This article is part of an ongoing Think Differently series, launched in October 2019. 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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When you think about the intersection of artificial intelligence and debt collection, do you have a clear picture of what that means? Maybe your initial response is, yes, of course. But if you try to explain it, the vision may get a bit blurry. This is what happened to me. So I set aside the technology for a moment to try to illustrate what it means to interact with artificial intelligence in the collections process. I thought that if the concept were viewed from the perspective of a consumer, it would be easier to visualize how AI affects the experience.  So, I started where the experience is most recognizable — the plain old process of getting a credit card and making purchases.

This led me to create an illustrated brief titled, “The Consumer’s Credit-Collections Journey, Powered by Artificial Intelligence.” Designed for legislators, regulators, industry participants, and anyone seeking to get their arms around how the latest technology affects the consumer experience, the brief provides a plain-English overview of what the consumer sees, what’s going on behind the scenes, and examples of the companies that provide the technology.

The illustrated journey begins with a consumer’s application for credit and continues through purchases, payments, and dealing with possible life curves such as fraud alerts, identity breaches, late payments or collection notices.

What became clear is that artificial intelligence — especially in the form of machine learning — offers a far more sophisticated approach to segmenting and servicing consumers in the manner best suited to the individual. Which means greater efficiency. And greater satisfaction on both sides of the communication.

What I also find exciting is the idea that machine learning can make it possible for call centers to benefit from the unstructured data they hold, such as call recordings or agent notes. If used correctly, this should be a benefit to consumers too. How often have you called customer service — for the 3rd time — only to have to repeat previously provided information because it didn’t fit neatly into a dropdown box or predetermined database field? 

The next step, of course, must be a more effective transfer of information between clients (like lenders, healthcare providers, telecom companies, utilities, and others) and their service providers (like outsourced call centers) so that data is not lost or buried. But I digress. 

This brief is intended to give regulator and industry stakeholders a place to start asking the right questions about the risks, the opportunities, and where they should focus their efforts as it relates to this fast-moving train of technology. I’d like to thank the members of the iA Innovation Council for their input. 

You can download the brief here.

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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 can inspire different thinking. www.iainnovationcouncil.com

2019 members include:

You’ll recall a few weeks back TCPAWorld.com featured analysis of efforts by VoApps—makers of the DirectDrop ringless voicemail platform—to stem the tide of negative TCPA rulings addressing ringless voicemail technologies. VoApps founder David King even joined the Unprecedented podcast to discuss his submission of a lengthy declaration to the court addressing how the technology works and why it is not covered by the TCPA.

Well, a few days ago the Court issued its ruling on the pending motion—a summary judgment effort by the Plaintiff—and I must say, it was rather anti-climactic. Indeed, the court punted on the key issue entirely.

In Saunders v. Dyck O’Neal, Case No. 1:17-CV-335, 2019 U.S. Dist. LEXIS 177606 (W.D. Mich. Oct. 4, 2019) the court issued its highly-anticipated ruling on the Plaintiff’s bid to earn judgment following the Court’s earlier ruling that a ringless voicemail is a call under the TCPA. It was in response to this motion that VoApps submitted a mountain of evidence that although a ringless voicemail may be a “call” it is not a call to a number assigned to a cellular service—and so such calls are not actionable under the TCPA’s infamous section 227(b).

Rather than answer the question directly the Court made mincemeat of the Federal Rules of Civil Procedure and treated the summary judgment motion as if it were some sort of motion to confirm the Court’s earlier ruling. This is weird because i) no it wasn’t; and ii) there’s no such thing. As the Court put it: “Admittedly, Saunders moved for summary judgment, but her motion is in fact limited to a request for clarification of the impact of the Court’s prior ruling: Was the Court’s prior ruling that DONI’s messaging technology falls within the purview of the TCPA a ruling as a matter of law that binds the parties going forward? The answer is clearly yes.”

Great. So we now know what we already all knew—the Saunders court holds that a ringless voicemail is a call. Got it. As to the key issue of whether the calls were made to a landline to a cell phone, however, the Court finds: “These issues were unnecessary to Saunders’s motion, as she has not [actually] moved for summary judgment on her claim.”

