Shaun Ertischek, Esq. appointed Chief Compliance Officer and General Counsel of Cascade Receivables Management, LLC

PETALUMA, Calif. — The Cascade365 Family of Companies is excited to announce that Shaun Ertischek was appointed the Chief Compliance Officer and General Counsel of Cascade Receivables Management, LLC. 

In this role, Mr. Ertischek will oversee all compliance, regulatory, litigation, and contractual matters for the company. He will take a proactive and strategic role in ensuring enterprise-wide compliance with all applicable laws in collaboration with the management team. The compliance team will report directly to him in support of the company’s efforts to mitigate risk and ensure the responsible liquidation of accounts receivable.    

Mr. Ertischek has over 16 years of experience in the legal and compliance field within the accounts receivable management industry.  Prior to joining Cascade, he served as Chief Compliance Officer and General Counsel at Sequium Asset Solutions, LLC, a national collection agency and outsourced call center. He also spent ten years as General Counsel for TRAKAmerica, a legal network management company, and previously served as in-house counsel at Cavalry Portfolio Services, LLC, a debt buyer and collection agency.  Additionally, Mr. Ertischek spent time in private practice at law firms handling both litigation and transactional financial law matters. 

Mr. Ertischek earned his Juris Doctorate from New York Law School.  He is also a graduate of Binghamton University, holding dual bachelor’s degrees in both Economics and Philosophy, Politics & Law (PPL).  He has been awarded the Credit and Collection Compliance Officer (CCCO) and the International Federation of Certified Collection Executives (IFCCE) designations by ACA International, Inc.

“I am ecstatic that Shaun has joined the team,” said Lee Brockett, Managing Director at Cascade. “His experience and expertise will help ensure that our legal, compliance and risk mitigation efforts are best in class.  Shaun will be instrumental in Cascade’s ongoing success as we continue a trajectory of sustained growth.”

“I am honored to work with the talented executive team at Cascade to further enhance their strong culture of compliance,” said Mr. Ertischek. “Cascade is a true leader in the world of accounts receivable management, collections, debt purchase and specialty finance.  I am excited to support the organization’s endeavors, including strengthening its compliance management system and helping to structure innovative solutions for its clients.” 

About The Cascade365 Family of Companies 

Cascade365 is a brand identity representing a family of companies focused on the responsible liquidation of accounts receivable.  Headquartered in the San Francisco Bay area, the Cascade365 Family of Companies are recognized leaders in the accounts receivable management, revenue cycle and specialty finance industries. Cascade365’s suite of products and services include AR Purchase and Finance, Master Servicing, Third Party Collections, and Revenue Cycle Optimization.  The Cascade365 Family of Companies believes in promoting financial accountability while treating consumers and patients in a fair, dignified, and lawful manner.  For more information, please contact Jeffery Howell, Director of National Sales at 707-244-2298 or via email at jhowell@cascade365.com.

Shaun Ertischek, Esq. appointed Chief Compliance Officer and General Counsel of Cascade Receivables Management, LLC
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FTC Enters Consent Agreement with Payment Processor for Opening Merchant Accounts for Fictitious Companies

On March 15, the Federal Trade Commission (FTC or Commission) released a consent agreement with Electronic Payment Systems and its owners John Dorsey and Thomas McCann (collectively, EPS) for allegedly opening credit card processing merchant accounts for fictitious companies on behalf of Money Now Funding (MNF).

The complaint filed against EPS alleges that it had opened 43 different merchant accounts for fictitious businesses on behalf of MNF, which aided that company in laundering millions of dollars of consumers’ credit card payments. Moreover, the complaint alleges that EPS knew these merchant accounts were fake and aided MNF in its illicit activities.

In 2015, MNF settled allegations with the FTC that it had telemarketed worthless business opportunities to consumers and falsely promised that consumers would earn thousands of dollars in income. Thus, according to the FTC’s complaint, MNF engaged in credit card laundering by creating fictitious companies that, through a sales agent, submitted applications for merchant accounts to EPS, which then opened merchant accounts in the names of these fictitious companies. The alleged victims’ credit card charges were processed through those accounts, rather than through one merchant account in the name of MNF.

