insideARM.com

At the request of the Federal Trade Commission, a federal court has halted the operations of a company that calls itself “FTC Credit Solutions.” The company allegedly used false affiliation with the Commission to market bogus credit repair services to Spanish-speaking consumers.

In a complaint filed with the court, the FTC alleges that defendants deceived consumers by claiming to be affiliated with or licensed by the Federal Trade Commission, falsely promising that they could remove negative information from consumers’ credit reports, and guaranteeing consumers a credit score of 700 or above within six months or less.

“Peddling lies under the name of the Federal Trade Commission to target consumers who are in difficult financial situations is appalling,” said Jessica Rich, director of the FTC’s Bureau of Consumer Protection. “This scam used the promise of a fresh start to hurt consumers when they most needed help, so we are pleased the court has taken a first step to ending it for good.”

The FTC’s complaint quotes a radio advertisement hosted by defendant Guillermo Leyes, in which he falsely stated that FTC Credit Solutions had a license from the FTC. Defendant Leyes misrepresented that the purported license allowed FTC Credit Solutions to guarantee any consumer a credit score of 700 or higher within 120 days or less.

According to the FTC’s filings, in undercover calls placed to the company by FTC investigators posing as consumers seeking debt repair services, defendant Maria Bernal, an employee of the company, said that the company “works under the Federal Trade Commission, which is a law that was signed by the President in 2010.” She also falsely promised that the company could “delete” and “get [the investigator] a pardon” for $19,000 in debt.

The FTC further alleges that the company unlawfully charged consumers fees in advance of providing the promised credit repair services. The company also sent the major credit bureaus letters with false information on behalf of numerous consumers.

The FTC alleges that the company, along with employees Leyes, Bernal, Jimena Perez and Fermin Campos, violated the FTC Act and the Credit Repair Organizations Act (CROA). Specifically, defendants violated the FTC Act by misrepresenting that they were affiliated with the FTC, by falsely promising to remove negative information from consumers’ credit reports, and by making false promises about improving consumers’ credit scores. In addition, the FTC alleges that by charging consumers upfront for credit repair services and misrepresenting their services, the defendants violated the CROA.

Under the terms of the temporary restraining order granted by the court, the company has temporarily ceased operations and the defendants’ assets are frozen.

The County of Los Angeles Department of Consumer and Business Affairs provided significant assistance in this case.

Patrick Lunsford

The Consumer Financial Protection Bureau (CFPB) announced today that it has finalized its publication rules for consumer narratives in complaints. The move will allow the CFPB to publish the language provided by consumers explaining why they are logging the complaint. The final policy includes a significant change to the way companies can respond to consumer narratives.

The CFPB is also publishing a Request for Information seeking public input on ways to highlight positive consumer experiences, such as by receiving consumer compliments about financial services businesses.

“Consumer narratives shed light on the full consumer perspective behind a complaint,” said CFPB Director Richard Cordray. “Narratives humanize the problems consumers face in the marketplace. Today’s policy will serve to empower consumers by helping them make informed decisions and helping track trends in the consumer financial market.”

When consumers submit a complaint to the CFPB, they fill in information such as who they are, who the complaint is against, when it occurred, and what issues were relevant based on a preset list of options. They are also given a text box to describe what happened and can attach documents to the complaint. When the Bureau forwards the complaint to the company, the narrative text and documents (if any) are provided.

But that narrative text does not currently appear in the CFPB’s public complaints database, nor is it published anywhere else. In July 2014, the CFPB proposed a policy that would allow consumers to publicly share their stories when they submit complaints to the Bureau.

There was strong opposition to the proposal in the banking and ARM industries. The American Bankers Association, ACA International, NARCA and many other groups filed comments on the proposal. The Financial Services Roundtable also launched a PR campaign against the proposal. But the plan will move forward, with some changes from the original proposal.

Starting today, when consumers submit a complaint to the CFPB, they will have the option to check a box and opt-in to sharing their narrative. In order for companies to learn about this new system, the Bureau will not publish any consented-to narrative for at least 90 days after the policy’s publication in the Federal Register, most likely Friday March 20. (Read the final statement submitted for publication)

In its announcement today, the CFPB noted that it is concerned with both consumer privacy and ensuring companies named in complaints have an opportunity to publicly respond. The CFPB said that the policy establishes a number of important safeguards for a clear, fair, and transparent process, including:

-Consumers must opt-in to share their story

-Personal information will be removed from narratives by CFPB staff – the CFPB will use a thorough process to ensure complaints are scrubbed of information such as names, telephone numbers, account numbers, Social Security numbers, and other direct identifiers.

