Last week, insideARM wrote about an Eastern District of New York case where a judge called out the abuses of the Fair Debt Collection Practices Act (FDCPA) by plaintiffs and their counsel. It looks like the District of Maryland joins in on doing the same, this time with a suit that claims an FDCPA and Fair Credit Reporting Act (FCRA) violation.

In Miller v. Trident Asset Mgmt., No. 18-CV-2538 (D. Md. Dec. 4, 2019), the court granted the defendant’s motion for sanctions, holding plaintiff and her counsel jointly and severally liable. To translate the legalese: When parties are held jointly and severally liable, it means they are both on the hook for the whole amount. The person to whom the amount is owed may go after either or both parties for the full amount, but cannot recover more than the full amount.

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So, What Happened?

Plaintiff’s daughter opened a Verizon account under plaintiff’s name (with plaintiff’s permission). After this, plaintiff and her daughter failed to make payments on the account. The account was closed and credit reported. Despite knowing that this debt is valid, plaintiff disputed the account. Later, a paralegal from plaintiff’s counsel’s law firm reported that plaintiff was a victim of identity fraud and had no knowledge of the debt. In both instances, Defendant met its FCRA and FDCPA obligations by investigating the disputes and marking the account as disputed.

Plaintiff then filed a lawsuit against Defendant—and similarly filed nine other lawsuits against different defendants for similar issues. The nine other lawsuits were settled, but Defendant defended the claims.

What happened at plaintiff’s deposition is best said in the court’s own words:

At deposition Plaintiff admitted that the debt was her daughter’s and her daughter used Plaintiff’s name with her permission and defaulted. Plaintiff at deposition also testified that she did not know whether the amount due or the credit reporting was accurate. Even after this admission in deposition, Plaintiff and her counsel continued litigating this claim. Plaintiff in opposing summary judgment changed her story again and denied her signature on the letter to Defendant and disavowed her knowledge of identity theft. Plaintiff’s counsel in his declaration denied knowledge of the false identity theft report until the time of deposition. 

(Internal citation omitted.)

The court was not impressed with plaintiff’s fraud upon the court by her flip-flopping positions. However, the court was similarly not impressed with the paralegal. The court noted that the paralegal has helped many of his family members file FCRA actions—likely to get settlements. Plaintiff, while not a family member, is a tenant in a property owned by the paralegal. The court further goes to call out plaintiff’s counsel:

It would also be imprudent to ignore the role of counsel in this case, who even after being faced with his client’s admission of the debt, the false reporting of identity theft, and her lack of knowledge of whether the reporting was accurate, continued to press this litigation. In a pattern that has repeated itself in other Alston filings, the failure at litigation has resulted in extensive post-summary judgment motions, styled as motions to alter or amend judgment. This post-judgment litigation resulted in even more attorney’s fees for Defendant, adding the proverbial insult to injury.

Ultimately, the court found that it was obvious from the get-go that there were no FDCPA nor FCRA violations and that plaintiff and her counsel unreasonably prolonged litigation in bad faith. A $190 valid debt that was properly credit reported ended up costing an unreasonable amount in what the court calls a fraudulent lawsuit.

The court states:

There has been extensive litigation in this case over nothing more than an actual and properly reported $190 debt that could have been settled with Defendant for one half that amount. Instead, the Plaintiff opportunist with help from Thomas Alston and/or her counsel turned this frivolous, non-existent claim into an attempt to continue the FCRA/FDCPA money making scheme.

The 37-page long decision extensively discusses the scheme her and the court’s reasoning for its decision. 

insideARM Perspective

As we mentioned in last week’s article, judges appear to be noticing the litigation dilemma faced by debt collectors that are targeted by frequent-filer plaintiffs’ counsel. And it’s important to repeat: decisions like this only come when debt collectors defend the lawsuits. As noted in this case, there were nine other defendants who settled similar cases with this plaintiff. Had Trident Asset Management similarly settled, a decision like this—which establishes a record of this type of conduct for future litigation—would not have come to pass. There are, of course, many factors to weigh when deciding to defend or settle a claim, and this should be one of them. Tools like the iA Case Law Tracker can help you research claims you are defending to help you analyze your litigation defense strategy.

