Yesterday, the Consumer Financial Protection Bureau published a report on the issues and trends revealed through Suspicious Activity Reports (SARs) on elder financial exploitation (EFE). In addition to reviewing the data provided through SARs, the Bureau recommends steps that financial services institutions – including both depository institutions and money servicing businesses – can take to protect older consumers.

Rise in SARs Related to EFE

According to the report, EFE is a widespread problem and the most common form of elder abuse. As of April 2013, federal law mandates that financial institutions report suspicious activities through SARs. SAR filings quadrupled from 2013 to 2017. In 2017, financial institutions filed 63,500 SARs related to $1.7 billion in suspicious activity. It is likely that many incidents go unreported, meaning this number represents only a small fraction of actual EFE.

Missed Opportunity to Help Consumers

The report notes that while many financial institutions are filing SARs, fewer than one-third of these SARs are reported to law enforcement or adult protective services. According to the Bureau, “this is a missed opportunity to increase investigation and prosecution, and make it more likely that victims will receive appropriate services.”

SARs from Depository Institutions and Money Servicing Businesses

Both depository institutions and money servicing business – including money transmitters, who accept funds from one person and transmit those funds to another location or person – must report suspicious activities. In 2013, a higher percentage of SARs came from depository institutions. However, this changed in recent years. In 2017, 58% of SARs were filed by money servicing businesses.

Types of EFE

The type of reported EFE activity varied depending on the reporting institution. The report classifies suspicious activities as either scams or non-scams. Scams include schemes involving a transfer of money to a stranger for a promised benefit that the older adult did not receive. Non-scams include activities such as theft by family members, account takeovers, and identity theft. At depository institutions, non-scam activities see the bulk of reporting, whereas scam activities are more prevalent at money services businesses.

Bureau’s Recommendations to Financial Services Institutions

The differentiation discussed above, according to the CFPB, means that interventions can be tailored accordingly. The Bureau recommends the following to the two different types of financial institutions.

For money services businesses:

Money services businesses could prevent more losses by blocking money transfers to people who previously aroused suspicion, providing conspicuous warnings about current scams on money transfer forms, and thoroughly training all agents, from the large chains to the small stores. MSBs could assist victims of fraudulent activity by refunding money transfer amounts and associated fees when appropriate and by ensuring that agents and frontline employees are complying with anti-fraud programs and controls.

For depository institutions:

Depository institutions could prevent or limit losses by improving fraud detection technology to reflect transaction patterns most prevalent when older account holders become victims and by using machine learning to obtain specific and timely information indicating fraudulent activity. Depository institutions can promote use of alerts on checking and savings accounts, and can offer services to enable trusted relatives and friends to help detect elder financial exploitation. Financial institutions, regulators and policymakers could collaborate to identify and consider any changes needed to enable depository institutions to hold transactions while investigating suspicious activity. They might want to look at state activity in this arena. Several states allow transaction holds when staff observe financial exploitation and report it to APS and/or law enforcement. These states provide timeframes for the transaction holds and provide immunity for institutions and employees who take these protective steps.

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insideARM Perspective

As the Bureau notes, elder abuse in the form of EFE is a widespread problem and the SAR data shows only the tip of the iceberg. This means that this issue could see the spotlight soon and this might be a great time for debt collectors and other financial institutions to revisit their policies, procedures, and training materials. While creditors often provide requirements for their debt collection agencies to follow for reporting suspicious activity, it never hurts to do a quick pass over those requirements to ensure consistency with the Bureau’s guidance.

By speaking directly with consumers, a well-trained collector is in a position to detect if something feels off about the conversation and put the wheels in motion to potentially stop EFE in its tracks. This, unfortunately, is undermined by the authentication hurdles faced uniquely by debt collectors when they attempt to communicate with consumers. A solution to the authentication issue could be an extra step towards protecting older consumers from EFE.

