RMAI Update October 2026

[Cheryl Nelson]

In This Update​

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At the Consumer Financial Protection Bureau (CFPB), RMAI continues to monitor and engage with the Bureau on potential changes to the debt collection Larger Participant rule. The existing rule generally subjects nonbank companies with more than $10 million in annual receipts from consumer debt collection activities to CFPB supervision. Following its August 2025 advance notice, the Bureau identified September 2026 as its target for a proposed rule. Although no additional guidance has been issued, RMAI submitted comments in fall 2025 and has remained in contact with CFPB officials regarding their regulatory plans.

The Bureau’s regulatory agenda also identifies potential activity concerning unfair, deceptive, or abusive acts or practices (UDAAP). November 2026 is listed for preliminary activity, which could include a request for information or an advance notice of proposed rulemaking. That timetable does not establish when a proposed or final rule might be issued. RMAI has also shared thoughts with the CFPB on its UDAAP plans to help ensure that the Bureau considers the potential implications for the receivables industry.

Recent reporting suggests the CFPB is taking a more limited approach to supervisory examinations. According to Reuters, more than half of the Bureau’s spring examinations underwent expedited reviews, generally indicating that supervisors identified no more than minor compliance issues with little risk of consumer harm. Approximately 70 companies were selected for examinations this year, about half the usual number. The reported shift follows the Bureau’s announced plans to reduce examinations and focus more heavily on banks, mortgages, and protections for military service members, with less attention to nonbanks, student loans, and medical debt

At the Federal Communications Commission (FCC), a September 30 order revises how callers may process consent revocations under the Telephone Consumer Protection Act (TCPA). The order permits callers to interpret an opt-out from an informational call or text as applying to the particular category of communications involved. It also allows callers to designate specified revocation methods, subject to disclosure requirements. These changes could help companies preserve wanted account communications while honoring consumer preferences. Implementation remains subject to the order’s effective-date requirements, which RMAI members should confirm before making procedural changes.

Another FCC proceeding proposes stronger oversight of the Robocall Mitigation Database, including more complete provider filings, stronger screening, and expedited removal of noncompliant telephone providers. While the proposal primarily targets telecommunications providers, RMAI is attentive to potential downstream effects on members, including the need to protect lawful traffic and ensure clear compliance standards and practical correction procedures.

While certain aspects of the FCC proposals fall outside the direct scope of RMAI members, RMAI is focused is on ensuring that broader requirements do not unintentionally extend to or adversely affect the receivables industry. RMAI continues to engage with the CFPB, FCC, FTC, and other federal agencies to provide RMAI members’ perspectives, identify potential unintended consequences, and advocate for practical regulatory approaches that recognize the operations of legitimate receivables businesses.

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RMAI is synonymous with our government advocacy initiatives – it is one of the pillars which our association has been built upon – fighting for the interests of our members. Our association has had an unparalleled level of success in amending and stopping harmful legislation.

A good measure of our success has come from the volunteer efforts of RMAI’s State Legislative Committee and the generosity of our members to the Legislative Fund which helps pay for our lobbying efforts. If you have an interest in volunteering in RMAI’s grassroots advocacy efforts, please contact RMAI General Counsel & Senior Director of Government Affairs David Reid at (916) 779-2492 or [email protected].

The 2026 State Legislative cycle is winding down. Only a few state legislatures are still in session. All eyes are now turning to the November elections. The results of this election could have a profound impact on the receivables industry as well as how RMAI deploys our lobbying strategies in 2027. Take a look at the state legislative article in the current RMAI Magazine for additional insights on the election.

Here is a sample of bills we are currently monitoring/lobbying:

New York City Int 1105-2026 – This bill would create the New York City “People and Organizations Winning Economic Relief Act” (“POWER Act”). This bill was introduced by the New York City Council on October 8, 2026. The POWER Act could materially expand litigation exposure for creditors, debt collectors, law firms, and service providers handling accounts of New York City residents. The bill creates broad private and nonprofit enforcement, recognizes non-economic injury, and adds $2,500 per violation plus mandatory prevailing-plaintiff fees. The present text contains significant ambiguities concerning the scope of covered activity, the persons covered, and who could bring a claim. [RMAI is actively reviewing our options in vigorously opposing this legislation, including retaining a New York City-based lobbyist. More information will be forthcoming on this proposed law.]

