Not Again…Trump CFPB Official Leading Effort to Gut Debt Collection Rules to “Kick Off” Another Ritzy Debt Industry Conference

Washington D.C. – The Trump-Kraninger CFPB’s top aide overseeing the overhaul of debt collection rules, Tom Pahl, is “kicking off” a lavish three-day long conference next month hosted by ACA International, the leading debt collection industry trade group. The announcement comes as the CFPB considers finalizing its rule that would reward debt collectors by letting them send unlimited, unsolicited texts and emails to consumers, oftentimes over “zombie” debts too old to be legally pursued or that don’t even belong to the person. It also follows Pahl’s speaking engagement at a debt industry “Executive Summit” in July.

“The amount of face-time debt industry executives has had with the Trump CFPB is extraordinary. And that’s reflected in the administration’s plan to give debt collectors carte blanche to harass consumers endlessly over even more mediums,” said Jeremy Funk, spokesman for consumer watchdog group Allied Progress. “If only Director Kraninger and her staff were to spend the same amount of time talking to consumers as they do hobnobbing with industry, perhaps their rules would be more balanced.” 

Added Funk: “But at least the administration is not bothering to hide its close relationship with the big debt collectors that have donated generously to Republican campaigns. Consumers will know who to blame when they suddenly get inundated with texts and emails from strangers demanding that they click on risky hyperlinks.

The CFPB’s debt collection proposal isn’t just hugely unpopular, it’s likely illegal after a Federal appeals court recently ruled debt collection agencies were prohibited from asking consumers to click on hyperlinks to obtain legally-required notices about outstanding debt. The proposal seeks to permit exactly that. The Trump spam plan rewards the debt collection industry despite racking up among the highest number of consumer abuse complaints and millions of dollars in fines and legal penalties for misconduct. Allied Progress has released several reports on the issue, including: 1) an analysis showing the debt collection industry trade groups have spent over $2.1 million on federal lobbying since Trump took office, and debt collectors have donated over $343,000 to Republican political campaigns since 2016; 2) a report on the history of consumer abuse from some of the debt collection industry’s biggest players; and 3) an analysis of the public comments submitted on the rule finding that at least 1,221 comments filed in support of the rule came openly from the debt collection industry – amounting to 1 out of every 7 comments.

WHAT YOU NEED TO KNOW: 

Political Appointee Tom Pahl, Who Has Advocated For Debt Collectors Throughout His Career, Is Leading The Trump/Kraninger CFPB’s Efforts To Make It Easier For Debt Collectors To Harass Consumers By Sending Unlimited Texts And Emails

Tom Pahl Is The CFPB’s Policy Associate Director For Research, Markets, And Regulations, A Political Position Created By Then-Director Mick Mulvaney As He Prioritized Loosening Regulations On Debt Collection.

Tom Pahl Is Currently The CFPB’s Policy Associate Director For Research, Markets, And Regulations, A Political Position Created By Then-Director Mick Mulvaney.

Thomas Pahl’s Position As Policy Associate Director for Research, Markets & Regulations “Is A Political Post” Created By Then-Acting Director Mick Mulvaney.“Tom Pahl has had the opportunity to make the regulatory rounds in recent years, uniquely preparing him for this moment. On Monday he returns to the Consumer Financial Protection Bureau (CFPB) as Policy Associate Director for Research, Markets & Regulations (RMR). He will report directly to Acting Director Mick Mulvaney. […] Unlike Pahl’s previous CFPB job as a career staffer, this latest job is a political post. In most federal agencies the top person, a political appointee, has a handful of positions available to bring in his or her own senior team. The Federal Trade Commission, for example, has nine such slots. The CFPB had none. Acting Director Mulvaney has created such positions and has hired individuals for those roles.” [Stephanie Eidelman, “Tom Pahl Returns to CFPB, Will Oversee Debt Collection Rulemaking at Critical Juncture,” insideARM, 04/19/18]

Pahl Was Likely Brought On By Then-Acting CFPB Director Mick Mulvaney Because Of His Debt Collection Rulemaking Experience; Now-Deputy Director Brian Johnson May Have Recommended Him For His Current Position.

Tom Pahl Was Likely Brought On By Mulvaney Because Of His Experience In The Federal Trade Commission’s Debt Collection Rulemaking. “Acting Director Mulvaney has said he views debt collection rulemaking as a priority. Given Pahl’s many years of deep experience in this arena, we could expect him to be up to speed extremely quickly and help to make this priority a reality.” [Stephanie Eidelman, “Tom Pahl Returns to CFPB, Will Oversee Debt Collection Rulemaking at Critical Juncture,” insideARM, 04/19/18]

On March 16, 2018, Then-Principal Policy Director Brian Johnson Told Other Senior CFPB Officials That He’d Like To “Bring In A Candidate” For “An RMR PD Interview.” On March 16, 2018 Brian Johnson emailed Kirsten Sutton Mork and Emma Doyle to request “an RMR PD interview,” saying “I’d like to bring in a candidate, per my conversation earlier this week.” [Email from Brian Johnson to Kirsten Sutton Mork and Emma Doyle, 03/16/18 (FOIA #CFPB-2018-517-F, p. 1023)]

