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CFPB Seeking Consumer Comments on FDCPA Reform


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What we all have been waiting for !

 

 

This is a Long Document 114 pages, and in each Section / Part there are a series of numbered questions, which you can comment on individually and should reference the # in your comments.

 

 

http://files.consumerfinance.gov/f/201311_cfpb_anpr_debtcollection.pdf

 

 

ACTION: Advance Notice of Proposed Rulemaking.

SUMMARY: The Consumer Financial Protection Bureau (the Bureau) is seeking comment, data, and information from the public about debt collection practices. Debt collection affects a significant number of consumers and the Bureau is considering proposing rules relating to debt collection. Therefore, the Bureau is interested in learning through responses to this advance notice of proposed rulemaking (ANPR) about the debt collection system, about consumer experiences with the debt collection system, and about how rules for debt collectors might protect consumers without imposing unnecessary burdens on industry.

The Fair Debt Collection Practices Act (FDCPA) was passed in 1977 and the Bureau is the first Federal agency to possess the authority to issue substantive rules for debt collection under this statute. The Bureau may also address concerns related to debt collection using its authority under the Dodd-Frank Act to issue regulations concerning unfair, deceptive, and abusive acts or practices and to establish disclosures to assist consumers in understanding the costs, benefits, and risks associated with consumer financial products and services.

 

 

Parts II and III of the ANPR principally focus on the quantity and quality of information in the debt collection system.

 

Part II solicits information on the transfer of information and access to information upon sale or placement of debts.

 

Part III seeks information regarding validation notices, disputes, investigations, and verification of disputes.

 

Parts IV, V, and VI primarily concern the conduct of collectors in interacting with consumers in trying to recover on debts through the collection process.

 

Part IV requests information about collector communications seeking location information about consumers, interacting with consumers themselves, disclosing debts to third parties, and newer technologies.

This part includes issues concerning sections 804 and 805 of the FDCPA. Part V asks for information about unfair, deceptive, and abusive acts and practices, including issues concerning sections 806, 807, and 808 of the FDCPA.

 

Part VI addresses issues relating to the collection of debts that are beyond the statute of limitations.

 

Parts VII and VIII predominantly address debt collection activities that implicate issues relating to State law.

 

Part VII requests information about debt collection litigation, most of which occurs in State courts.

 

Part VIII raises questions about exemptions under Federal law for State debt collection systems under section 817 of the FDCPA, as well as for private entities that operate bad check diversion programs under contracts with State and local district attorneys under section 818 of the FDCPA.

 

Finally, Part IX solicits information concerning recordkeeping, monitoring, and compliance

 

 

 

ADDRESSES: You may submit comments, identified by Docket No. CFPB-2013-0033 or Regulatory Identification Number (RIN) 3170-AA41, by any of the following methods:

 

Electronic: http://www.regulations.gov. Follow the instructions for submitting comments. ( which happens to be down at this moment in time..... )

 

Mail/Hand Delivery: Monica Jackson, Office of the Executive Secretary, Bureau of Consumer Financial Protection, 1700 G Street, NW, Washington, DC 20552.

 

Instructions

: All submissions must include the agency name ( if you're a CA/JDB. ) and docket number or RIN.

[Docket No. CFPB-2013-0033] RIN 3170-AA41

 

Please include the question number(s) to which your comment pertains. In general, all comments received will be posted without change to http://www.regulations.gov.

 

 

 

 

 

 

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Example question

 

Q122: Many consumers complain that debt collectors seek to recover on debts that consumers have already paid and therefore no longer owe. Other consumers assert that debt collectors promise that they will treat partial payments on debts as payment in full, but then collectors subsequently seek to recover the remaining balance on these debts. To what extent do debt collectors currently provide consumers with a receipt or other documentation showing the amount they have paid and whether it is or is not payment in full? Should such documentation be required under proposed rules? Are there any State or local laws that are useful models to consider?

