This article is part of the iA Think Differently series. Written by 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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It is undeniable that the world has changed in the last 40 years. That is, with the exception of the Fair Debt Collection Practices Act (FDCPA). Enacted in 1978 — and not updated since — the law mentions telegrams and came about decades before mobile phones, email, or the Internet. As a result, just like the law, much of the collection industry also remains stuck in the last century. It is time to catch up. Consumers are no longer reachable by snail mail or landlines. We all know this but what can we do about it?

The consumer you are trying to reach has gone digital, and the industry needs to follow. While there is still hope that a final rule from the Consumer Financial Protection Bureau (CFPB) will allow for text messages and email to consumers, this is just one piece of a digital strategy. There are many other things to do that do not put you at risk if you start thinking about a holistic digital strategy now. 

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The collection industry actually has an advantage.

Consider the amount of technological development over the past 40 years since the FDCPA was passed. While other industries spent the last 40 years attempting to find the best practices with developing technology, the collection industry can now take a giant leap forward by employing what those industries have learned through trial and error. This permits a collection agency to take a fully holistic approach to its digital strategy.

The primary objective of a collection agency is to recover funds owed by a consumer. The first milestone of that goal is to communicate with the consumer. According to the TransUnion Aite Group Report, The State of Third-Party Collections, 58% of survey respondents believe it is more difficult to contact consumers today than it was five years ago. They also state that “Getting consumers to respond is perhaps the biggest challenge in the industry today.” As you plan your future strategy, ask yourself the questions below.

1. Are you providing all of the preferred methods of communication?

Communication with the consumer can occur in two ways, inbound or outbound. We all know that inbound communication has the greatest chance of achieving the overall goal of collecting payment because the consumer is engaged. Until there are safer methods than a written letter sent through the US Postal service, a letter is still the primary method of generating inbound communication. 88% of respondents in the TransUnion Study mail a letter when the account is placed. Certainly, your phone number is on this letter, but how many calls do you get from a g-notice? Consumers have gone digital. They will rarely call you to have a conversation that is likely to be embarrassing for them. They prefer the more anonymous communication methods of text, email, or webchat. Do you provide them with those opportunities?

While a g-notice may prompt a few payments, it typically requires the consumer to write a check and mail it to you. Have you provided the consumer with their preferred method of payment? Some consumers prefer an automated telephone payment through an IVR, others prefer payment via the Internet at a payment portal. Some may have a question and want to interact with a chatbot on your website. What if they don’t recognize the debt? From the first communication, they should be able to find your website, read about your company, dispute or pay the debt, register their communication preference by text, email or phone, and provide consent – which you then record and keep on file.

2. What is the quality of your user experience?

All of these methods relate to a full digital strategy focused on the user experience. It offers every conceivable method of payment and the possibility to communicate in whatever channel the consumer prefers. As you might imagine, the heart of your digital strategy for collections will be your website and directing traffic there will be the goal of your communications strategy regardless of the method of communication. Voicemail, voicemail drop, email, text message, limited content message, private LinkedIn or Facebook message: the options for communication with consumers will continue to grow. The strategy, however, will be the same. You need to generate an inbound communication from an engaged consumer. Generally speaking, your website will be the easiest method for the consumer to gather more information in a safe, non-confrontational way.

If the consumer is ready to pay without questions or objections, the communication needs to offer all methods of making a payment that your digital strategy can offer. Consumers have many different preferences to make a payment: IVR, payment portal, chatbot, text payment, etc. None of these methods need to involve one of your employees. These methods are therefore the most financially effective methods of collecting. Your website can be the hub to funnel the user to their preferred method of communication and payment. For text messages, calls to a cell phone or even email, you should be tracking consent to communicate for each particular method. This can be handled easily by your website. Disputes? The website should also allow a consumer to register a dispute and provide reasons for the dispute. It can also function as entry to a payment portal, link a cell phone to an IVR for payment, provide a link to speak to “customer service” or allow the consumer to provide you with a cell number or email for a message back. If your collectors use a chat function on your website, the consumers can ask questions, provide consent, pay their bill or dispute a charge.

A holistic approach to a digital strategy can open a multitude of opportunities for a consumer to make a payment. All of them are easier and less expensive than actually reaching a consumer on their landline. And, the consumers prefer it!