So there you go. Plaintiff’s motion for summary judgment was not actually a motion for summary judgment after all. So all that work by VoApps was for nothing. But not really. Obviously this fight is not yet over. The Court declined to enter judgment in favor of the Plaintiff meaning that further work—and perhaps a trial—lies ahead for the good folks over at VoApps. We’ll keep you posted.

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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. 

This morning, the U.S. Supreme Court will hear oral arguments in the matter of Rotkiske v. Klemm on the issue of whether the “discovery rule” applies to Fair Debt Collection Practices Act (FDCPA) claims. The Court’s decision will impact how long consumer plaintiffs have to file FDCPA lawsuits against debt collectors as it will determine when the statute of limitations clock starts ticking.

The FDCPA states that a consumer may file an FDCPA action “within one year from the date on which the violation occurs.” A case arose out of the Third Circuit where the consumer argued that the statute of limitations should begin to run when the violation was discovered by the consumer—hence the name of the discovery rule—rather than when the injury occurred. 

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In May of 2018, the Third Circuit issued its decision in Rotkiske—the decision the Supreme Court will review—finding that the text of the FDCPA is clear: the statute of limitations begins to run when the violation occurs, not when it is discovered. The consumer appealed, and in February of this year, the Supreme Court granted the petition for writ of certiorari, a fancy name for the court agreeing to hear the case. 

According to the Supreme Court’s schedule, Rotkiske is slated as the second argument for the day, with one hour allotted for arguments. 

California’s Attorney General (AG) released its long-awaited proposed regulations for the California Consumer Privacy Act (CCPA), providing guidance on how to comply with the new privacy law. The CCPA, which was signed into law into law in June 2018, takes effect on January 1, 2020, and requires the AG to implement regulations by July 1, 2020.

The proposed regulations mainly provide procedural details, including process requirements regarding:

• Notices to consumers, such as what must be included in the notice and when the notice must be provided;
• Handling and processing consumer requests, such as requests to delete information;
• Verification processes to ensure the request is received from the correct person; 
• Requirements for company privacy policies; and
• Handling special situations, such as if the consumer is a minor.

The AG is set to hold four public hearings on the issue in Sacramento, Los Angeles, San Francisco, and Fresno between December 2 and December 5. The AG also invites public comments on its proposed regulations, which are due by December 6. Instructions on where to send public comments can be found here.

This will be the second round of public hearings held by the AG regarding the CCPA. Earlier this year, the AG held several public forums to get input on the CCPA itself. Summaries of those forums can be found as follows:

• January 8, 2019 (San Francisco)
• January 14, 2019 (San Diego)
• February 5, 2019 (Sacramento)
• March 5, 2019 (Stanford University)

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insideARM Perspective

When California’s Governor signed the CCPA into law—less than a week after the bill was retrieved from an inactive file—companies raised a lot of concerns, primarily regarding the uncertainty of the new requirements due to vagueness in the statute. One major concern was the timeline—the CCPA goes into effect on January 1, 2020, but the AG has until July 1, 2020, to release its regulations governing the CCPA. The gap leaves companies in an odd place. 

Well, folks, the first domino may have just fallen.

As I wrote just days ago, the Marks ATDS formulation is not as monolithic as it may first appear. Yes it is formidable in its breadth, but it leaves a lovely little string dangling—the dialer must call from a list “automatically.” What the term “automatically’ means very much remains to be seen. But we now have, at least, our first case limiting the scope of Marks where calls are made manually.

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In Ammons v. Diversified Adjustment Serv., Case No 2:18-cv-06489-ODW (MAAx), 2019 U.S. Dist. LEXIS 175842 (C.D. Cal. Oct. 9, 2019) the Court granted the Defendant’s motion for summary judgment challenging the Plaintiff’s TCPA claim in a debt collection case. Each of the 77 calls at issue were made using the LiveVox HCI dialer—the most battle-tested “manual intervention” dialer on the market.