 

 

example answer;

 

In regards to Question # 122, If a negotiated settlement is reached during a phone conversation, the all debt collectors and debt purchasers should follow procedures similar those the major banks and legal profession, to wit; a formal letter outlining the terms of final settlement, the full names of the parties, signed and witnessed by a notary public on the date it is signed by the respective parties. A settlement agreement is no less than a private contract or a legal document and should be treated as such.

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Apparently, the CA's believe this is going to be a good thing for them. They are encouraging collectors to write in with comments and suggestions to the CFPB. If you guys want changes, you need to respond quickly and in large numbers.

From the ARM site:

http://www.insidearm.com/daily/debt-buying-topics/debt-buying/cfpb-begins-rulemaking-process-for-debt-collection-industry/?utm_source=insideARM.com&utm_campaign=7ee9082007-CFPB_ANPR_Response_Webinar_11_11_13&utm_medium=email&utm_term=0_a05497525d-7ee9082007-79928297


o What's Happening?
The Consumer Financial Protection Bureau (CFPB) this week announced that it was officially launching its rulemaking authority in its mandate to enforce the FDCPA. No federal regulator has ever had this kind of authority; any rule changes had to be made by Congress. But the CFPB will now be making new federal rules for the ARM industry.

The first step in the process was the publication of an Advance Notice of Proposed Rulemaking. This is basically just a formal notice that the CFPB is looking to make rules impacting debt collection. They have given the public 90 days to comment on what rules would be most effective and how the regulator should approach rulemakiing.

Fortunately, the CFPB has made the comment process as easy as possible. There are many ways to submit comments. They even allow the attachment of documentation and data to support a response. But the Notice itself is 114 pages long and goes into quite a bit of detail. In other words, responding and commenting will take some effort.

And that's why we're holding this free webinar. The clock on the comment period started ticking Wednesday, and comments should be thoughtful and deliberate. ARM defense attorneys John Bedard, Ron Canter, and John Rossman will be presenting a template for how to respond and their ideas for what to focus on. They will also discuss what they see coming out of this process.

Make no mistake: this is what the debt collection industry has been waiting for. Industry trade groups will do a fantastic job of presenting comments that will benefit the industry as a whole, but this is your opportunity to speak directly to the CFPB about your business. Don't miss it.

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http://www.consumerfinance.gov/blog/

 

Although the public can submit comments formally in response to the notice at regulations.gov, we want to make it easier for consumers and small businesses to tell us what they think about debt collection practices. To do that, we’ve partnered with RegulationRoom.org, operated by the Cornell University’s eRulemaking Initiative, where you can provide your comments in an interactive and intuitive way.

RegulationRoom.org is not a government website. It’s operated by law students and staff at Cornell Law School, with the goal of making it easy for people to submit comments to government agencies. They are working on removing barriers to public participation, and we are excited to be partnering with them again.

 

The staff at RegulationRoom.org realizes that most people are generally unfamiliar with the formal commenting process at Regulations.gov (the official government site). So they present information, conduct a conversation, and then collect views until the forum closes about a week before the end of the comment period, so that their team can assemble all the feedback into an official comment. Those who have participated get one more chance to react to the summary before it is submitted formally to the CFPB through regulations.gov. And, like all other formal comments, we will read and consider them as we consider consumer protection rules for the debt collection market.

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http://www.insidearm...952396-79933657

insideARM.com and The iA Institute host this second annual Large Market Participant Summit on January 23-24, 2014 in Washington, D.C. This event caters to the unique interests of the larger firms in the ARM industry, with unparalleled peer networking, best practice discussion, and panels focused on the latest issues that keep you up at night.

At the inaugural Summit in February 2013 we welcomed 145 owners and senior executives from over 75 large market participant (LMP) companies. The event was a who’s who of the industry’s leaders and large players, and provided a focused forum for important and in-depth discussion.

Join us in January to learn of new developments to support LMPs, and for insight into the continuously changing dynamic among collectors, creditors, consumers, and regulators. If you are a progressive thought leader who wants to make a positive impact in the industry, this is the event to attend.