“Companies involved in payment processing can’t ignore red flags that fraudsters are using the system to steal people’s money,” said Samuel Levine, director of the FTC’s Bureau of Consumer Protection. “It’s urgent that our authority to get money to consumers be restored, but in the meantime, we’ll do everything we can to stop scammers and those who help them.”

The consent agreement will be subject to public comment, after which the Commission will determine whether to make the proposed consent order final. The FTC is unable to seek monetary redress due to the Supreme Court’s decision in AMG Capital Management v. FTC, discussed in our blog post here. However, under the consent agreement, EPS would be (1) prohibited from credit card laundering and any other actions to evade fraud and risk monitoring programs, (2) prohibited from providing payment processing services to any merchant that is, or is likely to be, engaged in deceptive or misleading conduct, as well as to any merchant that credit-card industry monitoring programs have flagged as high-risk for certain reasons, and (3) required to conduct detailed screening of potential merchants that conduct outgoing telemarketing or are engaged in certain activities that could harm consumers.

Troutman Pepper Take:  Although most payment processors do not engage in acts to aid in illicit behavior, this case is important because the FTC was not able to obtain monetary relief as it had in the past due to the Supreme Court’s AMG Capital Management decision. The FTC has been lobbying Congress to codify a statutory structure that will allow such damages, but Congress has failed to do so. We expect the FTC will continue lobbying Congress on this issue. We will continue to inform you about those efforts.

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Levy & Associates and Kodak Law Announce Business Combination

COLUMBUS, OH — Kodak Law, a tech-forward collection litigation law firm, and Levy & Associates, LLC, a leading collection/creditors’ rights firm, are announcing the combination of the two firms. Kodak Law has a large multi-state footprint representing clients in 14 states. Levy & Associates is a well-known firm in the receivables industry that partners with national industry participants and practices in 5 states. 

Going forward, the firm will be known as Levy Kodak Law, LLC. Existing clients of the two firms can expect the status quo at this time and will not be affected in the immediate term for either entity. The two firms are refining their plan for thoughtful integration to occur over the next few years to ensure that clients are able to benefit from the combination without any disruption in the services currently provided by both firms. The long-term benefits to clients will include a combined 18-state footprint and the merging of decades of knowledge and experience with a modern technology platform. 

“We’ve worked hard to get to this point, and we’re excited to take this next step with Yale Levy and his firm. His continued thought leadership and extensive experience will be an asset for us, while our next-level technology will allow us to offer clients truly the best of both worlds,” said Thomas Michael, Managing Member of Kodak Law.

“We look forward to continuing to serve our clients with excellence. Together with Kodak, we will be able to extend our overall scope and provide even greater value for our clients. Over the long term, clients will see access to increased jurisdictions under a unified brand and experience the benefits of new efficiencies found in a modernized platform. Current clients and services will not experience any disruptions as this will all take shape gradually and thoughtfully,” said Yale Levy, President of Levy & Associates

The two companies look forward to the opportunity to integrate their distinct strengths and broaden their market services across the industry. 

About Levy & Associates

Levy & Associates, LLC is a creditors’ rights law firm offering a wide spectrum of services to meet the needs of its clients in the credit recovery cycle. Levy & Associates, LLC’s clients include, but are not limited to, consumer and commercial credit grantors, insurance companies, local businesses, medical providers, landlords, and other businesses/non-profits companies. Levy & Associates currently provides legal services in the states of Ohio, Indiana, Kentucky, Maryland, Virginia, and D.C., representing a number of the best-known creditors in the country.

About Kodak Law

Kodak Law is an experienced collection litigation law firm. From its origin, the firm has been leveraging technology to deliver an unmatched experience for its clients, employees, and consumers. The firm’s attorneys and leadership are dedicated to setting and pursuing industry leadership in compliance, technology, and innovation. The firm is headquartered in Pittsburgh, PA, and practices in Arizona, California, Colorado, Florida, Illinois, Minnesota, Missouri, New Jersey, Ohio, Oregon, Pennsylvania, Texas, Washington, and Wisconsin.   