The factual record on the motion demonstrated that the LiveVox HCI system was “purposefully designed to require a human component to initiate each call through that platform, and to be incapable of automated calling.”  Instead, the human component, a “clicker agent,” must physically click a dialog box to launch each individual call. And there’s a real element of human intervention here— “[t]he clicker agent verifies that a “closer agent” is available to receive the call before launching it; LiveVox HCI does not use any predictive algorithms in launching the calls. Finally, Defendant’s evidence showed that LiveVox HCI has no capacity to “store numbers to be called, to produce numbers to be called using a random or sequential number generator, or to dial numbers automatically.”

Plaintiff countered that HCI certainly has the ability to store numbers to be called—dialing campaigns are set up in the system just like in a predictive dialing system. But the Court recognizes that calls to those stored numbers only occurs by a result of “human intervention”—the system does not have the capacity to “automatically” dial. And the Court rejects Plaintiff’s argument that the level of human intervention involved is too minimal—although the Plaintiff asserts that the human involvement is “unnecessary” and designed solely to avoid TCPA liability (hey, what’s wrong with that?) the Court concluded that the level of intervention was sufficient to remove the device from statutory coverage.

As the Court puts it:

LiveVox HCI goes far beyond merely triggering a system to run automatically. It requires human interaction to initiate each call. The Court agrees with other courts to consider the LiveVox HCI system and, applying Marks, finds that the clicker agent’s role precludes LiveVox HCI from qualifying as an ATDS.

While Ammons—where have I heard that name before?—is obviously a big win for users of HCI, it stands tall as the first decision within the Ninth Circuit to delimit the extent of Marks. Notably the Court in Hatuey v. IC Sys., No. 1:16-cv-12542-DPW, 2018 U.S. Dist. LEXIS 193713 (D. Mass. Nov. 14, 2018) likewise concluded that the HCI system survived analysis even under Marks, (Good) Ammons is the first district court to consider the issue while bound to follow Marks.

Great win!

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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. 

ARLINGTON, Va. — Convoke, a leader in SaaS solutions for the debt collection market, today announced the most recent software update to its debt collections compliance and management hub. Each year, Convoke develops and releases several updates to its platform to support its clients’ evolving needs. This release includes the onboarding of three new credit issuers, as well its continued development of existing functionality.

“We are pleased to begin supporting three additional major credit issuers on Convoke as part of this release,” said Dave Pauken, CEO of Convoke. “Our increasing customer base and continuous platform enhancements are validation of the value that Convoke continues to deliver to the collections and recovery industry.”

New Customer Onboarding

As part of its latest release, Convoke is proud to introduce the support of three new credit issuers, all of which are included in the top 20 largest banks in the United States. Convoke’s continued market penetration demonstrates its relevance in providing solutions to the collections and recovery industry in an increasingly complex regulatory environment.

Platform Enhancement

In response to current customer needs, Convoke has introduced numerous enhancements to existing functionality across its platform, including the streamlining of the complaints, debt settlement, and legal processes and reporting, in addition to further integration with credit issuer systems. These improvements to the platform will further assist credit issuers in their regulatory compliance efforts and the consumer experience in the debt recovery process.

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About Convoke

Convoke is a leader in SaaS solutions for the debt collection market. It enables credit issuers to comply with regulatory and internal requirements and manage and monitor debt collection activities for all third-parties, while maximizing recoveries and realizing material cost savings. Convoke’s online platform is a central, validated and persistent hub that records, organizes and stores information and activities, facilitates, tracks and automates interaction with third parties, and provides powerful auditing, management and reporting tools. Convoke is headquartered in Arlington, VA. For more information on Convoke, please visit www.convokesystems.com.  

Editor’s Note: This article previously appeared on the Ontario Systems Blog and is republished here with permission.

Data privacy and data security are two very hot topics in the ARM industry today. The California Consumer Privacy Act (CCPA) is set to take effect in January 2020, with additional privacy bills now pending in at least 25 states. Meanwhile, cybercrimes involving consumers’ personal data are growing in number, size, and sophistication.

While ARM business leaders are rightly focused on these issues, many are uncertain about the true nature and extent of their compliance and security risks. They’re also not sure how to manage these risks effectively. 