Steering Committee

We have engaged a steering committee of your peers to advise on the agenda in order to ensure your time is spent on those topics of greatest interest to Large Market Participants. Members of the committee include:

  • Chris Shuler, CEO – Vital Solutions, Inc.
  • Tim Bauer, CEO – Integrity Solution Services
  • Marcelo Aita, President & CEO – NCB Management Services, Inc.
  • Tony L’Abbate, Senior VP Operations – NCO Group
  • Dave Hall, Executive VP, Receivables Management – West Asset Management
  • Susan Giordano, VP, Compliance & Risk Management – EOS CCA
  • David Stocker, General Counsel – Automated Collection Services, Inc.
  • Harry Neerenberg, Chief Financial Officer – Teleperformance ARM
  • David Kaminski, Partner – Carlson & Messer LLP
Agenda

The agenda is a work in progress, as we expect to focus on the topics of greatest importance at the time of the event. Updates will be made and panels announced as details are finalized.

Thursday Jan. 23, 2014 7:45-8:30 Breakfast & Networking 8:30-8:40 Welcome – Stephanie Eidelman, president & CEO, insideARM.com and The iA Institute 8:40-9:30 CFPB Rulemaking update — Tom Pahl, Regulatory Counsel in the Office of Regulations, Consumer Financial Protection Bureau (confirmed) 9:30-10:30 De-Mystifying UDAAP – Manisha Sharma, Principal & Paula-Rose Stark, Senior Principal – Promontory Financial Group

A former CFPB examiner and enforcement attorney will highlight what recent UDAAP activity means for debt collectors of all kinds:
  • Will UDAAP bring the practices of first-party collectors into alignment with those of third-party collectors?
  • Can building culture focused on fairness pay dividends?
  • What strategies make sense for identifying and monitoring UDAAP risks?
  • What are the common pitfalls for collections firms trying to manage UDAAP risks?
  • How can firms prepare themselves for tough questions from regulators?
10:30-11:00 Break 11:00-11:45 KEYNOTE

Being your own best advocate: Making your compliance program compelling to your business partners and regulators — Linda Gallagher, Managing Director and Global Head of the Consumer Protection Practice, Promontory Financial Group

Creditors and regulators alike want to know that a collection firm complies with applicable law – and can prove it. Building a strong compliance management program – from risk assessment and testing through corrective action — is an essential first step. But conveying the thorough and credible commitment to consumer protection that your compliance program represents is an overlooked ingredient in succeeding in a world where you – and your business partners – will face regulatory scrutiny.

Linda has a deep understanding of the regulatory expectations that apply to creditors and collections firms of all kinds. Her address will focus on the investments in consumer protection that collection firms are making to reassure their business partners and regulators. 11:45-12:45 Lunch & Networking 12:45-2:15 Consumer Relations Consortium – Learn about this new group formed to represent the interests of large market participants to regulators and others, and its activities so far, including meetings with consumer advocates and the CFPB, as well as the group’s response to the ANPR released on November 6, 2013.

Facilitated by CRC steering committee members:
  • Marcelo Aita – President & CEO, NCB Management Services
  • Tim Bauer – CEO, Integrity Solution Services
  • Susan Giordano – VP Compliance & Risk Management, EOS CCA
  • John Rossman – Attorney, Moss & Barnett
2:30-5:00 Best practice breakout discussions

Organized by function: We will have separate sessions for Presidents/CEOs, General Counsel/Chief Compliance Officers, and CFOs/COOs.These were the most requested sessions by attendees at the 2013 Summit, so we have set aside a full afternoon to get into the specific topics you want to discuss within groups of your peers.