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Want to quickly find all of the cases where the courts have criticized the practices of plaintiffs’ counsel? The iA Case Law Tracker can help you conduct incisive and quick legal research in less time than it takes to pour your morning cup of coffee.

JACKSONVILLE, Fla. — Clear Payment Solutions is pleased to announce the recent addition of Gary Beet as Vice President of Sales. Gary has over 30 years of experience in credit and collections, most recently working for Experian after selling his company to them – eResolve, formerly PayLine Direct, in 2017. Gary has held senior-level positions with GE Capital, Sallie Mae and Computer Sciences Corporation, as well as pioneering new companies and products within the revenue recovery space.

Beet shares the company’s vision to position Clear Payment Solutions as the premier provider in the credit and collections industry. His unique skill set, entrepreneurial approach, and diverse experience will help drive this initiative – creating a ‘one-stop’ payment solution.

About Clear Payment Solutions

Founded 2008 in Jacksonville, Florida, Clear Payment Solutions was formed to service the collection industry as a payment processor. Recognizing the need for an industry-focused provider that understands the unique requirements of these ‘high-risk’ markets, CPS has refined its offering of specialized products and services that not only address today’s requirements, but also anticipate tomorrow’s needs. CPS offers a low-cost, technology-driven solution that is compliant, secure and proven.

BUFFALO, N.Y. — As part of our commitment to social responsibility and giving back to our community, Northwood Asset Management Group is donating Thanksgiving dinner and Christmas gifts to Haven House, a shelter providing services and refuge for victims of domestic violence in Buffalo, N.Y.

Haven House is a domestic violence shelter founded in 1979 by the Coalition for Victims of Domestic Violence (now known as the Erie County Coalition Against Family Violence). Haven House provides emergency services, counseling, advocacy and support groups, education and training, and economic empowerment for victims of domestic violence. The shelter also offers refuge for victims of domestic violence and their children, regardless of the county or state of residence. 

“Northwood Asset Management is passionate about supporting organizations that are doing vital work that keeps the members of our community safe. No one should live in fear; and for those in crisis or rebuilding their lives after violence, the holidays can bring added stress and worry,” says President Andrew Fanelli. “We are donating Thanksgiving dinner and Christmas gifts to brighten the spirits and deliver holiday cheer to those who need it most.” 

Haven House helps victims of domestic violence find safety and healing through an extensive continuum of care. They provide not only shelter for present victims of domestic violence, but also non-residential services to past and present survivors of domestic abuse. Haven House offers information and support through their 24/7 hotline. 

“The holidays are a time for us to share compassion for those in need. Everyone deserves to be in safe and healthy relationships, free from the fear of abuse. It is our privilege to be involved and help support survivors and their families,” continues President Fanelli. “By donating Thanksgiving dinner and Christmas presents, we hope to touch the hearts of those in need and make the holiday season more joyous and magical for everyone.”

For more information about Haven House, please visit www.cfsbny.org/programs/haven-house. 

If you or someone you know is in crisis or in need of emergency services, Haven House staff are available 24 hours a day at (716) 884–6000. All over the country, victims, survivors, and those affected by domestic violence can get help 24 hours a day, 365 days a year, through the toll-free National Domestic Violence Hotline at 1-800-799-7233 or by visiting www.thehotline.org. 

About Northwood Asset Management Group

Northwood Asset Management Group (NAMG) is a nationally-licensed, professional third-party debt collection company representing creditors in the resolution of account balances. Northwood Asset Management is committed to delivering services with professionalism, respect, and complete compliance. NAMG actively gives back to the communities we serve while working hard to find mutual agreements between creditors and account holders that enable both parties to move forward. The Company was founded in 2012 and is located in Buffalo, N.Y.

Another judge in the Eastern District of New York criticized plaintiffs’ counsel for what the court calls a “lawyer’s case”—so technical that only a lawyer, not a least sophisticated consumer, would think of it. Judge Sandra Feuerstein quoted previous decisions by Judge Brian Cogan and Judge Leo Glasser where they noted that these types of cases harm, rather than help, consumers.

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So, What Happened?