Michigan HB 6205 – This bill would codify new exemptions from garnishment, including means-tested public assistance, unemployment compensation, federal and state earned income tax credits, disability benefits, and worker’s disability compensation benefits. The bill also sets the following limits on the amount of wages subject to garnishment: (1) for weekly gross wages up to $1,925, only the lesser of 20% of garnishable earnings or the amount exceeding 30 times the federal minimum wage can be garnished and (2) for wages above $1,925 per week, up to 30% of garnishable earnings may be garnished. [These changes aim to provide clearer protections for certain types of income and set more precise limits on wage garnishment, aligning with efforts to safeguard low-income individuals and those receiving public benefits from excessive debt collection.]

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Ninth Circuit Reverses $140M TCPA Verdict
Bultemeyer v. CenturyLink Inc., No. 24-6413, 2026 WL 2834418 (9th Cir. Sept. 22, 2026)

A consumer visited the website of a telecommunications provider to research its products and services. Placing an order consisted of five steps: 1) choosing a product and pricing; 2) customizing the order; 3) viewing the shopping cart; 4) entering personal information, including name, birth date, and billing address, and clicking on a box “to accept the ‘terms and conditions’”; and 5) entering payment information and clicking on “Submit Order.”

The consumer completed the first four steps but did not submit the order. Thereafter, the consumer learned that the company “had taken a ‘hard’ pull of her credit information.” She filed a putative class action lawsuit alleging the company violated the Fair Credit Reporting Act (FCRA) which allows a person “to obtain a credit report from a consumer reporting agency if that person has a ‘legitimate business need for the information … in connection with a business transaction that is initiated by the consumer.’ 15 U.S.C. § 1681b(a)(3)(F).” (emphasis added) The consumer claimed the company willfully violated that provision because, by not clicking “Submit Order,” she did not “initiate” any transaction.

The company moved for a directed verdict and for judgment as a matter of law, which the trial court denied. A class of 56,075 members was certified, and a jury awarded “each individual $500 in statutory damages and $2,000 in punitive damages,” for a total of over $140 million. The company appealed the trial court’s denial of its motion for judgment as a matter of law.

On appeal, the U.S. Court of Appeals for the Ninth Circuit explained that to obtain statutory and punitive damages under the FCRA, the violation must be willful, which includes a “reckless disregard of the law.” However, pursuant to Safeco Ins. Co. of Am. v. Burr, 551 U.S. 47, 127 S. Ct. 2201, 167 L. Ed. 2d 1045 (2007), “a defendant does not act recklessly if its reading of the statute (1) had ‘a foundation in the statutory text,’ (2) occurred when ‘no court of appeals had spoken on the issue,’ and (3) was made without ‘authoritative guidance’ warning it away from that view.”

Regarding the first requirement, the Court noted that “initiate” is defined in “[t]wo widely accepted dictionaries … as ‘commence; start; originate’ and ‘begin, introduce, set going, originate.’” Thus, it determined the company’s interpretation had a foundation in the statute “ecause the term “initiated” lacks definition in the statute and bears a range of possible reasonable meanings…” Regarding the second requirement, the Court stated it had not found “any appellate decision that has addressed the question of when a business transaction has been initiated.” Finally, the Court could not identify any authoritative guidance that would have been specific enough to the company’s conduct to be useful.

Based on this, the Court of Appeals reversed the trial court’s judgment and remanded the matter.

