Jump to content

Sign in to follow this  
ndguy

Proper Validation

Recommended Posts

I requested a CA for actual proof or validation on a disputed debt. The CA came back with nothing but a final statement from the OC who sold them the debt. Their response was that they are not required to provide any more documentation as I requested and have used the court case of Chaudry v. Gallerizio as their argument that this is all that's required of them.

Has anyone come across this situation and if so, do you know of subsequent court cases in rebuttal of their argument.

I've never heard of this case as a defense for denying actual validation.

Thanks for any feedback!!

Share this post


Link to post
Share on other sites

I sent the definition of validate and verify along with the validaton laws yesterday

According to what little I know at this point ............... what you have there is no where near validation according to the FDCPA.

Share this post


Link to post
Share on other sites

ndguy:

 

I requested a CA for actual proof or validation on a disputed debt. The CA came back with nothing but a final statement from the OC who sold them the debt. Their response was that they are not required to provide any more documentation as I requested and have used the court case of Chaudry v. Gallerizio as their argument that this is all that's required of them.

Has anyone come across this situation and if so, do you know of subsequent court cases in rebuttal of their argument.

I've never heard of this case as a defense for denying actual validation.

Thanks for any feedback!!

 

ndguy,

 

Validation IS proof.

 

The case that the CA is citing is being taken out of context and isn't a valid reference as to what's required. Here's the case: http://laws.lp.findlaw.com/4th/981024p.html

 

Additionally, see below for a previous discussion and research on that particular case and how it was being used (the same as it's being used in your instance).

 

When you sent the validation letter did it say that you had no knowledge of the account?

 

Did their response contain the mandatory, this is an attempt to collect a debt language...?

 

The CA is wrong.

 

The point of validation is for the CA to go beyond it's own records (we know what they have because it is reported) to the original source and ensure that the records are the same as is being reported and attempted to be collected, and that a mistake wasn't made somewhere along the way. Importantly too, is ensuring that the wrong person is not being dunned. Additionally, there is the principles of contract law, that there was an agreement/contract establishing a debt, the terms of the same, and identifying the debtor.

 

It is a combination of documents that provides complete validation and a final statement alone doesn't get any part of it done.

 

FDCPA see below.

 

The Wollman letter, see below, speaks to WHAT validation requires while giving one example of what alone validation is not.

 

It is not a re-stating of what is on the CA's computer, it has to come from the OC, and the itemization by itself is not enough.

 

The Spears v Brennan case additionally on what alone is not validation, http://www.state.in.us/judiciary/opinions/...60101.ewn.html:

 

The contract by itself, doesn't get it done.

 

The contract in no way provides sufficient verification of the debt. A review of the document reveals that it identifies only the terms of Spears’ loan, including a 17.99% annual interest rate and the original loan amount of $2,561.59. The loan agreement contains no accounting of any payments made by Spears, the dates on which those payments were made, the interest which had accrued, or any late fees which had been assessed once Spears stopped making the required payments. Indeed, the existing unpaid contract balance at the time Brennan sent the debt collection notice was at least $350.00 more than the original loan amount. Therefore, Brennan violated 15 U.S.C. § 1692g(B) when he failed to cease collection of the debt by obtaining a default judgment against Spears after Spears had notified Brennan in writing that he was disputing the debt but before Brennan had mailed verification of the debt to Spears. See footnote We reverse the trial court’s entry of summary judgment in favor of Brennan on this issue.

 

In that same vein, a final statement alone (albiet from the OC) does not prove that the dollar amount is correct (HOW did they get to the final figure?), that there was ever a contract establishing the debt, nor that the correct person is being dunned.

 

Validation is a combination of all 3 things: Wollman, Brennan and contractual law. A signed contract establishing the debt, an itemized accounting, and a verification of records.

 

What follows is lengthy, but it is validation and it's backup and will help you understand why that attorney isn't worth his money and more importantly what validation is and isn't and why.