On February 12, 2019, the Consumer Financial Protection Bureau (CFPB or Bureau) published its Fall 2018 Semi-Annual Report to Congress. This is the first Semi-Annual Report released under Director Kathy Kraninger. The report covers the Bureau’s activities from April 1, 2018 through September 30, 2018, which is before Director Kraninger began her tenure as the Bureau’s leader in December 2019.

Credit Invisibility and Access to Credit

The report starts off by discussing the impact that credit invisibility has on consumers and their access to credit. Credit invisibility refers to consumers without credit records from the three major national credit reporting bureaus and consumers who have too little or too old information on their credit reports, resulting in the inability to calculate an accurate score.

To pinpoint the problem, the Bureau narrowed down the individuals most at risk of credit invisibility. Roughly 90% of consumers find their way out of credit invisibility – whether it be through a credit card or some other point of credit entry – by their mid-to-late twenties. Due to this, the report focuses on adults over the age of twenty-five to determine areas where credit invisibility is prevalent and what factors impact whether or not consumers make their way out of credit invisibility.

This issue appears to be rooted in geography as well as internet accessibility. Geographically, credit invisibility appears to be concentrated in rural and highly urban areas. Credit invisible consumers make up a large percentage of the population in rural areas. However, as a whole, more than two-thirds of credit invisible consumers reside in metropolitan areas, likely due to the higher population in urban areas. However, the report notes that access to a bank branch is not the only issue – internet access plays a large role as well. This is because many credit options today originate through online means.

Mortgage Shopping

The report also points out that most consumers do not shop around for mortgages, leading them to miss out on savings. Over 30% of consumers did not comparison shop for their mortgage, and over 75% applied for a mortgage with only one lender. Some reasons for this include constantly varrying interest rates, the belief that there is not much difference between what different lenders offer, and a reluctance to provide their personal financial information to multiple lenders, which is usually required to receive an accurate quote.

Consumer Complaint Analysis

According to the report, the Bureau received 329,000 complaints between October 1, 2017 and September 30, 2018. “The Bureau does not verify all the facts alleged in complaints,” says the report, “but gives companies the opportunity to confirm a commercial relationship with the consumer before providing a substantive response.” Of the complaints that passed this threshold, companies responded to 93%.

The report drills into the volume of complaints by credit product type.  Credit or consumer reporting led the pack, accounting for 37% of the complaints, with debt collection next at 25%.

Editor’s Note: The credit products listed are not mutually exclusive. The remaining items were different loan or credit product types (e.g., credit card, mortgage, student loan, vehicle loan). For example, a complaint can be related to both a credit card and credit reporting, or a student loan and debt collection. This overlap creates risk of inaccurate data. Also, these are consumer selected categories and the report provides no indication that the process includes a check to ensure consumers selected the correct option.

Enforcement Actions

The report offers a laundry list of Bureau enforcement actions in the same period. Some actions relevant to the ARM industry include:

• Triton Management Group, Inc., where a consent order was entered for allegedly deceiving consumers and violating TILA disclosures related to Annual Percentage Rates.
• National Credit Adjusters, LLC, where a consent order was entered for allegedly engaging in unfair and deceptive acts in the collection and sale of consumer debt.
• Citibank, N.A., where a consent order was entered for allegedly misleading borrowers into believing they had not paid their student loan interest that as eligible for tax deductions and incorrectly terminating borrower’s school deferments, resulting in late fees and additional interest.
• Security Group, Inc., where a consent order was entered in regards to in-person collection visits and collection calls to consumers’ workplaces and references as well as improper credit furnishing practices.
• Freedom Debt Relief, which is an ongoing action alleging that Freedom misled consumers about its ability to negotiate settlements with all creditors and about the circumstances under which it charges fees.