44 Attorneys General Secure $2.3M From Company Over Debt Collector’s Data Breach
Labcorp Assurance of Voluntary Compliance

On September 24, 2026, New York Attorney General Letitia James announced that she and 43 other state attorneys general had resolved their investigation into a data breach involving a healthcare company’s debt collection vendor. In addition to paying $2,287,455 to the attorneys general, the healthcare company also agreed to implement and maintain numerous data security measures, including:

• Information Security Program. The company must annually review and update its information security program.
• Security Leadership. The company must employ a qualified information security executive responsible for overseeing the program and advising senior leadership and the Board regarding security risks.
• Personnel with access to consumer personal information or protected health information (PHI) must receive security and privacy training at least annually, with training also required for new personnel.
• Incident Response. The company must maintain an incident-response plan addressing security events involving vendors.
• Vendor Security Events. The company must maintain procedures for timely escalation of significant vendor security events to senior management or the Board.
• Data Minimization. The company must maintain policies governing the collection, use, disclosure, and retention of consumer information and PHI and limit disclosures of PHI to vendors consistent with HIPAA’s Minimum Necessary Standard.
• Debt Collectors. The company must limit information provided to debt collectors to what is necessary and establish a process requiring collectors, at least annually, to confirm appropriate deletion, destruction, or other disposition of information associated with satisfied debts or rescinded collection referrals, subject to applicable law.
• Vendor Risk Management. The company must maintain a written, adequately resourced vendor risk management program that is reviewed at least annually.
• Vendor Risk Team. A qualified team must administer the vendor risk program and report at least quarterly to the Chief Information Security Officer regarding its effectiveness, vendor security risks, and mitigation plans.
• Vendor Monitoring. The company must use risk-based measures such as questionnaires, attestations, audits, certifications, and on-site visits to evaluate vendor security. Debt collector risk assessments must consider factors including the type and volume of data provided.
• Vendor Questionnaires. When questionnaires are used, the company must obtain appropriate corroborating information and maintain a process for tracking them.
• Debt Collector Inventory. The company must maintain an updated inventory of debt collector contracts containing information about the data handled, risk ratings, questionnaires, risk assessments, penetration tests, and applicable security audits.
• Debt Collector Contractual Security Standards. Debt collector contracts must require recognized cybersecurity standards or frameworks and safeguards addressing data segregation, minimization and retention, secure disposal, protection of cryptographic keys, and remediation of critical vulnerabilities.
• Risk Assessments. Debt collectors must conduct annual risk assessments and attest that critical or high-risk deficiencies have been or will be addressed.
• Penetration Testing. Debt collectors must conduct annual penetration testing of applicable network systems and similarly attest to remediation of critical or high-risk deficiencies.
• Independent Audits. Debt collectors must undergo an annual SOC 2 Type 2 audit, a biennial HITRUST CSF Validated Assessment, or a reasonably equivalent external audit, and attest to remediation of identified critical or high-risk deficiencies.
• Incident Responsibilities. Debt collector contracts must specify the parties’ respective responsibilities following a security event, including responsibility for required consumer notifications.
• The company must retain contractual remedies for collector noncompliance, up to and including termination.
• Independent Assessment. Within 18 months of the effective date, an appropriately qualified independent third party must assess the company’s compliance with the Assurance of Voluntary Compliance.

Colorado AG Settles with Medical Debt Collection Agency
In the Matter of Wakefield & Associates, LLC

On September 23, 2026, Colorado Attorney General Phil Weiser announced his office had entered into a settlement agreement with a collection agency it alleged had engaged in unlawful medical debt collection. Specifically, the Attorney General claimed the agency failed to comply with Colo. Rev. Stat. § 5-16-111(6) when it sought default judgments on 44 medical debt accounts.

Section 5-16-111(6) specifies numerous evidentiary requirements that must be met prior to entry of a default judgment against a consumer on medical debt incurred on or after May 4, 2023.

The agency did not admit to any wrongdoing, but nevertheless entered into the settlement requiring it to pay a fine of $30,000 and agreeing, among other things, to:

• Cease and desist from violations of the Colorado Fair Debt Collection Practices Act;
• File compliant medical provider affidavits when collecting Colorado medical debt incurred on or after May 4, 2023;
• Vacate 44 unsatisfied default judgments and refrain from seeking new judgments without providing required notice and filing compliant affidavits;
• Apply pre-judgment payments as directed by consumers, or, absent instructions, reasonably apply them to principal and interest;
• Not apply payments received post judgment to the judgment debt until 1) the agency elects to again seek judgment in the matter and tenders a compliant affidavit; or 2) the consumer, after written notice that no compliant affidavit was filed and that the consumer is under no obligation to pay the judgment amount, expressly directs in writing that the payment be applied to the judgment amount.
• Refund aggregate payments received after entry of judgment to the extent they exceed the total amount supported by a compliant affidavit.
• Provide the Administrator an accounting of required refunds within 91 days of the order’s effective date.