Just Over A Month Later, It Was Reported That The CFPB Would Be Hiring Thomas Pahl As Policy Associate Director For Research, Markets, And Regulations, Reporting Directly To Then-Acting Director Mick Mulvaney. On April 19, 2018, it was reported that the CFPB would be bringing in Thomas Pahl “as Policy Associate Director for Research, Markets & Regulations (RMR)” and would be “report[ing] directly to Acting Director Mick Mulvaney.” [Stephanie Eidelman, “Tom PahlReturns to CFPB, Will Oversee Debt Collection Rulemaking at Critical Juncture,” insideARM, 04/19/18]

  • CFPB’s Research, Markets And Regulations Policy Associate Director Is “Responsible For Monitoring Consumer Financial Markets, Conducting Research, And Writing Rules.”[Research, Markets & Regulations,” Consumer Financial Protection Bureau, accessed 05/13/19]

Thomas Pahl Was Poised To Be Displaced At The FTC At The Time. “In February 2017 Acting Federal Trade Commission Chairman Maureen Ohlhausen, a Trump appointee and advocate of ‘regulatory humility,’ named Pahl Acting Director FTC Bureau of Consumer Protection. Earlier this year, President Trump announced that he had nominated Ohlhausen to be a judge on the United States Court of Federal Claims, which meant that Pahl would likely be replaced by someone chosen by an incoming FTC Chairman.” [Stephanie Eidelman, “Tom Pahl Returns to CFPB, Will Oversee Debt Collection Rulemaking at Critical Juncture,” InsideARM, 04/19/18]

Consumers Advocates Say The CFPB’s Proposed Rule on Debt Collection Gives The Debt Collection Industry “Almost Everything” It Wants—And Call It Another Example Of The CFPB “Catering To Businesses Instead Of Consumers.”

Consumer Advocates Charged That The CFPB’s Proposed Rule Gave The Debt Collection Industry “‘Almost Everything’” It Wanted And Accused The Bureau Of “‘Catering To Businesses Instead Of Consumers.’”

Consumers Advocates Charged That The CFPB Gave Debt Collectors “‘Almost Everything That The Industry Wanted’” And Accused It Of “‘Catering To Businesses Instead Of Consumers.’” “Consumer advocates, though, say the bureau set the limit too high. ‘We’re very upset and very concerned — I think outraged might be the right word for it,’ said Margot Saunders, senior counsel at the National Consumer Law Center. ‘Almost everything that the industry wanted, the bureau gave them,’ Saunders said. ‘Although they didn’t go as far as the industry wanted, the whole rule is to expand collectors’ rights. … They’re not expanding consumers’ rights.’ […] Melissa Stegman, senior policy counsel at the Center for Responsible Lending, agreed, accusing the CFPB of ‘again catering to businesses instead of consumers’ in an emailed statement.” [Katy O’Donnell, “CFPB overhauls rules for debt collectors as consumer groups balk,” Politico, 05/07/19]

The Debt Collection Industry “Responded With Limited Enthusiasm” To The Proposal, With The CEO Of Trade Group ACA International Saying They Appreciated The “‘Potential Clarity’” Of Parts Of The Rule. “While debt collectors and consumer advocates were still digesting the 538-page proposal, the industry initially responded with limited enthusiasm while consumer advocates slammed the plan. Mark Neeb, CEO of collection trade group ACA International, said the group appreciates the ‘potential clarity’ provided by parts of the rule. ‘However, we think there are several areas that need to be clarified and improved upon before the rule is finalized, including the arbitrary limit on call attempts that could unnecessarily impede communications with consumers,’ Neeb added.” [Katy O’Donnell, “CFPB overhauls rules for debt collectors as consumer groups balk,” Politico, 05/07/19]

Tom Pahl Previously Oversaw Debt Collection Rulemaking Both At The CFPB And The Federal Trade Commission.

Tom Pahl Was “Closely Involved” In “Shepherding” The CFPB’s Previous Debt Collection Rulemaking While A Managing Counsel At The Bureau For Over Three Years.

Before He Was Named A Policy Associate Director At The CFPB, TomPahl Was A Managing Counsel “Closely Involved In The CFPB’s Debt Collection Rulemaking” In The Bureau’s Office Of Regulations. “Pahl also spent time as managing counsel at the Consumer Financial Protection Bureau’s Office of Regulations, where he was responsible for rulemaking, guidance and policy development activities. During this time, Pahl was closely involved in the CFPB’s debt collection rulemaking efforts.” [“Tom Pahl, Acting Director of the FTC’s Bureau of Consumer Protection, to Speak at ACA International’s Washington Insights Conference,” ACA International, 03/14/18]

  • Tom Pahl Was Managing Counsel At The CFPB For Three And A Half Years. “Pahl is in demand because he spent three and a half years as a managing counsel at the bureau, a creation of the 2010 Dodd-Frank financial regulatory law that has already levied $12 billion in fines and penalties against firms that break the rules.” [“Veteran Consumer Finance Regulator Heads Downtown,” Congressional Quarterly Magazine, 11/11/16]