3. Are you sending the wrong message to the wrong audience?

After review of several hundred collection agency websites, it appears that the majority of the sites are not mobile-first, offer no assistance to the consumer, and probably confuse them by marketing their services to attract new clients. That is the wrong message to the wrong audience. There is a wealth of free information available about how to design your website to provide a successful user experience. The easier it is for a consumer to pay, the much more likely it is that they will pay. It is time to embrace a holistic digital strategy and to approach the strategy with a “user experience” perspective. No need to wait on the final rule to roll out a digital strategy. Just add to your strategy once it does come out.

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Matthew Snedden is Chief Operating Officer of PDC Flow, part of the Beyond Investments, Inc. family of companies, and a member of the iA Innovation Council. 

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About the iA Innovation Council

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 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:

Rochester, N.Y. –- Continental Service Group, Inc., d/b/a ConServe, Jeans for Charity Program achieves a milestone in January, surpassing $1,000,000 in charitable giving to non-profits since the program’s inception.  ConServe launched the program in 2007 to make a difference in the community by assisting health and human services, educational, diversity, civic and economic development, and cultural organizations. Good corporate citizenship is at the core of ConServe’s mission statement, of which “helping to improve the human condition” is an integral part of their success.

ConServe hosted a special recognition event on February 5, 2020, bringing together their employees and members of the community to share in this celebratory milestone.  Perinton Ambulance was one of the Jeans for Charity Program recipients in January and their President, Jon LeRoy also attended this special event. ConServe’s gift to Perinton Ambulance was the donation that lead ConServe to $1M in charitable giving.  Goodwill of the Finger Lakes and Hillside Children’s Foundation also participated in the celebration and have also been past recipients of the Jeans for Charity Program.

“2020 commemorates yet another milestone,” said Mark E. Davitt, ConServe Chief Executive Officer and Jeans for Charity Founder.  In 2014, Mark was so inspired by the generosity of his employees that he decided to enhance the program to introduce, ConServe Matching Gift Program, which matches employee’s monthly contributions to the Jeans for Charity Program.  Mark Davitt said, “We practice what we preach; doing the right thing, at the right time, the right way.  ConServe is steadfast in partnering with our Clients, employees, vendors and community as a whole to foster financial freedom, creating positive change and to make a difference.”  

ConServe plans to continue the program and is proud of its employees and the contributions this program has made in the community. 

About ConServe

ConServe is a top-performing and award-winning provider of accounts receivable management services specializing in customized recovery solutions for our Clients. Anchored in ethics and compliance and steadfast in our pursuit of excellence, we are a consumer-centric organization that operates as an extension of our Clients’ valued brands.  For over 35 years, we have partnered with our Clients to provide unmatched customer service while simultaneously helping them achieve their accounts receivable management goals.  Visit ConServe online at: www.conserve-arm.com

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About ConServe’s Jeans For Charity Program

ConServe’s Jeans For Charity initiative began in 2008 when their employees had an idea to launch a program that would provide a way of giving back to their communities.  ConServe employees can participate in monthly charitable donations, benefitting a wide-range of not-for-profits (501-C-3) organizations, in exchange for having the option of dressing down and wearing jeans to work for the entire month. The funds raised by the employees’ generosity are supplemented by the organization’s Matching Gift Program – symbolizing ConServe’s commitment to good corporate citizenship. This ongoing initiative is just one of the ways in which ConServe supports varied and diverse community agencies. To date, the program has donated over $1,011.037 to local community organizations.  

About the Perinton Ambulance

The Perinton Ambulance is known as a “combination service,” utilizing volunteers and hourly personnel to maintain the staffing necessary to meet the service needs of the community. Every day, they have two full crews on duty around the clock and staff an additional ambulance during high volume hours. The remaining vehicles are staffed as the needs of the community dictate.

Visit them online:  www.perintonambulance.org

The Consumer Financial Protection Bureau’s (CFPB) structure has seen many challenges in the past couple of years. The highest-profile item is the pending U.S. Supreme Court review of the CFPB’s single-director structure where the director may only be removed by the President for cause. The CFPB’s financial independece—specifically, it’s ability to set its own budget and get funding directly from the Federal Reserve System—is another often-challenged item, most recently in the President’s 2021 proposed budget.