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Cleared Out: Court Orders Enormous Set of Discovery to Be Produced–but Why?

As every TCPA class action lawyer knows, the primary strategy of the Plaintiff’s bar is to serve massively overbroad discovery demands to put enormous pressure on the Defendant to settle for millions of dollars.

No company wants to be turned inside out and have its confidential–and often extremely sensitive consumer financial information- turned over to a plaintiff-side “expert” that will probably store it on a thumb drive in his kitchen junk drawer.

As I explained not long ago, a good set of objections to the typical shotgun style discovery demands TCPA class counsel serve should span over a hundred pages. And failing to properly articulate objections–and support them with suitable evidence in opposing motions to compel–can lead to terrible results.

Example.

In Beard v. John Hiester Chevrolet, No. 5:21-CV-173-D, 2022 U.S. Dist. LEXIS 46202 (W.D.N.C. March 16, 2022) the Court found that defendant failed to demonstrate that the discovery sought is not proportional to the case or should otherwise not be allowed.  Accordingly the Defendant was ordered to produce:

  • documents concerning Defendant’s relationship with third-party vendors involved in making the alleged calls (RFP 2 (written agreements), RFP 3 (written communications), RFP 4 (receipts and invoices);
  • call logs and other information concerning the individuals to whom prerecorded messages were sent by Defendant or its vendor (RFPs 8, 9, 10; Interrog. 3);
  • documents (or exemplars thereof) to support Defendant’s claim [*5] that putative class members consented to the calls (RFPs 15-17);
  • documents identifying revenue generated from the calls at issue (for the purpose of determining whether Defendant is vicariously liable based upon ratification of its vendors’ actions) (RFP 22); and
  • the names of employees involved in creating the prerecorded messages (Interrog. 6).

Arguably none of this information is needed ahead of certification–although templates of consent records is not so bad.

Notice that interrogatory 6 asked for the names of employees involved in the prerecorded calls. You know what’s coming next–an amendment to personally name those individuals.

If you’re served with an abusive set of class discovery demands make sure you seek out good counsel to preserve ALL of your rights. Asserting well-framed scope, necessity and burden objections–and substantiating those objections with evidence at the right time–is CRITICAL to defeating a TCPA class action.

Always here to chat.

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DFPI Marks Success in Implementation of the California Consumer Financial Protection Law

SACRAMENTO, Calif. — A year after implementing one of the most expansive consumer protection laws in the country, the Department of Financial Protection and Innovation (DFPI) announced it has collected close to $1 million in restitution for consumers, fielded hundreds of additional complaints related to the law, and launched more than 100 investigations using its expanded authority under the California Consumer Financial Protection Law (CCFPL).

The Department also created several new divisions to expand oversight and outreach, including the Consumer Financial Protection Division, Office of Financial Technology Innovation, Office of the Ombuds, and a Targeted Outreach Team responsible for working with historically underserved communities that include veterans, senior citizens, students, and immigrants.

“The Department has made substantial progress in its first year to implement the new law, expand protection for consumers, and foster responsible financial innovation,” said Clothilde V. Hewlett, DFPI Commissioner. “We remain committed to accomplishing the goals of Governor Gavin Newsom and are grateful to all stakeholders, including the Legislature, consumer advocates, industry partners, small businesses, community-based organizations, and many others for their continued input and support.”

In 2020, the Legislature passed the CCFPL as AB 1864 (Limón). Identifying gaps in consumer protection due to strict definitions in existing licensing laws, this new law provided the DFPI with the appropriate authority to oversee areas of the financial marketplace previously unregulated by the DFPI, including debt collectors, credit repair and debt relief companies, private postsecondary student loan products, and financial tech services that include early wage access products. The Department has also begun licensing debt collectors.