The case in question: Campagna v. Client Services, Inc. No. 18-cv-3039 (E.D.N.Y. Dec. 3, 2019). The debt collector mailed a letter to the plaintiff which identified the account as “RE: CHASE BANK USA, N.A.” and included an offer “to settle this CHASE BANK USA, N.A.” account for less than the full balance owed. Plaintiff, represented by Barshay Sanders PLLC, filed a Fair Debt Collection Practices Act (FDCPA) lawsuit alleging that the letter fails to clearly identify the creditor to whom the debt is owed or to describe the relationship between the debt collector and the creditor. 

Interestingly, the complaint does not claim a violation of §1692g—the section of the FDCPA which states that a debt collector must clearly identify the creditor to whom the debt is owed in the initial communication. Instead, the complaint alleges a violation of §1692e, arguing that the letter was false, deceptive, and misleading. 

The Court’s Decision

The crux of the court’s decision is that it concluded the letter in question was not the initial letter sent to the consumer, but rather a subsequent letter. This was based not only on the plaintiff’s failure to allege a §1692g claim, but also because plaintiff did not state that this was the initial letter. The court found that the creditor identification requirements of §1692g only apply to the initial communication, and thus a §1692e claim based on the failure to meet such requirements in a subsequent communication cannot hold water.

The court went even further to state that even if hypothetically this was the initial letter, the way the creditor was identified is sufficient to meet the relevant §1692g requirements.

FDCPA Abuse

Throughout this decision, the court questions the intent behind this and similar lawsuits brought by plaintiff’s counsel. In footnote 6, the judge states:

The Court is hard-pressed not to question whether this nuanced §1692e claim, the only cause of action raised, is being pursued in the hopes of finding a new avenue to FDCPA violations given the carefully crafted Complaint here, as well as in Lugo and Stehly v. Client Services, Inc., No. 18-cv-5103, 2019 WL 2646664 (E.D.N.Y. June 27, 2019) (filing virtually identical compliant as in the instant case and Lugo). Indeed, as Judge Glasser has recently observed, in stating that the FDCPA is intended to prevent debt collectors from trying to trap unsophisticated debtors and is not intended as a trap for compliant debt collectors.

The footnote then quotes Judge Leo Glasser, who in the Kraus case discussed the proliferation of FDCPA litigation:

[T]he number of FDCPA cases filed yearly in this District has more than quintupled. And small wonder, when all required of a plaintiff is that he plausibly allege a collection notice is “open to more than one reasonable interpretation, at least one of which is inaccurate.” This standard prohibits not only abuse but also imprecise language, and it has turned FDCPA litigation into a glorified game of “gotcha,” with a cottage industry of plaintiffs’ lawyers filing suits over fantasy harms the statute was never intended to prevent.

(Internal citation omitted.)

Judge Feuerstein then quotes Judge Cogan from the Ocampo case:

Cases like this – litigation over whether an innocuous debt collection letter is in technical compliance with the FDCPA – are far afield from the original intent behind the FDCPA, i.e.[,] preventing “collection abuses such as use of obscene or profane language, threats of violence, telephone calls at unreasonable hours, misrepresentation of a consumer’s legal rights, disclosing a consumer’s personal affairs to friends, neighbors, or an employer, obtaining information about a consumer through false pretense, impersonating public officials and attorneys, and simulating legal process.” Kropelnicki v. Siegel, 290 F.3d 118, 127 (2d Cir. 2002) (internal quotation marks omitted). That is not what happened here at all. Rather, this is a “lawyer’s case,” by which I mean that it alleges a defect of which only a sophisticated lawyer, not the least sophisticated consumer, would conceive.

And, as if to put a cherry on top of this, Judge Feuerstein cites deposition testimony from Kraus in footnote 9, where the plaintiff stated that she sought an attorney to help get her out of debt, not because she “felt abused, deceived, or otherwise aggrieved.”

insideARM Perspective

What a whopper of a case! It seems that as time goes on, the historically consumer-friendly Eastern District of New York is picking up on the FDCPA litigation scheme and putting stops to it where it can. 