 

Enjoy,

 

Sassy

 

The FDCPA, http://www.ftc.gov/os/statutes/fdcpa/fdcpact.htm#809

 

§ 809. Validation of debts [15 USC 1692g]

(a) Within five days after the initial communication with a consumer in connection with the collection of any debt, a debt collector shall, unless the following information is contained in the initial communication or the consumer has paid the debt, send the consumer a written notice containing --

 

(1) the amount of the debt;

 

(2) the name of the creditor to whom the debt is owed;

 

(3) a statement that unless the consumer, within thirty days after receipt of the notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid by the debt collector;

 

(4) a statement that if the consumer notifies the debt collector in writing within the thirty-day period that the debt, or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a judgment against the consumer and a copy of such verification or judgment will be mailed to the consumer by the debt collector; and

 

(5) a statement that, upon the consumer's written request within the thirty-day period, the debt collector will provide the consumer with the name and address of the original creditor, if different from the current creditor.

 

(B) If the consumer notifies the debt collector in writing within the thirty-day period described in subsection (a) that the debt, or any portion thereof, is disputed, or that the consumer requests the name and address of the original creditor, the debt collector shall cease collection of the debt, or any disputed portion thereof, until the debt collector obtains verification of the debt or any copy of a judgment, or the name and address of the original creditor, and a copy of such verification or judgment, or name and address of the original creditor, is mailed to the consumer by the debt collector.

 

© The failure of a consumer to dispute the validity of a debt under this section may not be construed by any court as an admission of liability by the consumer.

 

FTC Staff Opinion letter, Wollman: http://www.ftc.gov/os/statutes/fdcpa/lette...ers/wollman.htm

 

March 10, 1993

 

Jeffrey S. Wollman

Vice President and Controller

Retrieval Masters Creditors Bureau, Inc.

1261 Broadway

New York, New York 10001

 

Dear Mr. Wollman:

 

This is in response to your letter of February 9, 1993 to David Medine regarding the type of verification required by Section 809(B) of the Fair Debt Collection Practices Act. You ask whether a collection agency for a medical provider will fulfill the requirements of that Section if it produces "an itemized statement of services rendered to a patient on its own computer from information provided by the medical institution . . .” in response to a request for verification of the debt. You also ask who is responsible for mailing the verification to the consumer.

 

The statute requires that the debt collector obtain verification of the debt and mail it to the consumer (emphasis mine). Because one of the principal purposes of this Section is to help consumers who have been misidentified by the debt collector or who dispute the amount of the debt, it is important that the verification of the identity of the consumer and the amount of the debt be obtained directly from the creditor. Mere itemization of what the debt collector already has does not accomplish this purpose. As stated above, the statute requires the debt collector, not the creditor, to mail the verification to the consumer.

 

Your interest in writing is appreciated. Please be aware that since this is only the opinion of Commission staff, the Commission itself is not bound by it.

 

Sincerely,

 

John F. LeFevre

Attorney

Division of Credit Practices

 

The following is from this thread, on the specific case that was cited and referenced: http://consumers.creditnet.com/straighttal...20&pagenumber=2 and authored previously by me, so I'm not gonna feel guilty about poaching. Do follow the link and read the whole thread from the beginning!

 

Scoob,

 

I can't figure out how to format this to make it more readable, so, it's a cut and paste job, parts of your letter and comments after.

 

"We are in receipt of your fax dated 5/22/02 and your acct has been reported to all credit bureaus as disputed since that date."

 

You could ask for a copy of whatever documentation they provided to the bureaus showing they really did this.

 

"The bureaus themselves have 30 days in which to make a change, so your CBR was probably in the lag time period. "

 

I believe it says something to the effect of, the bureaus can't provide a report including the information that is disputed without the notation -- no timeframes mentioned. Therefore, the next time you pull your report it should either show the dispute notation or the information shouldn't be there.

 

"You state that federal law requires that we provide all statements evidencing the underlying purchases on this account. That is an incorrect assessment of the law. In this connection, I refer you to Graziano v. Harrison, 950 F. 2d 107 (3rd Cir. 1991), in which a computer printout of the details of the debt was considered sufficient by the Court. "

 

I don't see where you stated the federal law requires blah blah blah. However, in my state (Arizona), the statutes do indicate just that, evidence of the underlying service or merchandise creating the debt -- you might want to check your statutes as well.

 

I can't find that case that he refers to online, there's tons of references to it. That court only has online cases beginning in 1994.

 

Who cares anyway, that was prior to the effective date of the FCRA and FDCPA changes so it couldn't have been referring to a collection agency AND he cleverly doesn't say what a printout was sufficient FOR by the court.