The report also discusses two widely-reported court cases filed by the CFPB. The first was against Weltman, Weinberg & Reis Co., LPA, a case which the court ruled against the CFPB and found that the law firm had sufficient attorney involvement in its collection case. The second was against RD Legal Funding, which counterclaimed the Bureau’s complaint alleging that the Bureau’s structure is unconstitutional. This case is currently on appeal in the Second Circuit.

Timing really is everything. 

As TCPAWorld continues to struggle with the evolving definition of the TCPA’s critical “automated telephone dialing system” (“ATDS”) language, a court in New York has given us a new way to look at the issue—and it’s all about timing. 

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In Duran v LaBoom Disco, Case No. 17-cv-6331, 2019 U.S. Dist. LEXIS 30012 (E.D.N.Y.) the court entered judgment in favor of a text message TCPA defendant sua sponte (!) because the text platforms it utilized were not capable of selecting the timing of text message campaigns without human intervention. This is true although the system automatically sent text messages from a list after the campaign commenced. 

In Duran the Plaintiff moved for summary judgment arguing that the Defendant’s text message platforms—ExpressText and EZ Texting—were automatic dialing systems governed by the TCPA. The Plaintiff argued that these systems were not “click to dial” systems and that the Defendant could command the system to send thousands of texts at a time. After first determining that the Defendant did not have consent to send the telemarketing messages at issue in the case the Court analyzed Plaintiff’s challenge to the ATDS issues. In addressing those issues—and after carefully reviewing the Second Circuit’s King decision— the Duran Court determined that the 2003 Predictive Dialer ruling survived ACA Int’l at least in so far that a dialer is not categorically exempted from the TCPA merely because it calls from a list of numbers; i.e. the Duran court refuses to require “random or sequential number generat[ion]” as the hallmark of ATDS usage. See Duran at * 18. 

That doesn’t sound good, but what the Court does next is brilliant.  In applying the 2003 predictive dialer rulingDuran focuses on the FCC’s decision to regulate predictive dialers—specifically dialers that select the timing of calls to be made. As the Court put it: “when the FCC expanded the definition of an autodialer to include dialers, the FCC predictive emphasized that ‘[t]he principal feature of dialing software is a predictive timing function.’ 2003 Order, supra, ¶ 131 (emphasis added). Thus, the human-intervention test turns not on whether the user must send each individual message, but rather on whether the user (not the software) determines the time at which the numbers are dialed.” Duran at * 32. Interesting, no?

 The Court also defended the FCC’s focus on such dialers as based on sound logic: “the requirement that a computer determine the time in order for the device to qualify as ATDS is not arbitrary… the FCC decided to include predictive dialers under the statutory definition of an ATDS because…  programs with computer-run timing functions have the capability to barrage consumers at a higher rate than programs requiring more human involvement.” See Duran at * 35. 

After walking through this analysis the Court holds: “because a user determines the time at which the ExpressText and EZ Texting programs send messages to recipients, they operate with too much human involvement to meet the definition of an autodialer.” Id. At *36. Not only did the Court deny Plaintiff’s motion for summary judgement, therefore, it actually ended up granting judgment to the Defendant—with no formal motion needed—given the human intervention needed to select the time the messages were sent.

So there you have it TCPAworld. As we continue to struggle with the contours of the TCPA keep in mind that in evaluating whether a system is an ATDS_-as in life— timing is everything.

—

Editor’s Note: This article is published on insideARM with permission from the author.

On February 25, 2019, the Federal Trade Commission (FTC) and the Consumer Financial Protection Bureau (CFPB or Bureau) have renewed their Memorandum of Understanding. The memorandum recognizes that both agencies share the responsibility of protecting consumers and enforcing consumer financial protection laws under the Consumer Financial Protection Act of 2010. The cooperative agreement seeks to avoid duplicative work by the agencies.

The Memorandum, signed by the CFPB’s Director Kathy Kraninger and the FTC’s Chairman Joseph Simons, discusses several areas of cooperation. Four areas in particular are of interest to the ARM industry.