Recently, I had the privilege of joining two distinguished industry colleagues for a panel discussion about data privacy and security: Odia Kagan, partner and chair of the GDPR Compliance and International Privacy division at Fox Rothschild LLP; and Ben Johnson, director of risk management for Cornerstone Support.

Here are some, but not all, of the major issues and topics we addressed (you can access the full webinar here). 

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Data privacy: Understanding and Preparing for the CCPA

The CCPA applies to any business or service provider that collects personal data, determines the purpose and means of data use, or controls or is controlled by such a company. 

Starting January 1, 2020, the CCPA will grant California residents certain rights pertaining to personal data collected since January 2019 (a 12-month look-back window). Residents will be able to file claims for data access or deletion or for an opt-out. Companies subject to the CCPA will have 45 days to respond. 

Types and uses of data covered under the law run the gamut. Personal data can include everything from Social Security numbers and birth dates to lead generation activity, online browsing history, and interactions with mobile apps.

“Information like name, email address, collections history, purchase history, payment history, and determinations that you make off this (this person is likely to pay on time, they’re not likely to pay on time)—all of those things were not considered personal information in the traditional sense under U.S. law. That all has changed.” – Odia Kagan

Your business may be in scope if you do business in California and meet the minimum business thresholds listed below. 

For purposes of CCPA compliance, doing business in California means: 

• Your headquarters are in California;
• Your employees are in California;
• Your company is incorporated in California;
• Your company satisfies the definition of a California foreign entity; or
• You conduct out-of-state sales or transactions into California.

Minimum business thresholds are defined as: 

• You conduct business activities in California and your annual revenues exceed $25 million;
• You’re involved with personal data of more than 50,000 consumers, households, or devices (this could even include unique blog visitors); or
• Sales of personal information—including value acquired from its use (via data analytics, for example)—accounts for at least 50% of your annual revenues. 

To better understand how CCPA might affect your business and to prepare for its impact, you’ll want to take the six important steps Odia outlined in detail:

• Map your data flows and processes
• Determine your role under the law (independent business, service provider, or vendor)
• Look carefully at legal purpose as well as GLBA and FCRA exemptions and whether they apply
• Determine how you’ll comply with consumer requests within the required 45-day window
• Reevaluate your internal processes
• Plan for CCPA disclosure 

“So it’s basically looking at processes, looking at the information, seeing how [you] get to it, how [you] can produce it. Then the other question is, ‘Once I know how to collect all of this information, how do I provide the disclosure that CCPA requires me to provide along with all the information I am giving?’” – Odia Kagan

Data security: Reducing the Risk and Impact of Cyber Crime

As Ben reminded us, cybercrime has been called “the greatest transfer of wealth in history.” The exchange of consumer data via ID theft, phishing, hacking, etc. has been compared with the global drug trade and is estimated to be worth as much as a trillion dollars per year. 

Guarding against breaches and developing a breach response plan are essential for managing risk and minimizing disruption, financial losses, and potential harm to client relationships.  

Have a specific plan in place

In a security breach “fire drill,” you should know whom to call and what steps to take. Ben recommends, among other things, a cyber liability insurance policy (with full limit breach notification response), an established reporting process, and discussions with a claim adjuster and legal counsel. A breach response should also include forensic analysis to assess the source and extent of the damage.

“Some of you saw there was a high-profile breach in the collection space earlier this year. One of the things that came out . . . was that maybe they took a little bit longer to get a plan in place and respond. And so at times, that can make the cost even greater or the damage even greater.” – Ben Johnson

Monitor operations in real-time

Many companies enlist a dedicated third-party provider to monitor operations and flag any security weaknesses and unusual activity. Identifying problems early on will allow you to limit or compartmentalize the damage.

Change the way you store old data

Many high-profile breaches have involved personal information that dates back 10 or more years. Storing too many old records is a serious potential liability. By encrypting older files and offloading them to an external (ideally cloud-based) server, you can effectively make the data worthless to hackers and avoid triggering notification responses.