Sample topics (though YOU will set the agenda):
  • Collector compensation
  • Dispute handling
  • Complaint handling
  • Collection/convenience fees
  • Call frequency
  • Implementing Reg E
  • Credit bureau reporting
Friday Jan. 24, 2014 7:30-8:00 Breakfast & Networking 8:00-9:00 Insight from a year of CFPB CIDs and exams – Chris Willis and John Cullhane, Ballard Spahr LLP

This presentation will highlight current “hot issues” that the CFPB is pursuing in the collection industry, through examinations and civil investigative demands. With respect to each issue, they will highlight the operational processes involved, and make specific suggestions about compliance processes to mitigate the risks.Included in the discussion will be the CFPB’s Bulletins regarding debt collection and credit reporting, as well as the import of the CFPB’s Advance Notice of Proposed Rulemaking regarding debt collection. 9:00-10:00 A discussion about common ground with consumer advocates

There is a great deal of misunderstanding between consumers and collectors. One way we can begin to bridge the gap of understanding and expectations is through dialogue and relationships. We’ve invited a group of thoughtful consumer advocates to join us for a moderated discussion of an issue important to both consumers and collectors, where we can begin to identify common ground. Topic to be announced.
  • Laura E. Udis, Senior Financial Services Advocate – Consumer Federation of America
  • Jeanne Hogarth, Vice President, Policy – Center for Financial Services Innovation
  • Dalié Jiménez, Associate Professor of Law & Jeremy Bentham Scholar – University of Connecticut School of Law
  • Patricia Hasson, President & Executive Director – Clarifi; member of the CFPB Consumer Advisory Board
  • Linda Sherry, Director, National Priorities – Consumer Action
  • Moderator: David Kaminski, Partner, Carlson & Messler, LLP
10:00-10:15 Break 10:15-11:15 Managing vendor oversight with confidence – Eric Pittman, CFO, Vital Solutions, Inc.

It’s a new world and this is now a very real responsibility for collection agencies; especially LMPs. Learn how one of your peers utilizes a technology based process to simplify compliance with CFPB requirements for service provider oversight. 11:15-Noon Driving change through legislators – David Stocker, General Counsel – ACSI, and Harrison Wadsworth, Principal – Washington Partners

As the industry moves beyond the CFPB rulemaking process, we will need to focus on the legislative initiatives that drive long term change. This session will assist you in maximizing the process of working with your federal representatives to address your concerns about consumer laws that impact your daily business actions. The presenters have extensive experience in this essential activity. Noon Close Keynote Address

Linda-Gallagher.jpg?b058fbThursday’s keynote address will be given by Linda Gallagher, Managing Director and Global Head of the Consumer Protection Practice, Promontory Financial Group

Linda is a seasoned consultant with more than 30 years of bank holding company and financial services experience, specializing in regulatory matters. She has worked with a wide range of diversified and global financial services companies and has led enterprise-wide compliance efforts and readiness assessments.

Before joining Promontory, Linda was a principal and national leader for the financial services regulatory practice at KPMG. Linda, who worked at KPMG for 25 years, founded and built the firm’s compliance practice. She is a nationally recognized speaker on compliance programs and other regulatory risk management topics and was honored by Consulting magazine as one of the top 25 consultants of 2011.

Linda helps clients to focus not only on the technical aspects of compliance, but on the strategic dimensions as well. She has extensive hands-on experience in directing teams in conducting regulatory risk reviews, for lines of business as well as across enterprises. She has designed and implemented compliance programs for new and converting bank holding companies, nonbank financial services companies, and private equity firms.

Promontory’s team of former regulators and financial services executives sets us apart. We have several former CFPB regulators on staff with experience in supervision, regulations, enforcement, and front-office functions.

Promontory has extensive experience working with banks, nonbanks, and regulators to respond to regulatory concerns in the consumer area, including mortgage servicing and enforcement actions related to fair lending, as well as unfair, deceptive, or abusive acts or practices. Our experts’ regulatory backgrounds give them unique knowledge and understanding of the expectations of the regulatory agencies, including the CFPB.

Speakers

Thomas Pahl
Tom is Regulatory Counsel in the Office of Regulations, Consumer Financial Protection Bureau. He joined the Bureau in 2013 from the Federal Trade Commission, where he was Assistant Director in the Division of Financial Practices.

Manisha Sharma
Manisha came to Promontory Financial Group from the CFPB’s supervision, fair lending, and enforcement division where she was an examiner and team lead. She conducted exams related to debt collection and UDAAP, independently conducting reviews of affidavit processes, asset sales, estate collection, and third-party vendor-management practices at large banks.