Contribute to the Legislative Fund with Your 2027 Renewal
It’s renewal season here at RMAI! You should have received your renewal invoice via email on October 1 which is due by December 31, 2026. This is a great opportunity to donate to RMAI’s Legislative Fund when you pay your renewal dues. We greatly appreciate any support of the RMAI Legislative Fund, and every contribution, regardless of amount, makes an impact. Our new Legislative Fund donation tiers begin at $2,500, which qualifies for the Silver level. If you would like to contribute to the Legislative Fund with your renewal and be recognized at the Silver level, please be sure to update your donation amount when you remit your renewal payment.

In 2026, RMAI was on the forefront of countless issues on the state and federal level to advocate for the receivables management industry. We look forward to another amazing year of advocacy with you, and your donations help make that happen. Please consider donating any amount that you can contribute. To see more information on what has been accomplished this year and where your donations go, check out RMAI’s Legislative Fund Infographic.

About the Legislative Fund
RMAI actively monitors and responds to state and federal measures affecting how our members do business. Your contributions to the Legislative Fund extend the reach of RMAI’s advocacy across the country where and when needed. Read more about the Legislative Fund.





Information Security Webinar Series
Join us during Cybersecurity Awareness Month as we present RMAI’s 2026 Information Security Webinar Series. This consists of two (2) webinars which give receivables management and financial services professionals a practical look at cybersecurity from three critical perspectives: prevention, insurance, and preparedness.

From understanding vulnerabilities within administrative and revenue cycle operations, to learning what cyber insurers look for when evaluating risk, to testing whether your team can actually execute its response plan when an incident occurs, these sessions will help you move beyond simply having policies on paper. You can Register for both or each individually.

1. From Breach to Coverage: Understanding Cyber Insurer Expectations – October 20, 2026 – Register
2. Plans Meet Plot Twists: Tabletop Exercises That Actually Prepare Your Team – October 28, 2026 – Register

Pricing: Package | Member: $100 | Non-Member: $150
Pricing: Individual Webinars | Member: $64 | Non-Member: $94

Artificial Intelligence Webinar Series (Package or Individual)
AI is rapidly transforming the accounts receivables management industry. This five-part webinar series moves beyond the hype to explore practical, real-world applications of AI across the ARM enterprise—from recruiting and training to legal operations, compliance, licensing, finance, and back-office functions.

Each session features ARM-specific use cases, live demonstrations, practical examples, and actionable takeaways designed to help organizations identify opportunities, improve efficiency, manage risk, and prepare for what’s next. The series concludes with a live executive panel at the RMAI Annual Conference, bringing together industry leaders to explore AI strategy, governance, privacy, workforce transformation, and the future of AI in ARM.

Explore the possibilities. See AI in action. Build a smarter, more responsible path forward. You can Register for all four (4) or pick and choose individual courses. Fifth course will be live at the 2027 Annual Conference.

1. AI in Human Resources for the ARM Industry – November 4, 2026 – Register
2. AI in Legal Operations, Contract Review & Vendor Oversight – November 18, 2026 – Register
3. AI in Licensing, Compliance Monitoring & Quality Assurance – December 9, 2026 – Register
4. AI in Finance, Accounting & Back Office Operations – January 20, 2027 – Register
5. AI Across the ARM Enterprise: Strategic Outlook & Leadership Panel (Live at 2027 Annual Conference) – Register

Pricing: Package | Member: $175 | Non-Member: $325
Pricing: Individual Webinars
Webinar #1: Member: Free | Non-Member: $94
Webinars #2 through #4: Member: $64 | Non-Member: $94
Session #5: Included with Annual Conference Registration

Recorded Webinar
Recorded on September 15th, 2026, you can register for UDAAP by Analogy – Using Other Federal and State Statutes to Define and Enforce UDAAPs. Our presenters, Stefanie Jackman with Troutman Pepper Locke, Jo Ann Needleman with Clark Hill, and Manny Newburger with Barron & Newburger, P.C., provided an in-depth examination of UDAAP, exploring how both federal and state laws define unfair, deceptive, and misleading practices as well as statutes such as FDCPA Section 15 U.S.C. § 1692d, which state regulators frequently rely on when pursuing state-level UDAAP actions. **This webinar qualifies for UDAAP credit for individual certification.