The first change under the CCFPL was a new name for the Department which was formerly the Department of Business Oversight. Over the past twelve months, the Department has experienced many key successes under the CCFPL. These can be found in a statutory report that has been posted to the DFPI website: https://dfpi.ca.gov/wp-content/uploads/sites/337/2022/03/DFPI-CCFPL-2021-annual-report.pdf.

Key takeaways from CCFPL Report:

Enforcement

During its first year with authority under the CCFPL, the DFPI proactively identified enforcement targets and opened 106 investigations that resulted in 49 public actions under the CCFPL.

The DFPI investigations resulted in 49 public enforcement actions, $975,000 in restitution to consumers, $547,500 in penalties, and included several “first of its kind” actions for the DFPI in debt collection, student debt relief, earned wage access, and private post-secondary education financing.

Regulatory Activities

In 2021, the DFPI issued four invitations for comments to solicit stakeholder feedback on various aspects of implementation of the CCFPL. DFPI received 76 comment letters.

As of the end of 2021, the DFPI had three pending regulation packages pursuant to the CCFPL: 1) complaint procedures, 2) commercial financing UDAAP, and 3) phase one registration categories.

Proposed registration includes debt settlement services, student debt relief services, postsecondary education financing, and wage-based advances.

Research and Market Monitoring

In September 2021, the DFPI created a research team to help the DFPI identify emerging financial activities; scout for unlawful, unfair, deceptive, and abusive practices; and make policy recommendations based on consumer impact.

The research team is evaluating DFPI’s consumer complaint data to identify broader market trends that may pose risks to consumers.

Consumer Complaint Handling

In 2021, the Consumer Services Office (CSO) received 638 complaints regarding products and services subject to the CCFPL.

Complaints submitted under the new law, which covered debt collection activities in the first year, increased each quarter with a dramatic surge in the second half of the year when CCFPL complaints increased nearly 140 percent.

The top categories of complaints included debt collection, cryptocurrency, and “neo banks,” financial technology, or “fintech” service providers, partnering with banks to offer deposit account services. The top complaints appear to have been driven by communications efforts to raise awareness about the DFPI’s expanded authority and mission.

Office of Financial Technology and Innovation

In 2021, the Office of Financial Technology and Innovation (OFTI) met with dozens of companies, venture capitalists, lawyers, industry advocacy groups, federal and state financial regulators, consumer advocacy groups, and academics to better understand stakeholder perspectives on what constitutes responsible innovation in financial services.

OFTI participated in more than a dozen public events to publicize OFTI’s activities and extend the invitation to meet. The Office held weekly office hours, open to all who registered.

Communications and Outreach

In 2021, the DFPI held three roundtables with community groups, dozens of external stakeholder meetings, presented on the topic at several events and conferences, and participated in dozens of media interviews to raise awareness about the Department’s expanded authority and work.

A communications vendor selected to run a statewide communications campaign conducted four multilingual focus group discussions and launched its campaign March 2022 with radio, print, digital, social media, and outdoor advertisements.

The Targeted Outreach Team participated in 141 events in 2021 with an estimated total attendance of more than 9,700 and distributed more than 96,400 pieces of promotional and educational materials.

About the DFPI

The DFPI licenses and regulates state-chartered banks and credit unions, commodities and investment advisers, money transmitters, the offer and sale of securities and franchises, broker-dealers, nonbank installment lenders, payday lenders, mortgage lenders and servicers, escrow companies, Property Assessed Clean Energy (PACE) program administrators, debt collectors, credit repair and consumer credit reporting agencies, debt-relief companies, certain rent-to-own providers, and more.

For more information about the DFPI, visit their website at https://dfpi.ca.gov/.

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Requesting Too Much Assistance from the Alleged Victim in Identity Theft Investigations

On February 28, 2022, the Court of Appeals for the Seventh Circuit affirmed a district court’s decision to enter summary judgment for a debt collector for alleged violations of the FDCPA and FCRA. Woods v. LVNV Funding, LLC and Resurgent Capital Services, L.P., No. 21-1981 (7th Cir. 2022). Focusing strictly on the FCRA claim, the plaintiff in Woods asserted that the debt collector violated section 1681s-2(b)(1)(A) by failing to conduct a reasonable investigation into his fraud claims.