Paula-Rose Stark
Paula-Rose (P-R) was one of the first employees at the Consumer Financial Protection Bureau, from which she joined Promontory. She worked in the bureau’s regulations office, where she helped lay the foundation for statutory rulemakings on mortgage disclosures, mortgage servicing, and high-cost mortgages. She was also an enforcement attorney, and investigated practices related to mortgages, credit cards, and prepaid cards. She helped develop and monitor the implementation of the examination-support function performed by the bureau’s enforcement attorneys, and participated in examinations of marketing practices, disclosures, loan-originator compensation, debt collection, vendor management, and fair lending at various bank and nonbank institutions. Additionally, on behalf of the director’s office, P-R helped guide a strategic-planning process to define the bureau’s policy priorities. She worked with nearly all of the bureau’s senior leadership, and was the principal author of several publications.

Marcelo Aita
Marcelo Aita has been Chief Executive Officer of NCB Management Services, Inc. since June 1, 2008 and also serves as its President. He held various finance and operations positions at HSBC North America for over 17 years, serving as a National Director of Call Center Operations for the credit card business and having responsibility for more than 8,000 employees across 12 call centers in both North America and Asia. Marcelo managed customer service and sales, global resourcing, collections and debt recoveries.

Tim Bauer
Tim Bauer is an ARM executive with a wide range of experience in M&A, Operations, Compliance, Sales & Marketing, and Portfolio Acquisitions. In his current role as CEO of Integrity Solution Services, he collaborated with H.I.G. Capital to acquire three premier providers of BPO and ARM services, and re-branded the combined companies under the Integrity Solution Services name. Previously, Tim was engaged in a special capacity at Academy Collection Service, Inc. to facilitate a settlement of an FTC investigation and pursue a sale of the business. Prior to that Tim has held a variety of senior executive roles with Outsourcing Solutions Inc., Risk Management Alternatives, Inc., and Nationwide Credit, Inc. He also practiced law for 15 years with the law firm of Messerli & Kramer P.A. in Minneapolis, MN.

Susan Giordano
Susan Giordano is a licensed attorney and has been with EOS CCA since 2004. In her current role as VP Risk Management and Compliance, she provides general corporate governance to EOS CCA’s national and international offices and has been instrumental in implementing EOS CCA’s Compliance Initiative. Additionally, she provides oversight and direction on all litigation matters with emphasis on the TCPA, FDCPA, the FCRA claims. Prior to joining EOS CCA, Susan worked for the Massachusetts Water Resources Authority.

John Rossman
In his national practice at Moss & Barnett dedicated to the debt industry and creditors’ remedies, John Rossman has shaped debt collection law in numerous landmark cases that preserved and expanded the rights of collection agencies, debt buyers, mortgage lenders, creditors, and fellow attorneys. Licensed to practice in 15 courts and jurisdictions across the country, John regularly serves as counsel nationwide, both as a lead attorney and as a learned strategist for local counsel. He advises and counsels debt buyers and collection agency clients on regulatory compliance, defends them in claims and litigation, and advises them on best practices to prevent legal action.

Laura Udis
Laura Udis joined Consumer Federation of America in March 2013 and works on consumer credit, debt collection, and debt settlement issues. From 1988 to early 2013, she was First Assistant Attorney General of the Consumer Credit Unit and Administrator of the Uniform Consumer Credit Code in the Colorado Attorney General’s Office. She supervised all non-depository lenders and creditors and enforced Colorado’s laws on consumer credit, debt collection, debt settlement, rent-to-own, and credit repair. Udis oversaw all consumer credit litigation In the Attorney General’s Office, testified before the Colorado General Assembly, adopted regulations, issued administrative opinions, and supervised a staff of 20 employees. Udis was president of the National Association of Consumer Credit Administrators, the American Conference of Uniform Consumer Credit Code States, and the North American Collection Agency Regulatory Association.