1. Enforcement Actions

According to the memorandum, the agencies shall:

• Coordinate law enforcement activities, including conducting joint investigations where appropriate. The memorandum lays out procedures that the agencies shall follow throughout the lifecycle of enforcement proceedings.
• Share resources where applicable.
• Have a meeting at least annually with designated representatives from each agency to discuss legal issues and ensure to the greatest extent possible that both agencies are putting forth consistent interpretations of consumer financial protection laws.

2. Rulemaking

The memorandum also discusses rulemaking, requiring both agencies to give notice to each other of their rulemaking plans and agendas. This is in order to ensure consistency and avoid duplication in rules regarding certain spheres of consumer financial protection laws. Both agencies agree to consult with each other as they work towards setting parameters for the laws that they have authority to engage in rulemaking for.

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3. Supervision and Examination

The CFPB agreed to share its examination schedule with the FTC. Additionally, the CFPB will confer with the FTC regarding its examination plans and results. The agreement also allows the CFPB to share confidential supervisory information with the FTC upon written request.

4. Consumer Complaints

Regarding consumer complaints, the agreement states that the CFPB facilitates the centralized collection of, monitoring of, and response to consumer complaints. The CFPB routes complaints to the FTC where appropriate. The memorandum also calls for the CFPB to “share consumer complaint information with the FTC into the Consumer Sentinel Network so that such information will be made available to all other law enforcement organizations that use Sentinel.”

insideARM Perspective

A quick note about the Consumer Sentinel Network, where the CFPB routes complaints. As mentioned above, it is available for other law enforcement organizations to review with the goal that “information sharing can make law enforcement even more effective,” according to the FTC’s website. The list of members with access to view the confidential information in the sentinel is extensive. It includes many federal, state, and local regulators and law enforcement agencies. Back in 2012, the CFPB announced that it would be sharing its complaint data with state regulators, so the information sharing is no surprise. However, sometimes it’s good to be reminded to take care with responses to these complaints because they are seen by many eyes.

TREVOSE, Pa. — Ralph Liberio, President & Chief Executive Officer announced today that NCB Management Services, Inc., a privately held national debt buyer and collection agency has signed a new, multi-year lease on a state-of-the-art collection call center facility in Lincoln, NE.   

NCB’s COO, Susan Richards commented, “We are very excited to expand our operations into Lincoln, NE.  This new location will assist NCB with expanding our overall debt purchasing capacity and collection resources with a quality workforce that the Lincoln community offers”.

For more information about servicing or employment opportunities with NCB Management Services, Inc. please contact Brad Berens, EVP of Operations and Site Manager at 1-855-819-8108 or visit www.ncbicareers.com.

About NCB Management Services, Inc.

NCB Management Services, Inc., established in 1994, is headquartered in the Philadelphia area with satellite offices in Jacksonville, FL, and Sioux Falls, SD.  NCB is a recognized Accounts Receivable Management (ARM) industry leader as well as a nationally respected debt buyer. The company is partially owned by its employees through an Employee Stock Ownership Plan (ESOP). The NCB ESOP is a company-funded defined contribution retirement plan established in 2014 for the benefit of NCB employees.

ROCKVILLE, Md. — Last week the iA institute (parent of insideARM) hosted a roundtable discussion among consumer advocates, regulators, and members of the collection industry. The dialogue was in-depth, candid and engaging. In total, 20 organizations participated, including six consumer groups, two regulators, two creditor trade groups, and ten members of the the Consumer Relations Consortium (CRC).

This session was the seventh of such meetings hosted by the iA institute on behalf of the CRC over the last several years. The goals — to increase understanding of the complexity of the collection process, to identify common ground, to explore creative solutions to challenges facing consumers and industry, and to build trusted relationships — have been the hallmark of the CRC since its inception in 2013.

“This is a unique forum in the debt collection space,” said Stephanie Eidelman, Executive Director of the CRC. “We bring stakeholders together and facilitate a high quality dialogue that goes deeper than the standard public talking points. The facts are always more nuanced than they appear on the surface, and these can only be truly explored in a small, off-the-record setting.”  