-Complaints must meet certain criteria to qualify for narrative publication – including that the complaint is submitted through the CFPB website, that the complaint is not a duplicate submission, and that the consumer has a confirmed relationship with the financial institution.

-Companies can choose a response to publish – Companies will be given the option to select from a set list of structured response options as a public-facing response to address the consumer complaints. Companies will be under no obligation to offer a public response, and they have 180 days after the consumer complaint is routed to them to select the optional, public response. Companies will have the option to address all consumer complaints submitted, not just those where a consumer consented to publication.

The last bullet point represents a significant change from the original proposal.

The Bureau’s proposal has always allowed for a company response to consumer narratives. Originally, the CFPB thought that the company responses would be submitted in a manner similar to that of consumers: using a text box to write a response, given that consumer information was not included.

But the CFPB noted that it received many comments from trade groups and companies concerned that an unstructured open field might expose responding companies to liability under various laws, including Gramm-Leach-Bliley, the FCRA, and even the FDCPA. Commenters argued that, under the Bureau’s proposal to permit voluntary narrative company responses, they might not be able to provide any public-facing response at all due to legal, business, and reputational considerations, thus undercutting the CFPB’s desire to provide companies an opportunity to respond.

So the Bureau will provide companies with a finite list of optional structured responses from which company responders can choose. Within the secure web portal companies use to respond to complaints, the CFPB intends to add a set list of responses, giving companies the ability to recommend a public-facing response addressing the substance of the consumer’s complaint. Companies will be under no obligation to respond with their own narrative.

Also in a nod to comments received from the financial services industry, the CFPB today is issuing a Notice and Request for Information (RFI) seeking input from the public on the potential collection and sharing of information about consumers’ positive interactions with financial service providers.

Broadly speaking, the Bureau sees two options for sharing positive consumer feedback about companies. One option is to provide more information about a company’s complaint handling such as highlighting the quality of responses to consumers. The second option is to collect and provide consumer compliments – independent of the complaint process. Today’s RFI seeks input on these options and welcomes other ideas.

Patrick Lunsford —

A lawsuit filed in federal court in New York this week is seeking class action status under the TCPA. Named in the case is a major utility and nearly all of its subsidiaries and parent companies, including global holding firms, even though the alleged violation was committed by a third party debt collection agency. It is a continuation of a trend that sees plaintiffs skipping collectors and going straight after the big money.

The case in question, Jenkins v. National Grid USA, was filed by a recently-prolific pro se plaintiff that targets the ARM industry. But for this particular action, Jenkins retained an attorney to push for class action status.

The suit alleges that a third party collection agency, NCO Financial Systems, contracted by National Grid used an autodialer to make collection calls and send pre-recorded messages to the plaintiff’s – and other members of a potential class – cell phone without prior express consent to do so. The plaintiff was a utility customer of National Grid.

All of the actions named in the lawsuit were taken by NCO, not by National Grid. Jenkins claims that the company is “directly liable and/or vicariously liable” for NCO’s actions, however. NCO is not named as a defendant in the action.

But a host of entities associated with National Grid are named, including many of the largest utility providers in the Northeast and New England.

Jenkins has a fairly lengthy record of recent pro se actions against major ARM firms, principally for violations of the FDCPA or FCRA. Many of the cases have been dismissed. But one still open action appears to have led directly to this lawsuit.

In July 2014, Jenkins sued NCO under the FCRA for pulling his credit report. Jenkins claimed that NCO had not permissible purpose to access his credit file. NCO responded that it did, in fact, have a permissible purpose to obtain the credit report: it was collecting a debt on behalf of National Grid. NCO has filed a motion to dismiss, but the case is still ongoing.

Using some other information from discovery, Jenkins fashioned a TCPA claim based on NCO’s actions. But he skipped NCO as a defendant and went straight to their client. It’s a move that is becoming increasingly common.

Just last month, American Express lost a motion to dismiss a TCPA lawsuit that made very similar allegations. The credit card giant was the target of a class action suit claiming direct liability under the TCPA for the actions of a contracted debt collection agency. “With respect to the debt collection phone calls, whether American Express itself actually placed the calls at issue is irrelevant,” the judge in the case wrote.

It makes sense that collection agency clients would be target of TCPA class actions. There have been some massive settlements of such cases recently.

