validate the performance of the Bureau’s model collection validation notices.”

The main goal of the interviews will be to determine how consumers locate and use the information in the notice. The two specific issues the CFPB will focus on are:

(1) Whether the consumer can locate and use important information effectively, such as information about the debt, information about the consumer’s rights, and information about how the consumer may respond if they so choose; and

(2) How consumers view and respond to paper and electronic versions of the model validation notice.

Comments Period

The CPFB is requesting comments—due by July 29—on this new round of testing. The questions to be commented on include the typical questions for information collection, such as whether the information is necessary, the burden of collecting the information, ways to enhance the information collection process, and ways to minimize the burdens of the collection process.

insideARM Perspective

Oddly enough, the Federal Register notice does not include the model validation notices to be tested, so it might be presumed that it will be the same model validation notices the CFPB proposed in its Notice of Proposed Rulemaking (NPRM) last year. If that is the case, there are some serious issues to consider, such as those addressed in the Consumer Relations Consortium (CRC) comment to the NRPM.

This is also not the first time the Bureau will be testing the model notice. The CFPB conducted an initial round of testing the model notice prior to the NPRM. There were several issues with that round of testing, which are again outlined in CRC and other industry group comments to the NPRM.

COVID-19 is having a significant negative impact on the accounts receivable management (ARM) industry and is causing some companies to seek other opportunities outside of our typical business model. An excellent example is discussed in Stephanie Eidelman’s recent insideARM article published on May 12, “The U.S. Needs Thousands of Contact Tracers; Know Who is Ideally Suited? You Are.” Hardly a week goes by without seeing articles about the need for large numbers of staff to reach out to potentially exposed persons. Initially, this would appear to be an opportunity. However, the reality is that our industry has been largely ignored.

ARM companies are particularly suited to outbound calling and communicating with potentially exposed persons while notifying confirmed cases and face to face interviews are typically left to healthcare professionals.

Central Research, Inc. (CRI), like other ARM companies, has aggressively pursued contact tracing opportunities with limited success. The CARES Act virtually stopped industry activity for student loans through September 30, 2020. However, some Department of Education private collection agencies (PCA) have pursued other call center work in an effort to retain staff who would otherwise be without work. One PCA found work with a state unemployment department and CRI also briefly performed a call center service for the Small Business Administration. These are but two examples of industry efforts to keep our staff employed.

When it comes to contact tracing opportunities, what we have found is many municipalities, counties, and/or states are simply not aware of our industry expertise in filling these vital roles. We have seen municipalities and counties seeking to hire local unemployed residents as a first option rather than outsource. Some states are repurposing employees, using volunteers, or using an RFP process to select vendors to perform tracing functions. Many recent RFPs require the use of in-state residents, have a local preference, or favor businesses with contact tracing experience. While COVID-19 contact tracing is relatively new, our industry is limited in the required experience when competing against non-ARM companies with experience in contact tracing. These companies have been successful in capturing many of the opportunities.

CRI is still seeking contact tracing opportunities, and a recent acquisition has given us a chance to not only diversify our offerings but offer a unique contact tracing solution. CRI acquired Global Emergency Response, Inc. (GER) in early March 2020, prior to knowing what the COVID-19 impact would be on our population, economy, and the healthcare system. The company’s Disease Surveillance system was designed to be used for monitoring infectious diseases, such as COVID-19, and is also an excellent solution for employee screening and monitoring. This cloud-based software, available via a web interface or mobile application, expands our offering aimed at helping slow the spread of COVID-19.

During the ARM industry COVID-19 slow down, we encourage spending time expanding into other opportunities suited for ARM experience. At CRI, we are continuing to pursue contact tracing and call center work while devoting significant time marketing GER’s solutions for employee screening, monitoring, and contact tracing. Collectively, our industry can perform more outreach to educate municipalities, counties, and states of the value our industry can offer for COVID-19 related requirements.

CEDAR FALLS, Iowa — Tom Penaluna (Chairman and CEO, CBE) announced today that CBE has donated to establish a fund, in conjunction with the Waterloo Community Foundation, to which contributions can be made in support of the Waterloo Police’s efforts to improve race relations in our local community. These funds will be directed towards the City of Waterloo, Iowa with the goal to assist the City in improving race relations between the Police Department and the Black Community. The City of Waterloo’s new Police Chief, Joel Fitzgerald, has proposed sweeping changes to give officers the very important and relevant training needed to perform their duties in the following areas:

• Procedural Justice/Implicit Bias/Reconciliation Training
• Critical Incident Team Training
• De-escalation Instructor Training
• First Line Supervisor Training

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Penaluna commented, “Earlier this week, I shared CBE’s corporate commitment with our staff to do our part and address social injustices and racism. When our leadership team made those commitments, we understood that government leaders, corporate leaders, and other influencers must move beyond just saying politically correct statements and must take actions to address the decades of discrimination that Black Americans have had to face. CBE strongly believes that everyone has a right to live freely without discrimination, and we stand together to make real and lasting change to impact Black lives.  More importantly, we have been listening to those in our local communities on how to best initiate change, and we want to share the initial steps CBE will take toward our commitments. It is our hope that this additional support will lead to improved race relations between the Police Department and Black Community. Our goal is to raise $250,000.00 to assist with this vital community need. We invite other businesses and citizens of Waterloo to join us in donating to the fund. Again, we know these are initial steps and there is so much more listening, understanding, and action that needs to take place for real change to occur. Many Black Lives have been lost needlessly, and it’s up to every one of us to commit, to act, and to create a better future.”

Donation Information

Racial Equality Training Fund
Waterloo Community Foundation
P.O. Box 1253
425 Cedar Street
Waterloo, IA 50704