Spanning five hours, the sessions always cover a fair amount of ground. At a high level, last week’s topics included the concept of a consumer’s right to request a suspension of collections, the idea of delivering disclosures in a way that consumers can digest and understand, the challenge collectors face in today’s world which demands that transparency be reconciled with the FDCPA’s third party disclosure prohibition, and the uncomfortable authentication dance faced by consumers and collectors in order to begin a conversation.

The CRC will continue to host these dialogues; they are consistently well-received and well-attended, and have contributed to insight into where there are common interests and where there is misunderstanding.

About the Consumer Relations Consortium and the iA institute

The Consumer Relations Consortium (CRC) is a membership group for forward-thinking creditors, technology providers, and larger collection agencies. The CRC has two primary areas of focus: Regulation and Innovation. We engage within the group and externally — with regulators, consumer groups and other stakeholders — to produce common sense legal, process and technology solutions that benefit consumers, creditors and servicers. An important hallmark of the CRC is that the group is small enough to remain nimble and creative, yet large enough to be impactful and representative of the industry. Read more at www.crconsortium.org

The CRC is managed by the iA institute, a media company that influences the professional debt collection community, including those responsible for managing, recovering, and regulating consumer debt. Thousands know us for our flagship publication, insideARM. Beyond the news, iA institute initiatives bring a range of stakeholders to the table in candid and intimate environments to inform, to build a culture of compliance, to actively address industry challenges, and to make profitable connections. The iA institute (under the name insideARM, LLC) is a certified woman-owned and woman-controlled business (WBE) by NWBOC. Read more at www.theiAinstitute.com

This morning, the U.S. Supreme Court issued an order list addressing whether or not it approved certain cases to be reviewed by the court. The order lists one case which insideARM previously wrote about – Huebner v. Midland Credit Management, No. 18-991 —  on the list of denied cases, which means it will not be heard by the court.

We nicknamed Huebner as the “triple-whammy” petition because it asked the Supreme Court to review three relevant debt collection questions that the different Circuit Courts of Appeal do not agree on. Those three questions are:

1. Whether a consumer’s dispute needs to be in writing in order for it to trigger the Fair Debt Collection Practices Act (FDCPA);
2. Whether a debt collector can inquire about the reason for the consumer’s dispute; and
3. Whether the least sophisticated consumer standard is a question of law or a question of fact.

Unlike the Circuit Courts of Appeal, where the parties have a right to have their appeal heard, the U.S. Supreme Court has discretion to choose which cases it will review. To submit a request for the Supreme Court to hear a case, the appealing party files a petition for writ of certiorari. The Supreme Court gets a high volume of petitions and only accepts a small amount of cases. For example, the order referenced above included only one accepted case and a 9 page list of cases where the petition was denied.

insideARM Perspective

The industry is going to have to wait a little longer for an answer to the written requirement question for disputes under section 1692g of the Fair Debt Collection Practices Act (FDCPA). As previously reported on insideARM, there is a jurisdictional split about whether all subsections of 1692g require a dispute to be made in writing. According to the Third Circuit in Graziano v. Harrison, all disputes need to be in writing in order to trigger the FDCPA — an issue that prompted an open letter to the Consumer Financial Protection Bureau.

Fortunately, the Supreme Court’s denial to hear the case means that the Second Circuit’s decision in Huebner stands.

With the volume of decisions popping up within the Third Circuit on the issue (and the hurdles faced by debt collectors due to the jurisdictional split), it seems likely that we will see another petition before the U.S. Supreme Court… and hopefully soon.

Are passive debt buyers debt collectors under the Fair Debt Collection Practices Act (FDCPA)? According to the Third Circuit Court of Appeals in its decision in Barbato v. Greystone Alliance, LLC et al., No. 18-1042 (3d Cir. Feb. 22, 2019), a debt buyer that purchases debts but does no direct collection activity (passive debt buyer) is, indeed, a debt collector and subject to the FDCPA.