Click here for more information on our live and recorded educational webinars. Contact Shannon Parod-Tsui at [email protected] to find out more about sponsoring an RMAI webinar.





Congratulations to our new and renewed Certified Receivables Compliance Professionals (CRCP), & new and renewed Certified Receivables Business (CRB)!

CRCP New
Christopher Day, Capital Management Services
Jessica Marquis, Crown Asset Management
Mariel Vargas, TrueML Products
Scott Wortman, BounceAI

CRCP Renewals
Anthony Albanese, Overtime.AI
Joe Barbito, Orbita Capital Group
Autumn Bloom, Pro Asset
Kyle Cohen, Cohen & Cohen Law
Noel Crichton, Crown Asset Management
Toby Gialluca, Collection Attorneys USA
Todd Gurstel, Gurstel Law Firm
Michael Hilbig-Ross, Hilco Receivables
Kimberly Monty, Jormandy
Dixie Newsome, Crown Asset Management
Andrea Puls, Unifund CCR
Jamie Rieman, National Debt Holdings
Stacy Rodriguez, Much Shelist
Brian Solomon, Accelerated Asset Advisors
Mark Stelk, General Collection Co

CRB New
Parambir Bajwa, RMAI
Jack Coggins, Pro Asset
Dena DeForest, InDebted USA
Sarena Gaylor, Couch Lambert
James Oh, Javitch Block

CRB Renewal
Law Office of James R. Vaughan
SCJ Commercial Financial Services

View all certified businesses and vendors.
View all certified individuals.

Resources for Individual and Business/Vendor Certification
RMAI has developed certification resources for our members who are going through the individual or business/vendor certification and aren’t sure where to start or aren’t sure how long the process takes. These easy to follow resources will help you feel less intimidated and more confident in how to obtain certification at any level.

Individual Certification

• CRCP Timeline
• 7 Steps to Earn a Certified Receivables Compliance Professional (CRCP) Designation

Business/Vendor Certification

• CRB Timeline
• 7 Steps to Earn the Certified Receivables Business (CRB) Designation
• 7 Steps to Earn the Certified Receivables Vendor (CRV) Designation

View our full list of certification resources.





Renew Your Membership
Renewal invoices were distributed on October 1, 2026, via email and mail and can be paid online when you login. Please take a moment to review your invoice, and if you need help updating information, you can call (916) 779-2493 or email [email protected]. The deadline to renew is December 31, 2026, to avoid a late fee. Continue to receive member benefits like ongoing networking opportunities, live and pre-recorded webinars, timely information and resources, and robust state and federal advocacy. If you are planning to attend RMAI’s 2027 Annual Conference, remember that you must renew by December 31, 2026, to receive the members-only discounted registration rate.

Thank you for your continued support. We look forward to another amazing year with you!

Welcome, New Members
P3 Collection Services, LLC. | GA
Controlytics, LLC. | VA
General Revenue Corporation | OH
Bounce AI | NY

For a complete list of RMAI members (including contact information), login to check out the Member Directory.

2027 Annual Conference | February 8-11, 2027​

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RMAI LEGISLATIVE FUND CONTRIBUTORS OCTOBER 1, 2025 – OCTOBER 13, 2026



DIAMOND ($50,000+)

Crown Asset Management, LLC

PRA Group, Inc.

Resurgent Holdings, LLC

TITANIUM ($25,000+)

Absolute Resolutions Corp.

Cavalry Portfolio Services, LLC

Jefferson Capital Systems, LLC

Midland Credit Management

Second Round, LP

TRAKAmerica

PLATINUM ($10,000+)

Blitt and Gaines, P.C.

Cascade365 Family of Companies

Financial Recovery Services, Inc.