It’s important to note that we were only able to get to this point because debt collectors decided to stand up and defend these lawsuits. If claims are settled early—either pre-litigation or on the outset of litigation—then the cases don’t see their way to the judge’s desk. If the judges don’t see these lawsuits, then they won’t recognize the problems that debt collectors are facing. There’s nothing judges like less than asinine cases clogging their already over-filled dockets.

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Want to quickly find all of the cases where the courts have criticized the practices of plaintiffs’ counsel? The iA Case Law Tracker can help you conduct incisive and quick legal research in less time than it takes to pour your morning cup of coffee.

Well that didn’t take long. Just last Wednesday we reported that the text of the so-called Pallone-Thune TRACED Act–the “compromise” robocall bill merging elements of the House’s original Stopping Bad Robocalls Act and the Senate’s Original TRACED Act–had been released.

A week later the bill has already passed the house, and by a whopping 417-3 margin. Gees, we barely had a chance to analyze the bill before the thing passed.

The bill is now off to the Senate where it is expected to pass on unanimous consent.

Then the bill heads off to President Trump for consideration.

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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. 

SAN DIEGO, Calif. — The City of San Diego selects CSS IMPACT Financial Cloud Ecosystem as their new “NextGen” Debt Collections Platform, “CSS IMPACT | HD 2.0”. CSS, Inc., the developers of “IMPACT | HD 2.0” is the leading provider of “NextGen” Cloud Financial & Debt Collections Ecosystem platforms for enterprises & government.

CSS’s cloud Debt Collections Ecosystem platforms remove prohibitive costs in acquiring “NextGen” debt management technology, enabling City workforces to overcome fundamental day-to-day process challenges. Metropolitan Municipalities, such as the Cities of San Francisco & Los Angeles – and now the City of San Diego – are leveraging CSS’s Financial Cloud technology to deliver turn-key debt management & collections process automation with a frictionless “Digital Consumer Engagement” experience, while efficiently streamlining the City’s workforce resources, enabling them to focus on revenue management strategies & customer care.

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The City of San Diego is a renowned technology leader that continuously leverages innovative and sophisticated digital tools that push the boundaries of how to deliver services to its citizens.  Winner of the “Digital Cities Survey 2019” and 2nd place on the national “2019 Government Experience Awards” are clear evidence of the City’s unyielding commitment to a growing technological foundation to enhance its citizens digital experience while developing processes that improve efficiency and transparency for its employees. 

The City’s selection of CSS IMPACT | HD 2.0 as its platform of choice aligns with this vision of delivering services leveraging the latest digital technology to improve productivity and quality of service while enhancing citizen experience and engagement.  

“We are truly honored and humbled to have been selected by the City of San Diego for this implementation to deploy our “NextGen” Financial Ecosystem, which will allow the city to leverage our cloud automation toolset to deploy streamlined processes and make services much more efficient, effective and transparent, while providing a rich digital customer service experience and better serve its citizens. We are very excited for this partnership and look forward to a long-term relationship with the City of San Diego” said “Sergio Seplovich”, Executive Projects Director at CSS.

To learn more about how municipalities are leveraging CSS’s Cloud Financial Ecosystem, please visit https://www.cssimpact.com/collections/ or download our brochure at http://brochure.cssimpact.com

About the City of San Diego, CA – Office of Finance

The City of San Diego is known as “the birthplace of California”. With an estimated population of 1,425,976, it is the eighth-largest city in the United States and second-largest in California. It is part of the San Diego–Tijuana conurbation, the second-largest transborder agglomeration between the U.S. and a bordering country after Detroit–Windsor, with a population of 4,922,723 people. The city is known for its mild year-round climate, natural deep-water harbor, extensive beaches, long association with the United States Navy, and recent emergence as a healthcare and biotechnology development center. 

The city is the seat of San Diego County and is the economic center of the region as well as the San Diego–Tijuana metropolitan area. San Diego’s main economic engines are military and defense-related activities, tourism, international trade, and manufacturing. The presence of the University of California, San Diego (UCSD), with the affiliated UCSD Medical Center, has helped make the area a center of research in biotechnology. 

For more information please visit http://sandiego.gov

About CSS, Inc.