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President Donald Trump released his proposed budget yesterday, calling for the CFPB to be subject to the appropriations process. What does that mean? In the separation of powers of the U.S. government, Congress traditionally has the “power of the purse.” This means that Congress generally controls where the government’s money goes through an appropriations process. When the CFPB was created, it was designed to circumvent the appropriations process so that it can be “independent” of bipartisan politics. If the President’s proposal were to go through, the CFPB would need to seek funding from Congress rather than directly from the Fed.

The President has proposed a similar structural change in the past, but it never came to be. Chances are slim that it would make it through this time around.

GENESEO, N.Y. — Coast Professional, Inc. (Coast) has hired Brad Rounding as Information Security Officer. He will be working closely with both the IT and Compliance Departments in the Geneseo office. This hire is a direct result of the company’s significant growth over the past year.  

Brad is a Certified Information Systems Security Professional (CISSP) with over 15 years of industry experience. He will be responsible for the evaluation, selection, and implementation of Coast’s new information and device security products. Brad possesses an in-depth knowledge of network security best practices and protocols and will oversee the continued compliance with regulatory and certification requirements.

“Brad has extensive knowledge and experience in every aspect of this field, including security engineering and security incident response,” said Annmarie Buchanan, Chief Information Officer. “His skills align perfectly with Coast’s overall vision and strategic goals. He will bring immense value to Coast and I’m excited to welcome him to our ever-growing team.”

Brad received his bachelor’s degree in information technology from RIT (Rochester Institute of Technology), and his master’s degree in network security from Capitol College. 

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About Coast Professional, Inc.:

Coast Professional, Inc. is an accounts receivable management company, dedicated to the respectful and ethical collection of higher education and government debt. Coast provides professional collection services to over 200 campus-based colleges, universities, and government clients. Coast is a six-time honoree on the Inc. 5000 list for American’s Fastest-Growing Private Companies provided by Inc. Magazine and in 2019, was recognized for the fourth time as one of the “Best Places to Work In Collections” by insideARM.com and Best Companies Group. Since 1976, Coast has worked closely with clients to increase recoveries by assisting consumers in resolving their financial obligations. Coast’s success is exemplified by exceptional recoveries, superior service, and dedication to the highest levels of compliance. More information about Coast can be found at www.coastprofessional.com.

LOWELL, Mass. — Fonative, the Compliant Communications™ company, today announced the live customer deployment of its Trusted Entity Calling solution by a Fonative customer, Ontario Systems, a leading provider of receivables management software to healthcare providers, ARM agencies, and government collections departments. This solution is powered by Numeracle™, the pioneer of robocall blocking and labeling visibility in the calling ecosystem.

“Since adding Trusted Entity Calling we have seen a measurable increase in the call completion rate in the first month of use,” said Rip Harris, Ontario Systems’ Director of Product Management. “This bodes well as our call center customers need to be able to reach the people they call. Given the rise in robocalls, and numbers being marked as suspicious, having the means to make the outbound numbers trusted will only help their bottom line.”

Fonative’s Trusted Entity Calling provides customers, like Ontario Systems, with phone number registration to increase the connect rate on outbound calls, resulting in more and more effective customer conversations. To accomplish this, Fonative deployed Numeracle’s NumeraCert™ and NumeraList™ solutions to vet and verify trust in the calling party’s identity and register phone numbers across the wireless ecosystem. 

The cloud-based process is enabling call centers utilizing Ontario Systems’ Omni Voice service to register phone numbers associated with verified entities, laying the groundwork for STIR/SHAKEN call attestation. By validating the numbers with NumeraList, the legitimate calls are identified to the network. As a result, outbound calls to consumers originating from the Ontario Systems’ customer call centers will not be mislabeled and incorrectly displayed as FRAUD or SCAM calls.

“We’re here to provide a path and a process for legal, compliance-focused entities, like Ontario Systems and its customers, to identify themselves as ‘trusted’ across the call delivery ecosystem,” said Rebekah Johnson, Numeracle founder and CEO. “Through this process, we’re also able to identify fraudulent actors and prevent those types of entities from registering phone numbers through our platform and further dissolving trust in voice communications.”