In this case, once the debt collector received the account and began attempting to collect the debt, it started receiving disputes from the plaintiff. The debt collector responded to the disputes by requesting additional information and documentation regarding the alleged identity theft. Rather than providing information or documentation in support of the dispute to the debt collector, the plaintiff contacted the creditor, who subsequently determined that the debt belonged to the plaintiff.

The plaintiff filed a report with the local police department, alleging that he was the victim of identity theft, and submitting the correspondence from the creditor. The local police spoke with the plaintiff and prepared a report based on the information provided from the plaintiff. The police report included a statement that the creditor “had completed an investigation and . . . determined that it was in fact him.”

After having no success with the police department, the plaintiff filed a formal dispute with the CRAs and included a copy of the police report. The CRAs forwarded the ACDV to the debt collector, who reviewed the information provided and verified to the CRAs that the debt belonged to the plaintiff. Subsequently, the debt collector sent the plaintiff another letter inviting him to provide additional documentation to help resolve the case and attached a blank identity-theft affidavit. The plaintiff did not respond to the debt collector’s requests for information or documentation.

In determining whether the debt collector conducted a reasonable investigation following the receipt of the ACDV, the Seventh Circuit considered the content of the police report attached to the ACDV. Specifically, the Seventh Circuit focused on the officer’s commentary in the police report which indicated that the creditor had investigated the matter and determined that the debt belonged to the plaintiff. The Court noted that the debt collector was “well within its rights to rely on this representation to some degree” given that the ACDV made it seem that the creditor had already resolved the alleged fraud claim and affirmed the district court’s decision finding no FCRA violation.

As for the debt collector’s investigation, the Seventh Circuit stated that it was reasonable for the debt collector to send another request for documentation to the plaintiff because the ACDV made it seem that the vendor had already resolved the fraud claim against the plaintiff. However, the Seventh Circuit seems to suggest that under a different set of facts, continuous requests for documentation may be problematic. In fact, in closing, the Seventh Circuit states that its opinion does not offer furnishers “a license to offload their investigative obligations to consumers by spamming them with requests for additional information.” Thus, while communicating with the alleged victim about an FCRA identity theft dispute is considered reasonable, and even required, in most circumstances, the takeaway from this decision is that the level of involvement from the alleged victim must be determined on a case-by-case basis.

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Prodigal Announces Partnership: Best-in-Class Contact Center Telephony Meets Best-in- Class Interaction Intelligence

MOUNTAIN VIEW,
Calif.–
 Prodigal, the intelligence layer for lenders, is
proud to announce a strategic partnership with LiveVox, a leading cloud-based
provider of customer service and digital engagement tools.

Customer interactions provide invaluable insights on financial
health, experiential, and behavioral data, but also represent an epicenter of
inefficiency and compliance risk. Prodigals
partnership with LiveVox joins two performance-driven, omnichannel solutions
together in a simple and modular handshake to put consumers first.

LiveVox offers a cutting-edge API ecosystem to support
integrations with its world-class telephony infrastructure. LiveVoxs platform forks out
real-time shadow audio streams to power intelligent applications.

Prodigal easily integrates with LiveVox to deliver real-time,
in-browser interaction intelligence. For Prodigal customers, this partnership
represents a major milestone on their technological evolution: real-time
intelligence and agent productivity are available in browser, no IT bandwidth negotiation required.

Prodigal will seamlessly deliver products
that translate customer interactions to insights, meeting the growing need for
accurate intelligence across healthcare, consumer lending, and collections industries.

In addition to consumer experience benefits,
Prodigal customers can expect productivity benefits as insights
empower agents with
after-call summaries and next-action prompts.

Im excited to bring the transformative value of a
Prodigal and LiveVox partnership to our customers. When we align with
like-minded organizations to improve our solutions, we can offer more than the
sum of our parts: 1+1 = 5,” said Shantanu Gangal, CEO of Prodigal.