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The decision breaks down the FDCPA definition into two categories. According to the court, a debt collector is “any person (1) who uses any instrumentality of interstate commerce or the mails in any business the principal purpose of which is the collection of any debts… or (2) who regularly collects or attempts to collect, directly or indirectly, debts owed or due or asserted to be owed or due to another.” (Internal quotations omitted.)

While the U.S. Supreme Court stated that a debt buyer is not a debt collector under the latter prong in Henson v. Santander, the consumer here argued that the first prong applies to Crown Asset Management, which purchases debt and has third party collection agencies conduct collection activity. The Middle District of Pennsylvania agreed with the consumer, and now so does the Third Circuit.

The decision discusses the impact of Henson on Third Circuit precedent. Prior to Henson, the Third Circuit used a “default test” to determine whether an entity was a creditor or a debt collector. If the account was acquired prior to default, then the entity is a creditor. If after default, then debt collector. Henson rejected the default test, which now means that the terms “creditor” and “debt collector” are not mutually exclusive.

Since Henson did not address the first prong of the definition and since the two definitions are not mutually exclusive, the court found little weight in applying Henson to its review of the instant case.

Turning to the “principal purpose” discussion, the court rejected Crown’s argument that this applies only to overt collection activity. The court instead found no distinction in whether the collection activity was direct or indirect. The court states:

“Collection” by its very definition may be indirect, and that is the type of collection in which Crown engages: it buys consumer debt and hires debt collectors to collect on it. The existence of a middleman does not change the essential nature—the “principal purpose”—of Crown’s business. As Barbato points out, Crown could buy debt for the charitable purpose of forgiving it, or it could buy debt for the purpose of reselling it to unrelated parties at a profit. In both of those cases, the entity’s “principal purpose” would not be collection. But Crown does neither of those things. Indeed, the record reflects that Crown’s only business is the purchasing of debts for the purpose of collecting on those debts, and, as Crown candidly acknowledged at oral argument, without the collection of those debts, Crown would cease to exist. In short, Crown falls squarely within § 1692a(6)’s “principal purpose” definition.

insideARM Perspective

The Third Circuit’s summary of the District Court’s decision states the following regarding vicarious liability:

The District Court nevertheless denied Barbato’s motion for summary judgment, holding that she had not established that Crown was vicariously liable for Turning Point’s conduct because (1) in the District Court’s view, vicarious liability could be imputed to Crown in these circumstances only if the agent too was a “debt collector,” and (2) the evidence in the record was insufficient to hold that Turning Point was a debt collector under the FDCPA.

(Emphasis added.)

What does this imply? Does this mean that that a passive debt buyer is on the hook for alleged FDCPA violation of its third party collection agency if both are found to be debt collectors by a court? With the current state of litigation and pre-litigation claims against debt collectors, often times filed in droves on hyper-technical issues, what impact will a decision like this one have on the operational relationship between passive debt buyers and their collectors?

Last week, the Federal Communications Commission (FCC) announced that it released proposed rules banning illegal spoofed text messages and calls from overseas, where it is widely believed many of these spoofed communications originate. A copy of the Notice of Proposed Rulemaking can be found here.

The RAY BAUM’S Act of 2018 extended the applicability of the Truth in Caller ID Act of 2009 to calls and text messages that originate from outside of the country. The proposed rules implement the statute and extend the prohibitions to short message service (SMS) and multimedia message service (MMS) text messages as well as one-way interconnected VoIP calls.

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In their individual statements, the Commissioners unanimously supported the action, although some are more reserved about the solution than others.