Fonative’s carrier-grade CPaaS platform supports leading North American call centers that focus on healthcare-related and financial activities. Calls placed often surround payment and collection matters which involve the sharing, or collecting, of protected health information and payment data. As an intelligent solution, NumeraCert and NumeraList complement Fonative’s best in class, HIPAA, and PCI-compliant communications cloud-based API. 

“With carriers and the FCC cracking down on robocalling, it’s now critical to be bringing services like this to the market that validate, and certify, legitimate callers,” said Steve Smith, Founder and CEO of Fonative. The FTC’s recent letters warning voice service providers of the consequences of assisting with the delivery of illegal robocalls is evidence that a dedication to watchful compliance will be even more critical in 2020.

About Numeracle 

Numeracle is working with telecom carriers, call blocking and labeling analytics providers, device manufacturers, and industry leaders to deliver a path to visibility and control in the new calling ecosystem. Through the company’s technology vision and industry leadership, Numeracle is laying the foundation for returning trust and transparency to customer communications. To learn more about Numeracle’s call blocking and labeling solutions for call originators and call centers, visit www.numeracle.com.

About Fonative

Fonative helps businesses connect with customers through voice and text, providing compliant communications as a Communications Platform as a Service (CPaaS). The company’s technology enables developers to easily incorporate calling and messaging capabilities into business applications, without the need to maintain servers, infrastructure, network, and telecommunication carriers. Combining carrier-grade technology with advanced call center capabilities and regulatory compliance, Fonative is the only suite of telecommunication services to meet the stringent requirements necessary in key industries such as medical, financial services and government. For more information about Fonative’s Compliant Communications™ efforts, visit the company’s website, www.fonative.com.

Fonative is a registered trademark and Compliant Communications is a trademark of Fonative, Inc. Numeracle, NumeraCert and NumeraList are trademarks of Numeracle, Inc.

An interesting twist occurred in the battle against credit repair agencies that flood debt collectors with dispute letters. Last July, a jury in Texas returned a $2.5M verdict in favor of the plaintiffs—The CBE Group and RGS Financial—against Lexington Law and Progrexion, finding that the credit repair organization participated in a fraudulent scheme. On Thursday, Judge Sam A. Lindsay overturned the verdict, despite not being a fan of Lexington Law’s conduct.

The judge issued an order on several post-verdict motions filed by both parties in the lawsuit. Ultimately, the court denied plaintiffs’ motion for entry of final judgment and granted Lexington Law’s motion for judgment as a matter of law (which challenges the legal sufficiency of the verdict).

The ultimate effect of this is that the jury verdict is effectively canceled and “all allowable and reasonable costs are assessed against Plaintiffs.”

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So, what happened?

Lexington Law’s motion rested on the argument that plaintiffs’ fraud claim fails due to the failure to demonstrate two required elements: that the credit repair law firm knowingly made a material false statement and that, even if they did, there was no reasonable reliance on plaintiffs’ part. Plaintiffs’ motion, on the other hand, argues that all elements were met with the evidence presented at trial and Lexington Law failed to present contrary evidence.

The court found that, based on the evidence presented, Lexington Law did not make any material false statement. The court cites Lexington Law’s retainer agreements for its clients, which specifically states that Lexington Law may: act as the client’s agent or attorney in fact for disputing problematic credit report information; send communications on behalf of the client “and will not be identified as being sent by Lexington”; and sign letters on the client’s behalf.

According to the court:

The evidence presented at trial demonstrated that Lexington Law Firm was acting in accordance with the retainer agreement, and that each client explicitly consented to Defendants disputing certain of their credit lines and signing their names on the letters. In light of this evidence, the court fails to see any actionable misrepresentation on the part of Defendants. Plaintiffs have not explained convincingly—at the July 1, 2019 oral argument or in their postverdict briefing—how Defendants’ conduct amounts to an actionable misrepresentation.

The court also found that there was no evidence presented that Progrexion—Lexington Law’s co-defendant, made a misrepresentation. This is because Progrexion, while creating templates of letters for Lexington Law, does not itself send letters.

While the court overturned the verdict, it did not have praise for Lexington Law, stating that its conduct is not “cause for approbation.”