Jeanne Hogarth
As Vice President of Policy for the Center for Financial Services Innovation (CFSI), Jeanne Hogarth works to strengthen CFSI’s research program and engagement efforts with government and other key stakeholders. Jeanne brings a wealth of experience to CFSI, most recently having worked as an economist at the Federal Reserve Board. At the Board, she led research projects on consumer financial decision-making, financial services access and inclusion, and household economic stability. Prior to joining the Federal Reserve Board, Ms. Hogarth was a faculty member of consumer economics at Cornell University. She has authored numerous scholarly research articles in leading journals and served as a guest editor for the Journal of Consumer Affairs special issue on Financial Literacy, Public Policy, and Consumer Self-Protection in 2008. She has been a keynote speaker national and international conferences on financial education and family financial stability. In February 2013, Ms. Hogarth was recognized by the Financial Literacy and Education Commission for her outstanding work in the field.

Dalié Jiménez
Dalié Jiménez is an Associate Professor of Law at the University of Connecticut School of Law. Her scholarly interests include empirical and policy work in consumer financial protection, bankruptcy, credit and debt collection markets, and the financial distress of American families. She is currently working on a large-scale, randomized control trial evaluating the effectiveness of legal and counseling interventions to help individuals in financial distress. Professor Jiménez was part of the founding staff at the Consumer Financial Protection Bureau where she concentrated on debt collection, debt relief, credit reporting, and student loan issues. Prior to her academic career, Professor Jiménez clerked for the Honorable Juan R. Torruella of the United States Court of Appeals for the First Circuit, was as a litigation associate at Ropes & Gray, L.L.P. in Boston, and worked on consumer protection issues at the Massachusetts State Senate.

Patricia Hasson
Patricia Hasson is President of Clarifi, the non-profit agency formerly known as CCCS of Delaware Valley. As Executive Director, she oversees the operation of the agency and its professional and administrative staff of 85+ employees who devote themselves to creating pathways to Lifelong Financial Literacy for their clients and communities. Clarifi delivers on its mission in 13 offices in three states throughout the Philadelphia metropolitan area. Hasson is currently serving on the Consumer Advisory Board of the Consumer Financial Protection Bureau (CFPB) and the Oversight Board for the Philadelphia Mayor’s Office of Community Empowerment & Opportunity. Her insights and expertise have led to appointments like the Federal Reserve Consumer Advisory Council, the Greater Philadelphia Chamber of Commerce Board of Directors, PNC Bank Community Advisory Board and Capital One Consumer Advisory Council. Prior to joining Clarifi, Hasson spent more than 12 years as a banking executive at CoreStates Bank.

Linda Sherry
Linda Sherry is a nationally recognized consumer advocate and expert on credit and debt, financial services pricing and practices, and consumer rights. As director of national priorities for Consumer Action, she is responsible for the organization’s national advocacy work and for Consumer Action’s free, multilingual educational publications and website content. Sherry, who joined Consumer Action in 1994 from a background as a weekly newspaper reporter, established Consumer Action’s DC office in 2004. Sherry, Consumer Action’s chief spokesperson, regularly responds to inquiries about consumer protection issues by the national and local media, Congress and federal regulators.

David Kaminski
David Kaminski is a partner at Carlson & Messer LLP, a defense firm in Los Angeles, California. David represents banks, collection agencies and creditors against consumer claims brought under the FDCPA, FCRA, the TCPA, CFPB matters and related consumer statutes. He is a recognized authority and speaker on these topics, as well as a frequent contributor to numerous industry publications. He is the chair of the Member Attorney Panel of the ACA International. Mr. Kaminski also serves as outside compliance counsel to banks and collection agencies and has developed policies, procedures, and compliance/training programs to minimize the liability risks for banks and collection agencies.

Chris Willis
Christopher J. Willis is an Atlanta-based litigation partner at Ballard Spahr and a member of the firm’s Consumer Financial Services Group. He counsels financial institutions on compliance with consumer financial services laws, and defends them in both individual and class action lawsuits, as well as governmental investigations and enforcement actions, including investigations conducted by the CFPB. Mr. Willis chairs the firm’s Collection Documentation Task Force, which assists clients with the rapidly developing spread of document-related scrutiny, from the mortgage foreclosure process to the collection of credit card, student loan, and other forms of consumer debt. Mr. Willis is a frequent author and speaker on issues relating to consumer financial services litigation and regulation.