“While the expanded jurisdiction provided by [RAY BAUM’S] Act won’t solve all the challenges involved in bringing foreign criminals to justice, such as obtaining traceback-related subpoenas and accessing the cooperation of countries with weaker legal institutions, the explicit provisions should at least help the Commission cut through red tape in friendly nations,” states Commissioner O’Reilly.

Chairman Ajit Pai stated that the FCC received more than 52,000 complaints last year about caller ID spoofing and discussed how he demanded earlier this week that industry deploy a robust caller ID “authentication” system. Commissioner Carr notes that robocalls are the FCC’s top enforcement priorities. However, Commissioner Rosenworcel argues that the Commission is not doing enough in the enforcement category considering the prevalence of the issue. She states:

But I think rulemakings and reports have their limitations. It’s action that counts. In the past twenty-four months, this agency has had no more than a handful of enforcement actions involving illegal robocall[] schemes. Our work is too slow. We are trying to empty the ocean with a teaspoon. We need more dedicated resources. […] Why not create a division that will combat robocalls? If year-in and year-out this is the single largest source of consumer complaints at this agency, how about organizing our enforcement efforts to reflect that? I think that’s what we need to do and I think the time to do it is now. Before spoofed calls, robocalls, Rachel calls, or any of it gets any worse

According to Commissioner Starks’ statement, innovation must continue at the FCC. “We must continue to refine our tools, because we can be sure robocallers will try to find new and innovative ways to break through. In this battle, this additional authority [provided by RAY BAUM’S ACT] is essential and welcomes – the Commission will be better able to find illegal robocallers, stop them, and hold them accountable.”

insideARM Perspective

The proposed rules were issued on the same day as the report on illegal robocalls. The report mirrors the Commissoners’ statements above about the prevalence of spoofed robocalls and discusses the different initiatives the FCC has undertaken to combat this issue. The report listed four challenges facing the FCC in enforcement against spoofed robocalls:

• Many illegal robocalls seem to originate in foreign countries.
• These calls appear to be coming from VoiP providers, many of whom do not update the FCC nor keep accurate records of all calls made across their networks
• The short statute of limitations for Telephone Consumer Protection Act (TCPA) actions makes it difficult for the FCC to complete complex investigations into the issue.
• Notice via citation requirements that the FCC must follow prior to a forfeiture proceeding give time for offenders to incorporate under a new name and evade the issue.

The proposed rules would likely address the first issue, but the other three remain open. Solving for these issues isn’t simple. For example, increasing the statute of limitations for the TCPA might give more time for the FCC to investigate overseas spoofers, but it would cripple businesses — some to the point where they can no longer operate and have to close — because of the downpour of TCPA litigation resulting from inconsistent court rulings and lack of clarity from the FCC in how the statute should be interpreted. Any solution to the above-listed challenges must be viewed in context of the whole landscape.

WESTBOROUGH, Mass. —  Associated Credit Services, Inc. (ACS), headquartered in Westborough, MA, is proudly celebrating its 50 year anniversary with the announcement of the opening of a second call center in Tewksbury, MA. The new state of the art call center more than doubles ACS’ collection capacity.

ACS President and CEO Andrew Robinson commented, “ACS is proud to provide this new state of the art call center to our clients and employees. We are grateful to our legacy client partners for rewarding our commitment and performance with significantly increased market share, and to the many new clients who are just beginning to experience the proven advantages of our approach. With that added trust comes our additional responsibility to ensure that we have the capacity to continue to perform at the highest level and exceed client expectations. Our new call center ensures exactly that.”

About Associated Credit Services, Inc.

Established in 1969, ACS is celebrating 50 years as an award winning accounts receivable management company boasting an A+ rating with the BBB. ACS specializes in Banking, Utility, Healthcare, Insurance and Commercial third party collections as well as first party Default Prevention initiatives. For more information about Associated Credit Services, Inc. you can view our website at www.acsrecovery.com or contact us at 1-800-531-6500. You can also connect with us on LinkedIn at https://www.linkedin.com/company/associated-credit-services-inc-acs- 

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