 

I understand computer generated documents from original creditors as a course of business are usually accepted, that's not true for collection agencies though and is exactly what the FDCPA was to address -- collectors without any first-hand knowledge thinking their computer records were enough.

 

The FTC in it's 1997 and 1998 reports to the House of Representatives say this about that case:

 

Two federal courts of appeals decisions have strongly implied that the thirty-day period is a firm grace period, making a demand for payment within the first thirty days impermissible. Graziano v. Harrison, 950 F.2d 107, 111-13 (3d Cir. 1991); Swanson v. Southern Oregon Credit Service, Inc., 869 F.2d 1222, 1226 (9th Cir. 1988).(27) The Commission considers this interpretation erroneous.

 

It's usually referenced in this way as well as the wording of the initial communication and not as a citation of verification documentation.

 

Another judge in NY just disagreed with the judge in this case on another matter, saying that disputes don't have to be in writing.

 

That case is just too old and especially that it is prior to the FDCPA anyway CAN'T relate at all to validation standards. AND, because the FCRA provisions for furnishers of information was enacted about the same time, it can only be referring to verification as a result of a dispute with a CRA -- prior to those provisions, there were no duties imposed on information furnishers, only the CRA's, and no validation requirements.

 

He's just blowing smoke with that case and making big bucks for forwarding to you inapplicable caselaw.

 

You'll have to summons Lizardking and Marie as LKH suggested, Lizardking had something similiar with an attorney stating he had no cause of action based on some outdated caselaw.

 

"See also Chaudrv v, Gallerizzo (4th Cir. 1999) 174 F3d 394, in which the Court stated, "... verification of a debt involves nothing more than the debt collector confirming in writing that the amount being demanded is what the creditor is claiming is owed; the debt coilector is not required to keep detailed files of the debt. There is no concomitant obligation to forward copies of bills or other detailed evidence of the debt," citing Graziano. Moreover, there is no requirement that the level of verification of the debt that you are demanding be provided."

 

Here again, the attorney is being clever "verification" isn't "validation" and is referring to an altogether different provision.

 

This case is available at findlaw, same link as already posted.

 

"As part of our effort to verify this account we have requested that the original documentation from this account be sent to us. We will forward those documents as soon as we receive them."

 

This part cracks me up, as part of our effort to verify this account -- he just admitted it's not! he can't be continuing collection activity until he does.

 

"Our records indicate that PRA III, LLC purchased this Sears Account on 7/30/01. At the time of purchase the outstanding balance was $1574.62. Our records further show that the account was opened 6/1/96 and was charged-off by the original creditor on 2/16/00. The last payment on the account was made on 4/16/99 in the amount of $100. "

 

Fine, wonderful, whatever -- his records don't count, he has to get the information from the OC.

 

"Please send copies ofany communications you may have had with Sears National Bank with

regard to this account. "

 

This cracks me up too -- why would you forward any communications to him, you requested validation and said the account wasn't yours.

 

Sassy

 

AND

 

<<snipped>>

 

I noticed one other thing after I posted that I think is REALLY slimey. I'm not sure of the in/outs of attorney ethics, but I know they have a code of conduct they have to adhere to, that may be worth looking in to as well. You can complain to the bar association.

 

The attorney, either really clever or an salamander, or both, quoted this to you from the 2nd case:

 

See also Chaudrv v, Gallerizzo (4th Cir. 1999) 174 F3d 394, in which the Court stated, "... verification of a debt involves nothing more than the debt collector confirming in writing that the amount being demanded is what the creditor is claiming is owed; the debt coilector is not required to keep detailed files of the debt. There is no concomitant obligation to forward copies of bills or other detailed evidence of the debt," citing Graziano. Moreover, there is no requirement that the level of verification of the debt that you are demanding be provided."

 

The ENTIRE quote, less the other case citations should be, and he doesn't indicate he was only partially quoting:

 

Contrary to Appellants' contention, verification of a debt involves nothing more than the debt collector confirming in writing that the amount being demanded is what the creditor is claiming is owed; the debt collector is not required to keep detailed files of the alleged debt.

 

----------> Consistent with the legislative history, verification is only intended to "eliminate the ... problem of debt collectors dunning the wrong person or attempting to collect debts which the consumer has already paid."