Now we wait to see if CBE and RGS appeal the judgment.

insideARM Perspective

This is an unfortunate turn of events in the fight against a practice that ultimately harms consumers. Legitimate debt collectors understand the importance of accurately reporting account information to the credit bureaus, and they build robust compliance processes and procedures to ensure they are reporting correctly and are able to quickly investigate—and, if necessary, correct—disputed information. It is believed that many credit report disputes, such as the ones from credit repair organizations, are not legitimate; instead, they are an attempt to remove correct, but unwanted, derogatory items from credit reports. If debt collectors are flooded with these illegitimate disputes, it makes it more difficult to separate the wheat from the chaff and help consumers who have legitimate disputes.

Editor’s note: This article is provided through a partnership between insideARM and Squire Patton Boggs LLP, which provides a steady stream of timely, insightful and entertaining takes on TCPAWorld.com of the ever-evolving, never-a-dull-moment Telephone Consumer Protection Act. Squire Patton Boggs LLP—and all insideARM articles—are protected by copyright. All rights are reserved. 

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As I continue working through the 2019 TCPA Year-End Review—patience, friends—it dawns on me just how extraordinary a year 2019 was for TCPA litigation in the Eleventh Circuit Court of Appeal footprint.

At the beginning of 2019, there seemed to be no safer jurisdiction to pursue a TCPA suit. The Bad Reyes decision had firmly established the use predictive dialers tripped statutory coverage, relying on the old FCC rulings from 2003 and 2008—which the Eleventh Circuit’s Mais decision clarified were untouchable under the Hobbs Act.

The Eleventh Circuit’s Osorio decision appeared to confirm both that a caller needed the consent of the “current subscriber” to make phone calls–an impossible task in an era of mass-number recycling– and (at least arguably) that contractual consent was always revocable.

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Schweitzer appeared to double-down on Osorio and even made partial revocation a thing to worry about down South.

Plus, the Eleventh Circuit’s Church decision (an FDCPA case) suggested that any ole statutory violation gave rise to Article III standing post-Spokeo, and the residual impact of pre-Spokeo decisions—most notably Palm Beach Golf Center–seemed to assure that TCPA plaintiffs had ready and certain standing to bring claims for calls to their cell phones.

And the Eleventh Circuit’s Gamble decision came pretty close to suggesting that TCPA suits were not even subject to arbitration. Eesh.

Yep, coming into 2019, the Eleventh Circuit Court of Appeal was the absolute most pro-consumer, anti-caller circuit in the country–and there wasn’t really even a second place.

Unsurprisingly, consumer lawyers in Florida began betting big on TCPA suits—investing in websites and designer phone numbers advertising recoveries of $500-$1500 per call—and it looked like boom times ahead. Hundreds upon hundreds of TCPA suits, mostly large-dollar class actions, were filed in the Eleventh Circuit’s footprint as consumer lawyers rushed to take advantage of this favorable case law.

Multi-million dollar TCPA class action settlements piled up like so much driftwood.

Boy, what a difference a year can make.

The first hint that something odd was happening came in July, 2019. Then, in a decision that was ostensibly about the fitful death of the FCC’s solicited fax rule—the Eleventh Circuit jumped headlong into the battle between the various branches of government launched in PDR Resources. And in a surprise (but still dicta) twist, the Eleventh Circuit panel in Gorss Motels determined that the Hobbs Act did not actually prevent district courts from reviewing FCC TCPA rulings–a direct contradiction to the Eleventh Circuit’s earlier Mais opinion. Powerfully unexpected.

While the Gorss Motels ruling was offbeat and unexpected, it was nothing compared to what happened next. In August 2019 the first really big hit came completely out of left field. The same Circuit Court of Appeal that had repeatedly handed down decisions enunciating broad standing principles suddenly declared that receipt of an unwanted text message did not necessarily cause Article III standing. Instead–the Court ruled in Hanna v Salcedo—a Plaintiff must demonstrate that the unwanted text actually harmed him or her in some way. It was a stunning ruling, and one that departed completely from the Ninth Circuit’s Van Patten decision and the remnants of virtually all of the Eleventh Circuit’s pre-Spokeo TCPA standing cases. Indeed, Hanna specifically narrowed Palm Beach Golf Center so as to make the decision inapposite in non-fax cases moving forward.