CSS is a leading provider of end-to-end cloud Financial Debt Collections Ecosystem platforms & Contact Center solutions for enterprises that generate & manage mass receivables, payments, recoveries & revenues. By delivering cognitive cloud Financial Ecosystems technology, CSS helps municipalities and enterprises improve and automate all their daily financial processes, consumer engagement & business process. For more information, download our brochure at http://brochure.cssimpact.com or visit us http://www.cssimpact.com or call 877.277.4621 

Pairity is proud to announce its recognition as “Most Innovative Product” during last week’s CollectTECH19 Awards Ceremony. 

CollectTECH19 is a conference created by Receivables Advisors with a focus on the intersection of technology and compliance issues. Topics discussed included regulatory compliance and AI, as well as the use of blockchain in collections. 

Pairity’s innovations span from its patent pending artificial intelligence platform, a compliant and completely AI-powered Marketplace for portfolio sales and contracts, to its explainable machine learning as a service. Pairity’s AI maps consumer relationships to improve consumer contact, and also explains the choices behind its decisions so agencies and lenders understand the reasoning behind algorithmic-backed strategy.

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About Pairity

Pairity uses AI to ease the stress of consumer debt for everyone: lenders, collectors, and individuals who are repaying debt. Pairity’s machine learning models and patent-pending AI are designed to improve accounts receivable management by scoring accounts, allocating workloads and uncovering relationships for unprecedented results.

For more information, visit pairity.ai or contact info@pairity.ai. 

GENESEO, N.Y. — Coast Professional, Inc. (Coast) recently received a Training Top 125 Award from Training Magazine. The Training Top 125 Awards recognize organizations with the most successful learning and development programs in the world. The awards rank companies’ excellence in employer-sponsored training and development programs using quantitative and qualitative scoring methods. 

The Top 125 rankings are calculated based on corporate training overall, including the number of training hours per employee program, total training budget, and innovative learning goals. Over the last eighteen (18) months, Coast has worked diligently to establish a world-class training program resulting in the recognition from Training Magazine. This award is a direct result of Coast’s improved employee training programs, compliance standards, and human capital development. 

“Compliance training is a major component for our employees and their success,” said Coast Chief Compliance Officer, Annmarie Buchanan. “We ensure that all employees participate in annual compliance trainings and thoroughly understand the rules and regulations related to ethical industry practices. With their dedication and effort, Coast is able to uphold its company values and achieve its overall mission of delivering exceptional customer service.” 

In February 2020, the Coast team will travel to Disney’s Coronado Springs Resort in Orlando, FL to receive their official ranking out of the 125 companies.  Past Training Top 125 award winners include Verizon, IBM, and Jiffy Lube. 

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.

On December 2, 2019, in Sacramento, the California Attorney General (AG) kicked off its first public hearing collecting comments for its proposed regulations to the California Consumer Privacy Act (CCPA). There were approximately 12 different commenters, which is remarkedly less than the previous CCPA public hearing in Sacramento. Although the comments were few, one theme was clear. Organizations support increasing consumers’ privacy rights, but the proposed regulations have done little to help businesses and service providers operationalize many aspects of the CCPA. 

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Disclosures and Requests for Model Notices

Some expressed concerns that the proposed regulations will create confusion for consumers. They stated that consumers are overwhelmed with information and want short and simple notices and disclosures as opposed to the robust and lengthy notices and disclosures required by the CCPA. For example, one commenter explained how there are dozens of purposes for which a company collects information, and having to list all of them is going to be arduous. Representatives from financial service industries, including credit unions and banks, explained how it would be helpful if the AG published model notices and disclosures. Model notices and disclosures would serve many purposes, such as helping consumers have a more consistent experience across organizations, provide safe harbors for businesses, and reduce the burden organizations are having in interpreting and adapting the CCPA’s requirements. 

Disclosures During Telephone Calls

One commenter pointed out that the proposed rules assume that the required notices and disclosures will be provided in writing (see § 999.305(a)(2)); however, what if the information is collected orally? How should a business provide required notices and disclosures when it collects information through a telephone conversation? Does the business collecting that information have to list all the categories of information verbally?