In late February, a federal judge in Illinois granted final approval to a $40 million TCPA class action settlement between plaintiffs and credit card issuer HSBC. That was the third-largest TCPA settlement recorded. The largest TCPA settlement went final only weeks before, in front of the same judge. That action saw Capital One pay $75 million in a collection call-related TCPA class action settlement.

The past several years have seen an explosion of TCPA lawsuits aimed at the ARM industry. Plaintiffs’ attorneys are now realizing that the real money is with collection clients rather than ARM companies. Everyone in the debt collection industry should take note of these recent trends.

Patrick Lunsford

The U.S. Department of Education announced late Friday that it would “wind down” its relationship with five private collection agencies on its student loan debt collection contract that ED says were providing inaccurate information to borrowers regarding rehabilitations.

ED also announced that it will provide enhanced Fair Debt Collection Practices Act (FDCPA) and Unfair, Deceptive, or Abusive Acts or Practices (UDAAP) monitoring and guidance for all private collection agencies still on the contract to ensure that companies are consistently providing borrowers with accurate information regarding their loans.

In a press release, ED said that a review of all 22 of its private debt collection contractors had revealed “unacceptably high rates” of misinformation regarding rehabilitations among five collection vendors: Coast Professional, Enterprise Recovery Systems, National Recoveries, Pioneer Credit Recovery, and West Asset Management.

The review, conducted by ED’s Federal Student Aid (FSA) office, found that agents of the companies made materially inaccurate representations to borrowers about the loan rehabilitation program. The five private collection agencies named were found to have given inaccurate information at unacceptably high rates about these benefits. In particular, the agencies gave borrowers misleading information about the benefits to the borrowers’ credit report and about the waiver of certain collection fees.

ED said that it will reassign accounts held by these five agencies. The agency will also increase monitoring to ensure that the students who began rehabilitation under the five private collection agencies will be treated fairly as they complete the rehabilitation process. The agency will issue enhanced guidance to all remaining private collection agencies, increase internal training for FSA staff, enhance the private collection agency manual, expand monitoring for these types of issues, and refine its internal escalation practices.

“Federal Student Aid borrowers are entitled to accurate information as they make critical choices to manage their debt,” said Under Secretary Ted Mitchell. “Every company that works for the Department must keep consumers’ best interests at the heart of their business practices by giving borrowers clear and accurate guidance.”

Last year, the Government Accountability Office (GAO) issued a report blaming massive problems in the ED rehabilitation program on a poorly-managed computer system upgrade undertaken by the Department. The GAO found that because of limited planning and oversight, ED was unable to provide most borrowers who completed loan rehabilitation with timely benefits for more than a year following the October 2011 upgrade of its defaulted loan information system. As a result, borrowers who made a good faith effort to rehabilitate their loans experienced delays in having the defaults removed from their credit reports and reinstating their federal student aid eligibility.

Although ED noted that the FSA review was initiated to “ensure that its private collection agencies were complying with the terms of the contract, which includes assurances that the agencies would not engage in unfair or deceptive practices and would comply with all applicable Federal and State laws,” there were no allegations of FDCPA violations in its press release.

The companies involved have said that they had no indication from ED that the move was imminent. The five collectors were notified of ED’s decision on February 21. All have been working with the Department and other officials to understand exactly what happened.

“We had no warning,” said Joel Kunza, EVP and ED contract administrator with National Recoveries. “We have been an excellent performer on the contract, in both performance scorecards and internal audits. We are keeping all of our options open right now.”

Similarly, Pioneer Credit Recovery said that it was “blindsided” by the notification. Navient, Pioneer’s parent company, also noted in an SEC filing Friday, “We are engaged with ED to learn more about their decision and address any questions or concerns they may have.”

The announcement is already making waves in national and local news, especially in areas that the five collection agencies call home.

Newspaper Buffalo News and TV station WGRZ are running pieces focused on potential job losses in the Buffalo area, headquarters to Pioneer Credit Recovery. WGRZ noted that as many as 400 jobs could be at stake, although the company said in a statement that it has plenty of work for all current employs.

Buffalo News was the first to get statements from Congressional members in the area, quoting Republican U.S. Rep. Chris Collins as saying, “They didn’t like that Pioneer was making it seem like they were the magnanimous one waiving the fee, when it was the DOE. That’s easily fixed. That’s not worth terminating a contract, in my opinion.” A spokesman for U.S. Sen. Chuck Schumer (D-N.Y.) said the Senator is “doing everything in his power to help.”

The procurement process for the new unrestricted debt collection contract is still ongoing. As of Monday morning, ED had made no update to the procurement documents to reflect the announcement Friday.