“[Data] almost was seen as a . . . valuable asset—to have all this data, all of this knowledge, all of this experience. And secondly, data storage is relatively cheap. So another year goes by, another million records go on the server. [ . . . ] I think as an industry, collectively, we’ve really got to start sharing best practices, talking about what we’re doing to get old files offloaded.” – Ben Johnson

For More Answers and Advice, Catch the Complete Webinar

During our panel discussion, Odia and Ben covered a lot of territory. They offered detailed insights on the above topics and raised a number of other issues ARM business owners need to consider. “Straight Talk About Privacy, Security, and Cyber Liability for Debt Collectors” is one webinar you won’t want to miss. (See link in beginning of article to download). 

On October 8, the Consumer Financial Protection Bureau (CFPB or Bureau) published is Semi-Annual Report for Spring 2019, which covers the period between October 1, 2018, and March 31, 2019. While there has been a lot of debt collection related activity at the Bureau recently, the report—covering a time period prior to the release of the Notice of Proposed Rulemaking for debt collection—makes only a few mentions of debt collection practices.

Below are two areas of interest from the report regarding debt collection.

Credit Reporting Complaints Far Surpass Debt Collection Complaints

The report contains a snapshot of complaints received by the Bureau through its complaint portal as well as complaints forwarded to the Bureau from other regulators. The complaint snapshot reporting period, covering April 1, 2018, through March 31, 2019, is slightly longer than that of the Semi-Annual Report. In this time frame, the Bureau received 321,200 complaints, which is a 2% decrease from the prior reporting period. Companies had a 95% response rate for the complaints that the Bureau forwarded for review and response.

Most notably, credit reporting complaints are noted as the clear frontrunner, making up 39% of the consumer complaints—compared to 24% for debt collection complaints.

Editor’s Note: Previously, insideARM wrote about how certain credit repair organizations are flooding debt collectors with mass disputes and how a jury found one credit repair organization liable of fraud in relation to such practices. Through communication with industry members, it is believed that credit repair organization might also be flooding the CFPB complaint portal with similar disputes. 

Bureau Enforcement Actions Related to Debt Collection Practices

The only other area of the report that makes substantial mention of debt collection is the section outlining the Bureau’s enforcement activities. Below are a few of the actions mentioned, including the alleged problematic practices.

In re CMM/Cash Tyme (File No. 2019-BCP-0004): Making collection calls to third parties that risked disclosing information about debts. See insideARM article about the settlement of this matter here. 

In re Cash Express, LLC (File No. 2018-CFPB-0007): Collection letters threatening to take legal actions on time-barred debts despite the company policies against filing lawsuits on such accounts. Also, misrepresenting that the company might report negative information to the credit bureaus regarding late or missed payments when the company did not actually report this information. See the consent order here. 

In re Bluestem Brands, Inc. (File No. 2018-BCFP-0006): Delaying consumer payment transfers to debt buyers, causing consumers to undergo collection activity on accounts that are already paid. See insideARM article about the consent order here. 

In re National Credit Adjusters, LLC (File No. 2018-BCFP-0004): Using a network of debt collectors who represented to consumers that they owed more than they actually did and threatening consumers with visits by process servers and arrest. See the consent order here.

In re Security Group Inc. (File No. 2018-CFPB-0002): In-person collection visits where consumers were physically blocked from leaving their homes, and placing collection calls to consumer’s workplaces and references. See the consent order here. 

[Note: While not related to debt collection practices, the enforcement action against Freedom Debt Relief is also of interest to the industry, so it is included below.]

In re Freedom Debt Relief, LLC (N.D. Cal., Case No. 15-cv-6484): Debt relief company that allegedly misled consumers about its ability to negotiate settlements and charging consumers without settling debts as promised. See the consent order here. 

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insideARM Perspective

While this report has only several mentions of debt collection, it is anticipated that the next semi-annual report—which will cover a period including the release of the NPRM as well as the comment period—will contain significantly more information. It is also encouraging to see that debt collection complaints are declining. With that said, debt collectors and creditors who furnish data to the credit bureaus should be aware that the Bureau might be honing in on credit reporting. Not only is it now the most complained about “product,” but credit reporting was also front-and-center in the Bureau’s most recent Supervisory Highlights.

NEWTON, Mass. — Goldberg & Oriel is pleased to announce the expansion of its practice through a merger with Frank J. Maier & Associates of Worcester, MA.  The firm has also added industry veteran Dean Heinold as a Senior Attorney as well accomplished operational executive Jarrad Glennon, and promoted Madeline Baron to Senior Compliance Attorney.