First Financial Asset Management, Inc. (FFAM 360)

Garnet Capital Advisors, LLC

Halsted Financial Services, LLC

InvestiNet, LLC

Pharus Funding, LLC

Plaza Services

Rausch Sturm, LLP

Security Credit Services, LLC

Stenger & Stenger P.C.

T & I Enterprises, LLC

TrueAccord

GOLD ($5,000+)

Andreu, Palma, Lavin & Solis, PLLC

D & A Services, LLC

Klima, Peters & Daly, P.A.

National Credit Adjusters, LLC

Pressler, Felt and Warshaw, LLP

Provana, LLC

Tromberg, Miller, Morris & Partners, PLLC

Velo Law Office

SILVER ($2,500+)

Central Portfolio Control, Inc

Corporate Advisory Solutions, LLC

Kino Financial Co., LLC

Mountain Peak Law Group, PC

Stillman Law Office

Troutman Pepper Locke

Troy Capital, LLC

CONTRIBUTORS

Advancial Federal Credit Union

Aldridge Pite Haan, LLP

American Coradius International LLC

Arko Consulting LLC

ARM Compliance Business Solutions LLC

ARS National Services, Inc.

Avtal Inc

Balbec Capital

Bankrupt Debt Services

Basham & Scott, LLC

Bread Financial

Buffaloe & Vallejo, PLC

Call Center Services International

CASA Receivables Management, LLC

CBE Companies

CNG/Axcess Financial Services, Inc.

Cohen & Cohen Law, LLC

Collection Attorneys USA LLC

CompuMail Information Systems

Connect International

ConServe

Consuegra & Duffy, PLLC

Converging Capital, LLC

Convoke, Inc.

Cornerstone Licensing Services

Cozen O’Connor

Credit Brokers LLC

Credit Control, LLC

Credit Management Corporation

D1AL

David Reid

Debt Sales Partners

Exelero Corp.

FDR Alliance LLC

First National Collection Bureau

Floatbot, Inc

FLOCK Specialty Finance

FMA Alliance, Ltd

FMS, Inc.

ForgiveCo PBC Inc

G. Reynolds Sims & Associates, P.C.

Genesis Recovery Services

Gordon, Aylworth & Tami, P.C.

Grassy Sprain Group, Inc

Guglielmo & Associates, PLLC

Healthcare Finance Direct, LLC

Hilco Receivables, LLC

Indiana Receivables, Inc.

Invenio Financial, a Phillips & Cohen Associates company

JT Lawson, LLC

Kompato AI Inc.

Landmark Strategy Group, LLC

Latitude Software

LexisNexis Risk Solutions

Mandarich Law Group LLP

Markoff Law LLC

National Enterprise Systems, Inc.

National Loan Exchange, Inc.

National Recovery Associates, Inc.

National Recovery Solutions, LLC

NCB Management Services, Inc.

NICE

Nutun CX (PTY) LTD

Nuvei Technologies Inc.

Orbita Capital Group, LLC

Overtime.ai

PCI Group Inc.

Phin Solutions, LLC

Poser Investments, Inc.

Premier Bankcard

Premium Asset Recovery Corp (PARC)

Primeritus Financial Services, Inc.

Pro Forma Inc

Quality Acceptance

Quantum3 Group, LLC

Receive Revenue Recovery

RevSpring

Risk Strategies

Robinson Hoover & Fudge, PLLC

Roosen, Varchetti & Olivier, PLLC

Rossman Kirk, PLLC

SAM – Solutions for Account Management, Inc.

SCJ Commercial Financial Services

Scott & Associates, PC

Shepherd Outsourcing, LLC

Smith Debnam Narron Drake Saintsing & Myers, LLP

Solvo Solutions, LLC

Sonnek & Goldblatt, Ltd.

Stone, Higgs & Drexler

Superlative RM

Suttell & Hammer

The Cadle Company

The Forwarders List of Attorneys

The Law Offices of Ronald S. Canter, LLC

The Moore Law Group

The Oakes Law Firm, LLC

The Receivers Office

Tobin & Marohn

Vargo & Janson, P.C.

Velocity Portfolio Group, Inc.

VeriFacts, LLC.

Womble Bond Dickinson

World Credit Recovery LLC

Yrefy, LLC


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