Last year, ED awarded spots to 11 collection agencies on the contract’s small business set aside. Two of the small business awardees, Coast Professional and National Recoveries, were among the five announced Friday.

Patrick Lunsford

At a symposium in midtown Manhattan Thursday, three representatives from New York City and state financial regulators provided some clarity to recently-enacted rules impacting collection agencies, debt buyers, and collection law firms operating in the state.

The event, hosted by debt buying trade group DBA International, was well attended by attorneys and operations professionals from ARM firms of all types. The diversity of the participants speaks to the broad confusion over how to best comply with rules recently enacted by New York State’s Department of Financial Services (DFS), some of which are slated to take effect next week.

DFS itself acknowledged the confusion last week with the release of answers to commonly asked questions from the ARM industry regarding the new rules. But there were still far more issues to clear up as collectors implemented the changes.

The symposium featured presentations from Joy Feigenbaum, DFS Executive Deputy Superintendent; Antonio Galvao, Deputy Counsel with New York State’s Office of Court Administration (OCA); and Marla Tepper, General Counsel with New York City’s Department of Consumer Affairs (DCA). Feigenbaum discussed the new DFS rules, the primary focus of the symposium, while Tepper and Galvao explored the interplay between the new DFS rules and new requirements recently enacted by their offices.

All three also sat on a lengthy Q&A panel afterwards that gave participants an opportunity to ask specific questions about how to comply with the new requirements. The panelists were very candid in their replies to questions and offered to provide additional clarification in cases where a specific question could not be answered live. The industry is urged to monitor the DFS site in coming weeks for any additional clarity.

Feigenbaum stressed that the focus of the new regulations was very narrow, in her department’s view. The most onerous of the new rules impact only charged-off debt resulting from a credit transaction involving a third party financial firm. There are exemptions from the rules for credit extended directly by a seller of a product or service that she confirmed would exclude most medical debt and other types of debt, such as auto loans that were granted by a dealer. The new rules do specifically apply to debt buyers.

Similarly, Galvao noted that new rules issued recently by the New York’s OCA concerning debt collection law suits in state courts are very narrow. “The rules are quite narrow in the scope of their application, but will have broad impact due to the volume of suits they cover,” said Galvao. The new court rules will apply only to default judgment requests made by ARM plaintiffs.

He noted that public comments, especially by industry groups like DBA, helped to narrow the scope even further before final implementation. For example, Galvao said that one of the major changes was limiting the scope to credit card collection lawsuits only.

While the regulators argued that the rules would be narrow, many attendees noted that the debt types and collection practices singled out would have much broader impact, as they cover a large swath of the ARM industry.

One point of contention was the language mandated in disclosures by the upcoming DFS rules and how they overlap or seemingly conflict with requirements already in place by DCA for collections in New York City.

DFS and DCA have requirements for disclosures provided to consumers when attempting to collect a time-barred debt. But model language provided by the agencies is different. Both Feigenbaum and Tepper explicitly stated that ARM firms collecting in New York can have a statewide compliant disclosure if they use the current NYC DCA language with one additional passage that tells consumers that suing on the debt is a violation of the FDCPA and that if the consumer pays, or agrees to pay, the debt, the SoL could restart.

All three also addressed a potential federal layer of confusion if CFPB debt collection rules do not perfectly overlap with their requirements. They said that each agency had been working very closely with the Bureau and that all will re-examine their rules if needed when the CFPB issues its debt collection rules proposal.

Combined with universal disclosures required for all accounts, a new DFS provision regarding debt substantiation, and additional information mandated for accounts that are charged-off (including an itemized accounting of charges, fees, and payments) many attendees noted an issue with “real estate” on certain communications. In short, how can all of the required written disclosures be made on an account that triggers all of the requirements?

Part of that issue has to do with the requirement that the disclosures be “clear and conspicuous.” While DCA has mandated placement and even font size in their guidance, DFS has not gone as far. When asked, Feigenbaum noted that DFS will be using FTC guidance on “clear and conspicuous,” and that ARM firms should look to that interpretation to inform their letter layouts.

Still, she conceded that there may be room to more actively help the industry with letter real estate and offered to review letter samples, should the industry provide them, for feedback.

Access to required documentation from creditor clients for substantiation, a DFS concept that goes beyond the FDCPA’s validation, was another point of contention. The level of documentation required is far greater than before. All of the regulators noted that it falls on the ARM firm to work this out with clients before accounts are transferred or sold.