Long-time Prodigal customers already see that
premium. Said Greg Schubert,
President & CEO of Sequium Asset Solutions,Prodigal’s real time insights had material impact
quickly. It made agents both effective on every customer interaction and
efficient between interactions. Prodigal
s native integration
with LiveVox made these business goals our sole focus from day one.”

LiveVox (Nasdaq: LVOX) is a next generation
contact center platform that powers more than 14 billion omnichannel
interactions a year. By seamlessly unifying blended omnichannel communications,
CRM, AI, and WEM capabilities, the Company
s technology delivers
exceptional agent and customer experiences, while helping to mitigate
compliance risk. With 20 years of cloud experience and expertise, LiveVox
s
CCaaS 2.0 platform is at the forefront of cloud contact center innovation. The
Company has more than 650 global employees and is headquartered in San
Francisco, with offices in Atlanta; Columbus; Denver; New York City; St. Louis;
Medellin, Colombia; and Bangalore, India. To stay up to date with everything
LiveVox, follow at @LiveVox or visit livevox.com.

Prodigal has redefined technologys
role in customer care, pioneering a new category of intelligence for financial
and healthcare services. The Company uses artificial intelligence and machine
learning to deliver actionable insights ultimately maximizing revenue,
optimizing operations, and minimizing compliance risk for its customers.
Prodigals global team, whose backgrounds
intersect at financial services and data science, is headquartered in Mountain
View, California. Prodigal is backed by Menlo Ventures, Accel and Y Combinator.
For more information about Prodigal, please visit
prodigaltech.com and follow us @prodigaltech

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CFPB Says its UDAAP Authority Includes Ability to Review for Discrimination; Updates UDAAP Exam Procedure

On March 16, 2022, the Consumer Financial Protection Bureau (CFPB) announced that it will use its supervisory operations to evaluate discrimination in all consumer finance markets including credit, servicing, collections, consumer reporting, payments, remittances, and deposits. 

Acknowledging this is new territory and an expansion of its supervisory authority,  CFPB Director Rohit Chopra stated, “we will be expanding our anti-discrimination efforts to combat discriminatory practices across the board in consumer finance.”  Though fair lending laws may not apply to these markets, according to the CFPB, since discrimination meets the definition of “unfairness” it has the authority to make a determination regarding discrimination and disparate impacts to consumers. As such, the CFPB will use its authority to ensure companies are appropriately testing for and eliminating discrimination.

To meet its newly expanded efforts, the CFPB updated the UDAAP exam manual. The exam manual, which notes that consumers can be harmed whether or not discrimination is intentional, requires examiners to look at a covered entities process for assessing risks and discriminatory outcomes, including documentation of customer demographics and the impact of products and fees on different demographic groups. The CFPB will also use its authority to look at how companies test and monitor their decision-making processes for unfair discrimination.

Additionally, the updated exam manual includes questions related to:

  • whether the entity has a process in place to percent discrimination, including the evaluation of all policies and procedures for discrimination and continued monitoring (Question 1(f) page 13)
  • whether the company’s compliance management system includes a process for periodic analysis and monitoring of all decision-making processes (Question 2(j) page 14)
  • policies, procedures, and training to prevent discrimination (Question 2(k)(m) page 14)
  • the decision-making process for collections (Question 3(l) page 15)
  • how the entity evaluates and makes necessary adjustments and corrections to prevent discrimination.

insideARM Perspective:

Let’s get this piece out of the way: discrimination is a terrible thing. No one in the ARM industry is advocating for the ability to discriminate. That said, in order to go down this path (and setting aside whether the CFPB has the authority to do this), the CFPB needs to provide the industry more information regarding what it intends to look for than the vague, loose, open-ended questions found in the exam manual. 

Additionally, the CFPB should explain how it intends to look at subjective issues which might affect its analysis of a debt collector. For example, if the biggest client of an ARM entity is an inner-city hospital or a retail chain located in a heavily minority populated area, it would make sense for that ARM entity to have more monitory consumers in certain stages of collections. Instead, the new exam manual seems to take an entirely objective approach and does little to explain how an ARM entity can comply.