The even bigger news came in November, however, when the Eleventh Circuit handed down Cordoba. There the Court confirmed that uninjured class members cannot recover at trial and, therefore, a Court must take into account Article III standing issues at the certification stage in assessing predominance. Translation: unless all class members definitively suffered an injury, class certification is not possible owing to individualized issues of who suffered harm and who didn’t. And, as Hanna established, TCPA cases do not necessarily cause harm. My prediction from 2016 had come true: TCPA class actions were no longer certifiable as a result of Spokeo. (Yes, I wrote that article, never mind that another firm has their name on it. It happens.)

In the meantime, the Florida district courts launched their own TCPA revolution. Some held that contractual TCPA consent was irrevocable, no matter what Osorio said. Others refused to apply the TCPA outside of random or sequential calls, or where “human intervention” was used to send text messages. Heck, even Bad Reyes ended up stayed on the verge of trial.

But the biggest hit of all came this year when the Eleventh Circuit Court of Appeal handed down Glasser. In that decision, the Court concluded that the TCPA only applies to dialers that call using random or sequential number generators. Glasser departed completely from the Ninth Circuit’s formulation in Marks and explained—in a lengthy and well-analyzed opinion—why the TCPA’s dialer restrictions simply do not apply outside of the marketing context.

In a single year, the Eleventh Circuit has gone from the absolute best place on Earth to pursue a TCPA class action to the absolute worst. And you can almost hear the rumble—the great sucking sound—of TCPA class lawyers flocking from one coast to the other. The Ninth Circuit, with Marks and Van Patten providing cover, is now the center of the TCPA litigation universe. At least for now.

Who knows what 2020 will hold. In the meantime though, I know a pretty good California-based TCPA class action defense team if you need one. 😉

Stay safe, TCPAWorld.

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The iA’s Case Law Tracker can help you keep up with new court decisions and conduct quick, incisive legal research in less time than it takes to pour your morning cup of coffee.

CAMARILLO, Calif. — A.R.M. Solutions is excited to announce the newest member of our business development team, Robert Rock. Robert joins us after twenty plus years of executive experience, previously having held the position of Chief Strategy Officer and Chief Operations Officer at multiple national corporations including Alliance Group & Associates, The National Service Bureau, and Receivables Performance Management. In recent years, Robert has acted as an Executive Consultant for business process outsourcers, contact centers, agencies, and creditors in both US and International markets. 

Robert is known for his expertise in sales, operations, client services operations, vendor management, customer service, and beyond. He has received multiple client performance awards throughout the years, and has consistently met each challenge he’s encountered with a client-first mentality. He will be joining us as the Vice President of Business Development, working closely with our ever-growing sales group to ensure that our current customers are receiving the best care possible, as well as helping us expand to new industries and markets. We are humbled and proud to welcome another Veteran to our A.R.M. team, and thank Robert for his service with the United States Marine Corps. 

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About A.R.M. Solutions

A.R.M. Solutions is the national leader in diplomatic debt recovery. For over a decade, we have delivered the most cost-effective programs to maximize recovery rates, retain valued customers, and lower the overall cost of collecting on past due accounts. Recently named one of the top 10 collection agencies in the country by CFO Tech Outlook, A.R.M continues to maintain our reputation of top-tier service and expertise to our customers across dozens of industries. 

Another day, another court decision that discusses interest disclosures in collection letters. This time, we have a decision out of the Western District of Wisconsin. 

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In Salvatore v. Americollect, Inc., No. 19-cv-447 (W.D. Wisc. Feb. 5, 2020), the consumer alleged that a collection letter sent by Americollect did not state the amount due clearly enough for an unsophisticated consumer to understand. The letter was sent in regards to the consumer’s past-due medical debt and, in addition to listing the balance, stated that the amount owed is as of the date of the letter but future interest may accrue.

The exact statement in the letter said that “[f]uture interest of 5% per year may be added to the account if the amount due is not paid.” The consumer’s main argument was that the letter doesn’t state how interest would be accrued or what would happen if she paid the amount stated in the letter after interest accrued.