One attendee noted, “This implementation will be about 80% IT and 20% compliance.” Fortunately for the industry, the substantiation requirements do not become effective until August.

In an afternoon session, ARM legal experts Irwin Kirschenbaum and Don Maurice noted that the new DFS rules do not include a right to private action. This means that the government will be the only entity able to bring actions under the statute. While it may be a comforting thought that plaintiffs’ attorneys will not be able to use the new rules in suits, it was pointed out that any changes in letter language will probably prompt FDCPA challenges, even if the language was mandated by a regulator.

Maurice also noted that when DFS engages in an investigation of an ARM firm under the new statute, it will most likely look very carefully at policies and procedures regarding the identification of time-barred debt. He and Kirschenbaum also reiterated what the regulator panel said about working with clients, that the ultimate impact of the new rules will be to create a much more hands-on relationship with creditors.

Patrick Lunsford February 20, 2015

The CFPB’s Consumer Advisory Board (CAB) meeting in Washington, DC Thursday was used as a platform to reiterate the Bureau’s focus on matters dealing with consumer credit reporting and medical debt, specifically how it is collected and appears on credit reports.

The meeting was the first of the year for the CAB, a group mandated by the Dodd-Frank Act and comprised of representatives from consumer advocacy groups, legal experts, and the credit and collection industry. The CAB provides perspective from different stakeholders to CFPB decision makers in all of the markets the agency regulates.

CFPB Director Richard Cordray, in opening remarks, spoke almost exclusively about the Bureau’s work in the credit reporting market. He noted that it is a nearly universal issue for Americans, as each of the three biggest credit reporting companies maintains files on over 200 million consumers.

One board member eloquently described credit files as “passports into the American financial mainstream.”

Of primary concern to the Bureau is consumer access and understanding of credit reports and the accuracy of information on those reports. In conjunction with the meeting, the CFPB released a new report based on credit reporting focus groups it conducted last year.

The focus groups showed that there is confusion over the difference between a credit report and a credit score, and that many people assumed that federally-mandated access to one free credit report per year meant access to a credit score, which is not the case. Credit scores, widely used by lenders in credit granting decisioning, are provided for a fee by FICO and VantageScore. But the Bureau is working on that, updating the public on its Open Credit Score initiative.

That initiative is working with major credit card issuers and other financial services firms to give consumers access to their scores on bills and account statements. The CFPB said that with recent buy in, some 50 million consumers will have free access to their credit scores on statements.

The conversation then turned to medical debt. What was billed as an exploration of medical debt collection practices really focused on issues consumers have with medical billing and confusion over insurance coverage.

One specific medical debt collection issue that was raised is the prevalence of very early stage medical collection accounts appearing on credit reports. The CFPB noted that medical accounts often appear on credit reports far before other debt types. The Bureau also presented data from its May 2014 Medical Debt and Credit Score data point that showed payment or non-payment of medical accounts was not a good predictor of future payment behavior, and should be taken into account by credit bureaus.

The panel did note that FICO has already announced it will recalibrate its FICO 9 Credit Score formula to differentiate between medical and non-medical collection agency accounts. But that change might take years to propagate through the system as lenders are typically slow to upgrade to new FICO updates.

CAB member Joann Needleman, speaking for the ARM industry as President of NARCA, noted that in her experience, many consumers ignore early intervention efforts from healthcare providers concerning outstanding bills. Much of this is due to confusion over what their insurance is covering and what the consumer’s obligation is under co-pays and out-of-pocket allocations.

Many on the panel agreed that the issue lies upstream with medical billing and coding and general misunderstandings over how much insurance covers.

A representative from the CFPB’s Research department did note, however, that the Bureau still needs to explore whether medical debt collectors are increasingly using credit reporting as a recovery tool.

HFMA is the nation’s leading membership organization for healthcare financial management executives and leaders. More than 39,000 members—ranging from CFOs to controllers to accountants—consider HFMA a respected thought leader on top trends and issues facing the healthcare industry.

Speakers and topics are as follows:

“Clinical Integration Concepts for Successful Population Health” presented by Jane F. Jerzak Health Care Partner, Wipfli

With over 25 years of experience, Jane Jerzak, a partner in Wipfli LLP’s health care practice, is uniquely positioned to provide unparalleled service to the health care industry. Utilizing her extensive experience in strategic planning and reimbursement, she offers health care organizations individualized solutions to complex marketplace issues.