Speaking of telephone conversations, many businesses record telephone conversations. Since audio may be considered personal information under the CCPA, does the business now have to provide call recordings at the consumer’s request, and if so, how should the business provide those recordings to the consumer?

Requests to Delete v. Opt-Outs

Others expressed concerns about how the proposed regulations instruct companies to treat a request to delete if they cannot verify it as a request to opt-out of a sale (see § 999.313(d)(1)). They felt the right to delete should not be conflated with the right to opt-out. They also raised concerns about practical and technical challenges posed by allowing consumers to opt-out via user-enabled privacy settings and plugins (see § 999.315(a)). 

Confusion about Party Designations

One commenter stated that the CCPA’s treatment of “business” versus “service provider” versus “third party” is so complicated that it can prevent legitimate data sharing between businesses. Another commenter stated concerns around requiring service providers to process and respond to requests for information and requests to delete information. How is a service provider—such as Salesforce, for example—supposed to know what it should or should not delete when it is simply holding information for its customer?

CCPA Not Scalable

A few comments focused on the lack of scalability the CCPA poses for both consumers and businesses. For example, consumers will have to potentially make hundreds of individual requests for information to each business and/or service provider they know may have their personal information. This would also require consumers to follow numerous different verification procedures to have their requests treated as a “verifiable consumer request” under the CCPA. This could prove daunting to consumers.

Additionally, the CCPA may prove burdensome for companies. Looking at the GDPR for lessons learned, some companies in Europe report having to process hundreds of requests for information received in a week. One commenter asked the AG to change its proposed rule that the 45-day response period to customer requests begins when the company can treat that request as a “verifiable consumer request” rather than when it receives the request (see § 999.313(b)). 

Companies Should Submit Written Comments

The deadline to submit written comments to the California AG is Friday, December 6th, and public forums around the state in Los Angeles, San Francisco, and Fresno are being held this week. The AG encourages comments and has even published Tips on Submitting Effective Comments. Submitting a comment is as easy as sending an email to PrivacyRegulations@doj.ca.gov.

As we all look to operationalize the CCPA, whether as a business, service provider, or third party, this is our opportunity to provide the AG with insight into the challenges, questions, and suggestions we have for making compliance with the CCPA something we can all be confident with. 

SACRAMENTO, Calif. — Registration is already open for the Receivables Management Association International (RMAI) Annual Conference, occurring February 3–6, 2020. The conference brings together key participants in the receivables management industry, including debt buying companies, collection agencies, collection law firms, brokers, originating creditors, and affiliates.  Companies and individuals who take advantage of early bird pricing can save hundreds of dollars on registration costs; the early bird deadline is December 6th.  Anyone interested can register at https://rmaintl.org/AC2020.

This conference is the premier event for the Receivables Management Industry—welcoming over 1,200 attendees and showcasing over 80 exhibit booths—and provides abundant networking opportunities with key participants, including debt buying companies, collection law firms, collection agencies, brokers, major creditors, and international members. With over 20 education sessions, it’s also the perfect setting to learn about the latest trends impacting the industry and earn certification and CLE credits.

“We’re looking forward to another exciting Annual Conference in 2020,” said Jan Stieger, Executive Director of RMAI.  “This will be our 23rd Annual Conference, and we continue to grow and expand the opportunities available, and the value we provide to attendees.”

RMAI has increased networking opportunities for conference attendees this year.  The conference will kick-off with a day of golf at Bear’s Best Las Vegas on February 3rd, new in 2020.  RMAI has also added a networking session specifically for Originating Creditors.  Favorite sessions from past years will return, including Solutions for a Winning Streak session, where conference attendees can get a quick pitch on services that can help their business; the Women in the Industry reception, following its popularity when launched in 2019; and Suite Crawl, the networking event of the year, a traveling party in the luxury Ara Sky Suites.

About Receivables Management Association International

Receivables Management Association International (RMAI) is a nonprofit trade association that represents more than 500 companies that purchase or support the purchase of performing and nonperforming receivables on the secondary market. The Receivables Management Certification Program and Code of Ethics set the global standard within the receivables industry due to its rigorous uniform industry standards of best practice which focuses on the protection of the consumer. 

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