 

There is no concomitant obligation to forward copies of bills or other detailed evidence of the debt.

 

He's being deceptive, the arrowed part that he left out as part of the quotation, is EXACTLY what you were asking for in requesting validation and saying it wasn't yours. He was quoting you ONLY the part supported his position and not what applied to you or what you were lawfully asking for.

 

In saying that it isn't yours, instead of saying you already paid it, or the amount isn't right, or questioning the fees and interest or something else, he has to prove that it is yours, that he is not dunning the wrong person.

 

That's where Spears v Brennan comes in, the appeal is a 2001 case, and says that a copy of the contract alone isn't enough and details what would be an itemized accounting to substantiate the total amount he is claiming you owe -- which is just what you asked for.

 

You need the contract to establish that there was an agreement; the terms of the agreement to know how they calculated what they claim you owe; and with the identifying information to show that you are the right person.

 

The contract by itself is not enough, you need it with a complete itemized accounting to substantiate what the CA is claiming you owe.

 

AND, you need those records from the original creditor, not the CA, because when you ask for validation it's pursuant to the FDCPA requirements, and it's not enough that you get a computer statement from the CA because they have no first hand knowledge of the debt -- that's the FTC Wollman opinion letter. They have to go further to the original records to be sure that you are the right person and that their records are correct.

 

If you put all 3 elements together, that's validation -- one part can't stand alone.

 

That the attorney is being deceptive and misleading in twisting his case citations are additional violations of the FDCPA, shame on him!

 

You could ask him for documentation proving that they purchased the debt, as well. You never had an agreement with him or his company, if you had an agreement, it was with the original creditor. I could say I bought your debt too and it's not hard to come up with a computer print-out to show whatever I want it too ;-)

 

Since he's obviously really dumb, can't do any credible research or at least has questionable integrity, I don't think you should give him an inch and certainly NO scooby snacks!

 

Sassy

 

Scoob was working with Christine at the bayhouse site, http://www.creditforum.org/showthread.php?threadid=750 , and then posted at CN's site for answers (that is what is cut and pasted directly above). HEY, now I think you have come full circle, LOL

 

This thread too, specifically addresses the verbage that the attorney is citing from that case, again only poaching my own work, do real the whole thread though: http://consumers.creditnet.com/straighttal...?threadid=34171

 

Robin,

 

There is a thread addressing that 4th court decision, I'll see if I can find it for you.

 

I love the edcombs site, their whole firm and I have posted links myself to this same news reference.

 

I don't however know when it was written and I think, and don't have time at the moment to verify, that the awesome and lengthy article just hasn't been updated since the spears v brennan case.

 

The 4th court decision is old law and in fact, unless my memory is failing me, was made prior to the amendments of the FCRA -- however, the CA's still like to reference it hoping, or likely they themselves, not knowing that it is old and newer cases decided both trump, exceed, and define what is or isn't validation.

 

There are some cases, where it was good enough for the court that the OC having only computer records, as a business practice, were allowed to submit them. However, all of the cases are different, always are, it depends what you are arguing about.

 

In identity theft cases, computer records aren't enough. If you are claiming the OC's records are inaccurate, payment dates and the like, and all the OC has is computer records, those records, to prove accuracy seem to be acceptable and reasonable in some courts.

 

I think a court would likely accept, as a matter of business practice as well, that documentation was sent -- just because that is what businesses do as they carry on their business. And you know that is what they will say in a court room anyway, yep I sent it.

 

The FDCPA however says that © The failure of a consumer to dispute the validity of a debt under this section may not be construed by any court as an admission of liability by the consumer.

 

I think that provision covers I sent it -- well I didn't get it situations. Even if you don't validate within the initial 30 days, the CA gets to decide the initial 30 days as they aren't required to prove anything here, you still aren't admitting anything.

 

It's not good enough when you are requesting validation though, after whenever the CA says they first sent the notice, for them to say we already sent it and I'm not sending it again. Because, if you are disputing the accuracy, they need to prove it is accurate.

 

This is where, I think, the FDCPA and FCRA section 623 responsibilities and duties of information furnishers makes a key connection.

 

If they aren't willing to provide it to you and you then dispute the information with the CRA, they are required to reinvestigate and correct or update the information.