When the CFPB announces new expectations and new exam manual updates to go along with those expectations, it’s a good time to think about the gaps in your CMS. One of the best tools for this job is a risk and gap assessment. 

Find out how to start your own assessment with the on-demand webinar, A Complete Guide to Risk and Gap Assessments – How to Get Started (from insideARM and Research Assistant). You’ll learn what you can expect from a good risk and gap assessment, plus, find out how to test, how to break an assessment into manageable chunks and assign responsibility, how to win support from operations, and how to build towards ongoing audits so you get all the benefits of an assessment without having to put in all the work. Get it here.

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Harvest Strategy Group, Inc. Appoints Brad McCurnin as CEO and David Ravin as Vice Chairman

DENVER, Colo. – The board of directors of Harvest Strategy Group, Inc. takes great pride in announcing the promotions of Brad McCurnin to President and Chief Executive Officer and David Ravin to Vice Chairman effective April 1, 2022. These new responsibilities support Harvest’s growth in the industry and will help distribute additional strategic management tasks between them as they pioneer new opportunities for the company. 

“Over the years at Harvest and working in the industry, I have had the great pleasure of working for the best people in the industry and making lifelong friendships,” Brad McCurnin says. “As incoming President & CEO for Harvest Strategy Group Inc., I am thankful to be working with our talented team to deliver on our mission of leading the accounts receivable management industry through partnerships, service, technology, and superior results. I look forward to taking the next step as CEO of Harvest to lead our organization and continue our growth serving the industry.” Brad McCurnin

Mr. McCurnin is also passionate about Harvest’s charitable initiatives, which included 10 charities in 2021 with a focus on Diversity, Equity, and Inclusion (DEI), as well as helping families who are most in need. Mr. McCurnin has been active in the accounts receivable industry for over 20 years with a focus on operations, analytics, and modeling. He holds an MBA from Louisiana State University.

“Since the company was founded in 2007, Harvest has grown beyond even our expectations,” David Ravin says. “Our unique culture and values are what enable Harvest to enjoy an average tenure of nearly a decade among its management team and staff and provide our clients with best-in-class recovery management services. I am proud to take on the responsibility as Vice Chairman and am excited to continue to work with Brad and the rest of our management team to grow Harvest into the premier receivables organization.” David Ravin

David Ravin is a 16 year veteran of the collections industry and has worked closely with Mr. McCurnin in many roles for Harvest Strategy Group. David began as CEO before moving into the Executive Vice President role. Mr. Ravin has a Bachelor’s in Film Production and Screenwriting from the University of Colorado-Boulder and worked as the Assistant SVP of Physical Production for Spyglass Entertainment for several years before working as a Client Relations Manager for Machol & Johannes, PC. He has attended both the University of Denver Daniels College of Business and the Northwestern University Kellogg School of Management for executive development courses. 

Harvesting Potential

David Ravin and Brad McCurnin’s close working relationship has pushed Harvest Strategy Group to the forefront of the ARM industry. Harvest is a member of both leading industry organizations Receivables Management Association International (RMAI) and ACA International. In addition, they maintain membership with the National Automotive Finance (NAF) Association to expand their outreach in every sector they help manage. 

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Harvest challenges boundaries, thinks outside the box, and feels a sense of ownership and accountability for the results created for clients. Under Mr. Ravin and Mr. McCurnin’s guidance, Harvest maximizes each company’s litigation and management strategies. Harvest’s proprietary ProScore data model helps to ensure the best direction for each account so that the right channels find the right accounts.

Learn More

With the unique ability to align client’s needs with specific in-network participants, the Harvest team is engaged end-to-end with comprehensive compliance oversight and performance management. To learn more about Harvest Strategy Group or to contact them to learn more about how their account management services can help clients manage their receivables, call (303) 531-0654 or visit their website at harveststrategygroup.com.