Goldberg & Oriel now offers well over 100 years of combined experience in successfully collecting monies owed for its valued clients.  Through the merger, Attorney Maier’s longstanding credit union and commercial client base will benefit from the technology and compliance expertise of Goldberg & Oriel’s platform, while the combined firm enhances its ability to effectively and efficiently drive results on behalf of its client base.

Dean Heinold brings over 20 years of high-volume collections experience to the firm.  Jarrad Glennon brings a unique operational perspective having led a variety of businesses throughout his career, from startups to enterprise companies.  Madeline Baron’s well-earned promotion to Senior Compliance Attorney is a testament to her knowledge of all compliance-related issues. All will play central roles as Goldberg & Oriel positions itself as a leader in the New England debt collection legal market. 

Based in Massachusetts, Goldberg & Oriel assists a wide variety of clients with the collection of consumer and commercial debts, both in New England and throughout the country via their rigorously-vetted network of national attorneys. 

Goldberg & Oriel
199 Wells Avenue, Suite 209
Newton, MA 02459
Email: dgoldberg@golawoffices.com
Phone: 617-969-1111
Fax: 617-969-1116

WASHINGTON, D.C. — The Estate Debt Coalition (“EDC”), a coalition of three of the largest specialized debt collection agencies that focus on estate debt – AscensionPoint Recovery Services, LLC., Estate Information Services, LLC, and Phillips & Cohen Associates, Ltd. – was pleased to respond to the Consumer Financial Protection Bureau’s (CFPB) recent Notice of Proposed Rulemaking (NPRM) for debt collection practices. 

“As the industry’s only coalition of estate account specialists, we appreciate the efforts the Bureau has made to meet with us to understand the unique nature of our industry and the ways our specialized procedures have evolved over the years,” said Jonathan Grossman, Spokesperson for EDC. 

“Our members take very seriously the delicate nature of their responsibilities, and we applaud CFPB’s efforts to learn more about the processes and procedures involved in resolving the debts of estates,” Grossman continued. “Our goal is to ensure that the rules promulgated take into account the unique factual circumstances surrounding estate debt in order to protect consumers, while also not creating unintended barriers to fair and efficient estate resolution.”

“Most importantly, the CFPB has agreed with the guidance published by the Federal Trade Commission, which became the industry standard in 2011, and concluded that the FDCPA permits estate debt collectors to communicate with individuals acting in the capacity of estate administrators or executors, even if those people have not been formally appointed to those positions.”

EDC’s other comments are as follows:

• With respect to location communications, the final rule should adopt the 2011 FTC guidance in which estate specialists could ask for the person “who has the authority to pay the outstanding bills of the decedent out of the assets of the decedent’s estate.”  For eight years, this language has facilitated the accurate and efficient identification of the individual with the responsibility of resolving the estate. 
• The CFPB should require affirmative disclosure that the individual handling the estate is not personally liable for the debt of the estate.
• A cooling off period after the death of 21-28 days during which collectors cannot contact consumers is reasonable, so long as it does not apply when the personal representative of the estate affirmatively contacts the collector.
• Consistent with its position expressed throughout the NPRM, the CFPB should add to the list of individuals included in the definition of “consumer” in § 1006.6 the “Personal Representative of the consumer’s estate, which includes any person who is authorized to act on behalf of the deceased consumer’s estate.”
• The final rule should include a model validation notice for estate collections.

You can view and download a copy of EDC’s full comment letter, here. 

About the Estate Debt Coalition 

The Estate Debt Coalition is comprised of three of the largest debt collection agencies that specialize in decedent debt: AscensionPoint, Recovery Services, LLC; Estate Information Services, LLC; and Phillips & Cohen Associates, Ltd. The coalition works to ensure that federal, state, and local laws, rules and regulations are applied to the unique area of estate debt collection in a manner that simultaneously protects the rights of consumers and allows for the efficient resolution of estates. As the leaders in this unique industry, our members strive to ensure that best practices are advanced industry-wide.