 

That act has to be based on something, though I think likely it is in fact based on nothing at all.

 

If then you were to contact the CA again and say, you verified inaccurate information, it is again their burden to prove that they did not.

 

This is where the newest cases, like chase v. manhattan come in, if after you have followed the process, they still won't or can't report correctly, they have a liability to you as an individual.

 

And if you were then to pursue legal action, they would be forced by the court to provide, that which they should have provided all along, validation.

 

Sassy

 

AND

 

FDCPA § 807. False or misleading representations [15 USC 1962e]

 

(8) Communicating or threatening to communicate to any person credit information which is known or which should be known to be false, including the failure to communicate that a disputed debt is disputed.

 

Your right to dispute, under the FCRA never goes away.

 

And once notified of a dispute by a consumer, as an information furnisher, they are required to note the account as disptuted.

 

§ 623. Responsibilities of furnishers of information to consumer reporting agencies [15 U.S.C. § 1681s-2]

 

(a) Duty of furnishers of information to provide accurate information.

 

(3) Duty to provide notice of dispute. If the completeness or accuracy of any information furnished by any person to any consumer reporting agency is disputed to such person by a consumer, the person may not furnish the information to any consumer reporting agency without notice that such information is disputed by the consumer.

 

Further, you have to check your own State's laws, my state for instance, requires that collection must cease until provided, any relevant documentation requested, WHENEVER it is requested.

 

Here's the FTC Opinion letter:

 

http://www.ftc.gov/os/statutes/fdcpa/letters/cass.htm

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

 

Federal Trade Commission

 

December 23, 1997

 

Robert G. Cass

Compliance Counsel

Commercial Financial Services, Inc.

2448 E. 81st Street, Suite 5500

Tulsa, OK 74137-4248

 

Dear Mr. Cass:

 

Mr. Medine has asked me to reply to your letter of October 28, 1997, concerning the circumstances under which a debt collector may report a "charged-off debt" to a consumer reporting agency under the enclosed Fair Debt Collection Practices Act. In that letter, you pose four questions, which I set out below with our answers.

 

I. "Is it permissible under the FDCPA for a debt collector to report charged-off debts to a consumer reporting agency during the term of the 30-day validation period detailed in Section 1692g?" Yes. As stated in the Commission's Staff Commentary on the FDCPA (copy enclosed), a debt collector may accurately report a debt to a consumer reporting agency within the thirty day validation period (p. 50103). We do not regard the action of reporting a debt to a consumer reporting agency as inconsistent with the consumer's dispute or verification rights under § 1692g.

 

II. "Is it permissible under the FDCPA for a debt collector to report, or continue to report, a consumer's charged-off debt to a consumer reporting agency after the debt collector has received, but not responded to, a consumer's written dispute during the 30-day validation period detailed in § 1692g?" As you know, Section 1692g(B) requires the debt collector to cease collection of the debt at issue if a written dispute is received within the 30-day validation period until verification is obtained. Because we believe that reporting a charged-off debt to a consumer reporting agency, particularly at this stage of the collection process, constitutes "collection activity" on the part of the collector, our answer to your question is No. Although the FDCPA is unclear on this point, we believe the reality is that debt collectors use the reporting mechanism as a tool to persuade consumers to pay, just like dunning letters and telephone calls. Of course, if a dispute is received after a debt has been reported to a consumer reporting agency, the debt collector is obligated by Section 1692e(8) to inform the consumer reporting agency of the dispute.

 

III. "Is it permissible under the FDCPA to cease collection of a debt rather than respond to a written dispute from a consumer received during the 30-day validation period?" Yes. There is nothing in the FDCPA that requires a debt collector to continue collecting a debt after a written dispute is received. Further, there is nothing in the FDCPA that requires a response to a written dispute if the debt collector chooses to abandon its collection effort with respect to the debt at issue. See Smith v. Transworld Systems, Inc., 953 F.2d 1025, 1032 (6th Cir. 1992).