Specializations:
*Health care strategic and service line planning and analysis
*Health care integration facilitation
*Revenue cycle and reform
*Reimbursement modeling
*Bundled payment and other innovative payment concepts
*Operational reviews
*Health care audit and compliance

“The Coming Retail Revolution” presented by Braxton Millar, The Advisory Board Company

Braxton “B.J.” Millar brings more than 24 years of health care experience to his role as a member of the Advisory Board Company’s (ABC) Value-Based Care team. As Director, B.J. serves ABC’s clients with Clinical Integration program formation, accountable care organization formation, bundled payment design and implementation, program effectiveness, care transformation strategy, population health management, payer strategy development, provider aggregation and physician network alignment. Prior to joining ABC, B.J. served as Healthcare Director of Navigant Consulting, located in Chicago, Ill.

insideARM.com

DBA International elected Kaye Dreifuerst as president during the association’s 18th Annual Conference. Dreifuerst begins her term on the heels of a very successful conference where the overall mood in the industry appeared to be shifting to a more balanced and optimistic view of the future.

An industry veteran with over 20 years’ experience in the collection and debt purchasing industry, Dreifuerst began her debt purchasing/selling career on the issuer side where she was responsible for Asset Sales and Collection Operations. She moved to the debt purchasing side in 2002 and is currently President of Security Credit Services based in Oxford, MS where she oversees’ acquisitions and the collection operation. She also plays a key role in establishing alternative capital sources which has significantly improved the profitability of the company.

According to Executive Director Jan Stieger, in addition to her vast industry expertise, Dreifuerst has provided valuable service to the industry, serving on the board of directors since 2009 and working on myriad committees over the years.

“Dreifuerst has recently co-chaired both the federal and state legislative committees where she has advocated for uniform, consumer-oriented, best practices that are transforming the collections industry,” said Stieger. “Assisting her company in achieving their Certified Professional Receivables Company (CPRC) designation, Dreifuerst appreciates DBA International’s responsibility for ensuring that debt buying companies large and small are abreast of laws and regulations and contribute to the discussion on new public policy.”

Other officers elected at the conference include:

President Elect – Trish Baxter, Recovery Management Systems Corp.
Treasurer – Irwin Kirschenbaum, KMT Group, LLC
Secretary –Todd Lansky, Resurgence Capital, LLC
Past President – Bryan Faliero, Sherman Financial Group
Director – Brian Fair, Fair Resolutions, Inc.
Director – Marian Sangalang, The Bureaus, Inc.
Director – Phil Stenger, Capital Alliance Financial, LLC

Additionally, two will continue as Board Directors: Mark Naiman, Absolute Resolutions Corp., and David Paris, Velocity Portfolio Group.

Recognizing the value that debt buying companies play in restoring economic stability and viability, Dreifuerst takes the helm whilst the receivables management industry is continuing to work with industry leaders and regulators to establish uniform standards, while raising the level of professionalism and consumer protection.

“Attending the annual conference I was able to notice the shift in overall mood as members are exploring new markets and opportunities, whilst maintaining their commitment to treating all customers with respect,” said Dreifuerst. “As demonstrated by the upcoming DBA International Symposium in New York City, it’s nice to have a respected voice at the table and see the regulatory community actively work with our industry to ensure we all understand the intent and implementation of new rules and regulations.”

DBA International (DBA) is the nonprofit trade association that represents the interests of more than 550 companies that purchase performing and nonperforming receivables on the secondary market. DBA’s Receivables Management Certification Program and its Code of Ethics set the “gold standard” within the receivables industry due to its rigorous uniform industry standards of best practice which focus on the protection of the consumer. DBA provides its members with extensive networking, educational, and business development opportunities in asset classes that span numerous industries. DBA continually sets the standard in the receivables management industry through its highly effective grassroots advocacy, conferences, committees, taskforces, publications, webinars, teleconferences, and breaking news alerts. Founded in 1997, DBA International is headquartered in Sacramento, California.

DBA International is a non-profit trade association and the voice of the debt buying industry. DBA members work in a variety of financial services fields and includes debt buyers, debt sellers, collection agencies, attorneys, and industry-related service providers. By providing products, services and education to its members, DBA International enhances the economic performance and liquidity of the international financial services industry.

ATG Credit was proud to attend the DBA International Annual Conference on February 3-5, 2015.

ATG Credit has completed their SSAE 16 Certification process.

This will ensure that our systems and processes are standardized and exceed the highest level of service and compliance. ATG Credit has always held compliance and service as the most important aspect of the account recoveries industry. This new certification confirms our commitment to excellence.