The court granted Americollect’s motion to dismiss, finding that the letter would not confuse an unsophisticated consumer.  The court, instead, went back to the different appellate court cases that discuss this issue, such as Taylor from the Second Circuit. The court found that the appellate court decisions, while they provide a safe-harbor language, don’t require the exact language to be used. With that, said that the consumer identified nothing in the FDCPA that requires the information sought by the consumer to be provided.

The court states:

The debt-collection letter that Americollect sent to Salvatore told her the precise amount that she owed as of the date of the letter and said that future interest might accrue if she did not pay her debt. This is all that § 1692g(a)(1) requires. Even if the information that Salvatore contends that the letter lacked would have been helpful, its absence does not give rise to a cause of action under the FDCPA.

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The iA’s Case Law Tracker can help you keep up with new court decisions and conduct quick, incisive legal research in less time than it takes to pour your morning cup of coffee.

GENESEO, NY — Coast Professional, Inc. (Coast) recently celebrated the 10^th anniversary of its Geneseo, NY office. In 2009, CEO Brian Davis and President Everett Stagg were confident that the Geneseo office would become home to a significant number of staff and bring economic prosperity to the Livingston County area.

Under Brian and Everett’s leadership, Coast’s Geneseo location has been remodeled three times in order to keep up with the company’s significant growth. In 2009, the building located on Geneseo’s Volunteer Road was approximately 4,000 square feet and housed just 20 employees. Now, 10 years later, that same building has grown more than five times its original size to over 27,000 square feet and can be seen from the shopping center parking lots below. The office is now home to approximately 500 employees and was named the company headquarters in 2017.

“We believed in this community from the very beginning,” said Brian Davis, Coast CEO. “Geneseo was the perfect location for economic prosperity and fit with our vision of where we wanted Coast to go. Geneseo, Livingston County, and the surrounding communities as a whole, are an ideal combination of high quality employees, a thriving business environment, exceptional core values, and work ethic. Over the past 10 years, we have continued to invest in our commitment to the surrounding area through consistent charitable giving and volunteer programs. Community outreach is a key component of our culture at Coast and we’re excited to continue thinking of new, innovative ways to get back and get involved.”

The economic impact that Coast has made in the Geneseo area is evident. From the creation of approximately 500 jobs to its generous charity donations, Coast leaders are focused on more than just company success. Brian and Everett have fostered a culture of giving, and they believe in the importance of giving back and working with the residents of their local community. In the last five years, Coast has donated over $215,000 to local charities courtesy of the company’s dress down for charity program that began in 2012. In 2018, Coast was named the Livingston County Chamber of Commerce and Tourism’s “Large Business of the Year.” The company was nominated for its efforts to treat consumers with respect, maintain positive relationships with community partners, growth in employment, and their dedication to ethics in all levels of the company. The award also recognized Coast’s commitment to area involvement through Chamber and community events. In 2019, Coast was a Democrat and Chronicle Top Workplaces award recipient – an award where the results are based entirely on employee feedback.

“Geneseo and the surrounding regions have employees of the highest caliber,” said Everett Stagg, Coast President. “We wouldn’t be here without our incredible staff and their ongoing dedication to this company. I want to thank our amazing staff for their unwavering support for our cause and the Livingston County business community for the opportunity to plant our roots for significant growth. We are proud to be a Livingston County business.”

As part of the company’s efforts to expand, Coast has recently opened two additional offices outside of Buffalo, NY. All three offices in NY, including Elma, East Aurora, and Geneseo, are currently hiring for high-paying careers. Please visit www.bonuscheck.net to view all opportunities.

About Coast Professional, Inc.:

Coast Professional, Inc. is an accounts receivable management company, dedicated to the respectful and ethical collection of higher education and government debt. Coast provides professional collection services to over 200 campus based colleges, universities, and government clients. Coast is a six-time honoree on the Inc. 5000 list for American’s Fastest-Growing Private Companies provided by Inc. Magazine and in 2019, was recognized for the fourth time as one of the “Best Places to Work In Collections” by insideARM.com and Best Companies Group. Since 1976, Coast has worked closely with clients to increase recoveries by assisting consumers in resolving their financial obligations. Coast’s success is exemplified by exceptional recoveries, superior service, and dedication to the highest levels of compliance. More information about Coast can be found at www.coastprofessional.com