 

IV. "Would the following action by a debt collector constitute continued collection activity under § 1692g(B): reporting a charged-off consumer debt to a consumer reporting agency as disputed in accordance with § 1692e(8), when the debt collector became aware of the dispute when the consumer sent a written dispute to the debt collector during the 30-day validation period, and no verification of the debt has been provided by the debt collector?" Yes. As stated in our answer to Question II, we view reporting to a consumer reporting agency as a collection activity prohibited by § 1692g(B) after a written dispute is received and no verification has been provided. Again, however, a debt collector must report a dispute received after a debt has been reported under § 1692e(8).

 

I hope this is responsive to your request.

 

Sincerely,

 

John F. LeFevre

Attorney

 

Enclosure

 

Doc, consolidates his validation notes here: http://www.creditboards.com/phpBB2/viewtop...wollman+brennan

 

And, who can address validation without mentioning fave Butch growling dude's mega but very thorough validation work of art here:

 

http://consumers.creditnet.com/straighttal...20&pagenumber=1

 

This is bathroom reading if I ever saw bathroom reading, LOL

 

:(

 

Sassy

Share this post


Link to post
Share on other sites
Their response was that they are not required to provide any more documentation as I requested and have used the court case of Chaudry v. Gallerizio as their argument that this is all that's required of them.

 

 

How come I never got really juicy stuff like this?

 

I never get to have any fun.

 

[ pout ... pout ]

 

lol

Share this post


Link to post
Share on other sites

It's the GROWLING, fave Butch growling dude,

 

They're worried you're rabid!!!!!!!!!! :wink:

 

Sassy

Share this post


Link to post
Share on other sites

I may just have to use this thread as the basis for filing against a CA reporting inaccurately on my credit files.

 

Thanks Sassy! :angry:

Share this post


Link to post
Share on other sites

Is this Sherman? I got letter on Saturday saying the same thing. Now, with the help of this bard, I know whoever sent it is an salamander. Bwahahahahahahahaha!!!

Share this post


Link to post
Share on other sites

Wow...I have read this thread twice and suddenly the world is a much brighter place. I can't believe I hadn't found it before. Thanks Cram for the bump!

 

If you are new here this thread is a must read.

Share this post


Link to post
Share on other sites

I'd lost my link to it a while back and hadn't been able to glean it out of the search engine again...

 

One of the single best pieces on info on the entire internet.

Share this post


Link to post
Share on other sites

Hi

 

Can I have a OC validate when it never went to a CA?

 

I cant seem to get an answer or I am posting in the wrong place and am still confused .

 

We had a car accident mid Oct 2003

 

When finally applying for credit a few months ago I found out we had a CO on our report from our totalled car.

 

Tu says paid as agreed, on true credit it say paid derogotory

Ex says Paid/ charge off /written off 1022 Nov 2004

Eq says Paid /charge off, Oct 2003

EX and EQ use to to just say charge off/written off 1022

 

We had the car under a year, insurance paid the first half of the car, then the OC determined we had a refund of 480 for unused waranty , and we had gap insurance which paid the balance.

 

I called the OC, they told me because the first ins company didnt pay the entire balance of the car off, it ws considered a charge off.

 

I just dont know what to do.

 

Can anyone help?

 

Deby

Share this post


Link to post
Share on other sites

I was about to start answering the OP's questions until I realized this thread was from oh... 2003.

 

My how far some information has come since then. All this time people have been fighting to say Chaudhry doesn't apply, when it appears it DOES apply just in the way the CAs don't want.

Share this post


Link to post
Share on other sites
I was about to start answering the OP's questions until I realized this thread was from oh... 2003.

 

:offtopic:

 

 

Doc, consolidates his validation notes here: http://www.creditboards.com/phpBB2/viewtop...wollman+brennan

I would send the second validation letter since they screwed up. If you're feeling scoundrelly, lol, you should only do the not-received tactic if they actually send you a perfected (or nearly-perfected) validation -- and that claim is really best saved for court. "Your honor, they never sent me a response." You will be able to prove that you sent the requests (certified mail receipts), and they'll be able to just stare at the judge and make flimsy claims.

[END QUOTE]

 

Sweet :D

Edited by catchnrelease

Share this post


Link to post
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now
Sign in to follow this  

About Us

Since 2003, creditboards.com has helped thousands of people repair their credit, force abusive collection agents to follow the law, ensure proper reporting by credit reporting agencies, and provided financial education to help avoid the pitfalls that can lead to negative tradelines.
×

Important Information

Guidelines