John Cullhane
Mr. Culhane is a partner in the Philadelphia office of Ballard Spahr and a member of its Consumer Financial Services Group and its Collection Documentation Task Force. He counsels clients offering multi-state credit card programs, private student loan programs, and mortgage loan programs on servicing and collection issues. He also conducts assessments of debt buyer, collection agency, and collection firm compliance management systems and assists in the defense of collection-related class actions, attorney general investigations, and agency enforcement actions.

Eric Pittman
Eric Pittman was recruited as a member of the senior management team for the start-up of Vital Solutions in 2002. He is currently serving as Senior Vice President and Chief Financial Officer. Eric has led the company successfully through more than 60 compliance audits over the last 3 years, including outside CPA firms, government licensing agencies, and clients. Eric has also led the company through multiple ISO 27002, SSAE-16, and PCI compliance certifications. Most recently, he led the development and launch of Vital Vendor Risk to help companies achieve compliance with new CFPB requirements for third party service provider oversight. Eric’s experience prior to Vital includes more than a decade of financial services management ranging from business start-ups, crisis turnaround as Controller, and in management with fortune 500 companies.

David Stocker
Mr. Stocker currently serves as General Counsel for Automated Collection Services, Inc. Previously, he was Associate General Counsel for Sallie Mae, General Counsel and Director of Government Relations for General Revenue Corporation, General Counsel for Pioneer Credit Recovery, General Counsel and Director of Government Relations for ACT and as an Assistant Ohio Attorney General he represented the Ohio Tax Commissioner and Workman’s Compensation Bureau and was assigned to the Ohio Student Loan Commission as General Counsel and Manager for Litigation Outsourcing. As director of government relations for OSLC and GRC, he has participated in several national organizations including National Council of Higher Education Loan Programs, American Collectors Association, National Association of Retail Collection Attorneys, Commercial Law League of America and COHEAO. While active in COHEAO for over 18 years, he served as chair of various committees, as a member of the Board of Directors and is a Past President.

Harrison Wadsworth
A principal in Washington Partners, LLC Harrison Wadsworth has more than 20 years of experience in public policy and communications. Wadsworth has expertise in a variety of areas, including media relations, the legislative and political process, higher education, finance, communications and trade association management. Wadsworth has also worked as a congressional press secretary and legislative director and as a newspaper reporter and editor. He received a B.A. in mass communications from the University of California at Davis and an M.A. in economics and American foreign policy/security studies from Johns Hopkins University School of Advanced International Studies.

Registration

The Summit is open to senior executives of ARM firms that meet the CFPB definition of “large market participant” ($10M or more in annual collection-related revenues), in addition to others as determined by insideARM. Although the CFPB does not count medical receivables at this time, for the purpose of this Summit, that asset class may be included as part of your calculation.

The fee for those who register by 11/22/13 is $949. After 11/22 the registration fee is $1099.

To register, please complete a registration form and fax to 240.499.3807 or scan and email to orders@insidearm.com

Hotel

The Summit will take place in the shadow of the White House and the Capitol in Washington, D.C.

W Hotel
515 15th Street NW
Washington, D.C. 20004

Rate $235/night

Call central reservations at 877-946-8357 and mention the “insideARM Large Market Participant Summit” for the group rate. Rooms are available at this rate until 5pm EST on January 2, 2014, or until our block is sold out. NOTE: As of November 22, 2013, the block is 50% sold.

The hotel is extending the Summit rate to attendees for as many days prior to and following the event as you need, so feel free to come early for meetings or stay the weekend to see the sites.

Questions

Contact Stephanie Eidelman, president & publisher insideARM.com at 240.499.3806 or by email.

Underwriters

We know you have many opportunities throughout the year to visit with new and existing industry suppliers. With no exhibit hall, this event allows you to focus purely on peer discussions and networking. Thanks very much to our underwriters, who help to make this exclusive experience possible.

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