About Harvest Strategy Group

Harvest Strategy Group provides single-point-of-contact, nationwide recovery management services for banks, finance companies, debt buyers, and credit unions. The company fosters an entrepreneurial environment and encourages its staff to challenge boundaries, think outside the box, and feel a sense of ownership and accountability for results. Harvest’s mission is to lead the accounts receivable management industry through strength in partnerships, exceptional service, and the delivery of superior results. Harvest Strategy Group Inc. is located in Denver, CO. 

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Equifax, Experian, and TransUnion Support U.S. Consumers With Changes to Medical Collection Debt Reporting

CHICAGO, Ill. — On March 18, 2022, the three nationwide credit reporting agencies (NCRAs) – Equifax (NYSE: EFX), Experian (LON: EXPN), and TransUnion (NYSE: TRU) – announced significant changes to medical collection debt reporting to support consumers faced with unexpected medical bills. These joint measures will remove nearly 70% of medical collection debt tradelines from consumer credit reports, a step taken after months of industry research.

According to the Kaiser Family Foundation, two-thirds of medical debts are the result of a one-time or short-term medical expense arising from an acute medical need. After two years of the COVID-19 pandemic and a detailed review of the prevalence of medical collection debt on credit reports, the NCRAs are making changes to help people to focus on their personal wellbeing and recovery.

Effective July 1, 2022, paid medical collection debt will no longer be included on consumer credit reports. In addition, the time period before unpaid medical collection debt would appear on a consumer’s report will be increased from 6 months to one year, giving consumers more time to work with insurance and/or healthcare providers to address their debt before it is reported on their credit file. In the first half of 2023, Equifax, Experian and TransUnion will also no longer include medical collection debt under at least $500 on credit reports.

The companies’ CEOs provided a joint statement on the decision to change medical collection debt reporting:

“Medical collections debt often arises from unforeseen medical circumstances. These changes are another step we’re taking together to help people across the United States focus on their financial and personal wellbeing,” said Mark W. Begor, CEO Equifax; Brian Cassin, CEO Experian; and Chris Cartwright, CEO TransUnion. “As an industry we remain committed to helping drive fair and affordable access to credit for all consumers.”

For more information, please visit: Equifax, Experian, and TransUnion.

About Equifax

At Equifax (NYSE: EFX), we believe knowledge drives progress. As a global data, analytics, and technology company, we play an essential role in the global economy by helping financial institutions, companies, employers, and government agencies make critical decisions with greater confidence. Our unique blend of differentiated data, analytics, and cloud technology drives insights to power decisions to move people forward. Headquartered in Atlanta and supported by more than 13,000 employees worldwide, Equifax operates or has investments in 24 countries in North America, Central and South America, Europe, and the Asia Pacific region. For more information, visit Equifax.com.

About Experian

Experian is the world’s leading global information services company. During life’s big moments — from buying a home or a car to sending a child to college to growing a business by connecting with new customers — we empower consumers and our clients to manage their data with confidence. We help individuals to take financial control and access financial services, businesses to make smarter decisions and thrive, lenders to lend more responsibly, and organizations to prevent identity fraud and crime.

We have 20,000 people operating across 44 countries, and every day we’re investing in new technologies, talented people, and innovation to help all our clients maximize every opportunity. We are listed on the London Stock Exchange (EXPN) and are a constituent of the FTSE 100 Index.

Learn more at www.experianplc.com or visit our global content hub at our global news blog for the latest news and insights from the Group.

About TransUnion

TransUnion is a global information and insights company that makes trust possible in the modern economy. We do this by providing an actionable picture of each person so they can be reliably represented in the marketplace. As a result, businesses and consumers can transact with confidence and achieve great things. We call this Information for Good®.A leading presence in more than 30 countries across five continents, TransUnion provides solutions that help create economic opportunity, great experiences, and personal empowerment for hundreds of millions of people.

Media Contacts:

FTI Consulting

CRAs@fticonsulting.com

Kate Walker

Equifax

mediainquiries@equifax.com

Scott Anderson

Experian

scott.n.anderson@experian.com

David Blumberg

TransUnion

david.blumberg@transunion.com

Equifax, Experian, and TransUnion Support U.S. Consumers With Changes to Medical Collection Debt Reporting
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