Tom Pahl “Spent More Than Three Years Shepherding” The CFPB’s Previous Debt Collection Rule Efforts. “At the agency, Pahl spent more than three years shepherding a contentious plan to regulate the debt-collection industry, about which the bureau receives more consumer complaints than any other industry.” [“Veteran Consumer Finance Regulator Heads Downtown,” Congressional Quarterly Magazine, 11/11/16]

Tom Pahl Was “In The Thick Of It” At The CFPB, “Responsible For Rulemaking, Policy Development And Regulatory Guidance To Implement Laws Governing Debt Collection.” “Pahl was in the thick of it at the bureau, responsible for rulemaking, policy development and regulatory guidance to implement laws governing debt collection and credit reporting.” [“Veteran Consumer Finance Regulator Heads Downtown,” Congressional Quarterly Magazine, 11/11/16]

Pahl “Managed” The Federal Trade Commission Division That Oversaw Rulemaking And Policy Development For Debt Collection Activities For Six Years.

Tom Pahl Oversaw Rulemaking And “Policy Development Activities” Over Debt Collection As An Assistant Director For The Division Of Financial Practices At The Federal Trade Commission’s Bureau Of Consumer Protection. “Prior to joining the CFPB, Mr. Pahl was Assistant Director for the Division of Financial Practices, Bureau of Consumer Protection at the Federal Trade Commission, where he managed the division responsible for law enforcement, rulemaking and policy development activities related to financial services, including debt collection, payday lending, mortgage lending and debt relief services.” [“Former CFPB Attorney Thomas B. Pahl Joins Arnall Golden Gregory’s Washington Office,” BusinessWire, 09/20/16]

Tom Pahl Was Assistant Director In The FTC’s Division Of Financial Practices For Six Years. “Pahl first joined the FTC in 1990, and spent more than two decades serving in various positions, including for six years as assistant director in the Division of Financial Practices, which oversees debt collection issues. In his current position, Pahl oversees the FTC’s attorneys, investigators, and administrative personnel working to protect consumers from unfair and deceptive practices in the marketplace.” [“Tom Pahl, Acting Director of the FTC’s Bureau of Consumer Protection, to Speak at ACA International’s Washington Insights Conference,” ACA International, 03/14/18]

Tom Pahl Has Railed Against Potential Debt Collection Rules And Argued That The CFPB “‘Should Abandon These Efforts As An Exercise In ‘Regulatory Humility.’”

Tom Pahl Has Opposed CFPB Limits Against How Many Times Debt Collectors Can Contact Consumers, Arguing The Bureau “Should Abandon These Efforts As An Exercise In ‘Regulatory Humility.’”

Thomas Pahl Opposed CFPB Limits On How Many Times Debt Collectors Can Contact Consumers, Arguing That The Bureau “Should Abandon These Efforts As An Exercise In ‘Regulatory Humility.’” “In January 2017, Thomas Pahl wrote a piece opposed to CFPB limits on the number of times debt collectors may contact consumers titled “Collector Contact Caps and the Application of ‘Regulatory Humility.’” Responding to a recent CFPB announcement that it was “considering proposing rules that would mandate specific numerical limits on communications through all methods between debt collectors and consumers,” Pahl said that the Bureau “should abandon these efforts as an exercise in ‘regulatory humility.'” [Thomas Pahl, “Collector Contact Caps and the Application of ‘Regulatory Humility,'”insideARM, 01/30/17]

Pahl Has Argued That States, Not The CFPB, Should Have “Primary Oversight” Over Attorneys In Debt Collection Litigation.

Thomas Pahl Has Argued That States, And Not The CFPB, Should Have “Primary Oversight” Over Aspects Of Debt Collection Litigation. In December 2017, Thomas Pahl wrote a piece opposed to CFPB regulation of debt collection litigation titled, “Why States Should Have Primary Oversight of Attorney’s Activities in Debt-Collection Litigation.” He wrote that the CFPB’s work on debt collection “may impose even more extensive and complicated requirements to flesh out meaningful involvement, substantiation, and other FDCPA [Fair Debt Collection Practices Act] concepts for representations made in complaints.” He claimed that applying “FDCPA standards and state court and state bar standards at the same time to the representations in complaints risks conflict and confusion that will make it harder for collection litigation attorneys to comply with the law.” [Thomas Pahl, “Why States Should Have Primary Oversight of Attorney’s Activities in Debt-Collection Litigation,” insideARM, 12/14/18]

Tom Pahl Has Represented Companies Regulated By The CFPB, Including Debt Collectors And Credit Reporting Agencies.

While At Arnall Golden Gregory LLP, Tom Pahl Represented CFPB-Regulated Companies, Including “Consumer Reporting Agencies, Debt Collectors, Debt Buyers, [And] Creditors.”

Thomas Pahl Represented “Consumer Reporting Agencies, Debt Collectors, Debt Buyers, Creditors And Other Consumer Financial Services Companies.”“Thomas B. Pahl, the former managing counsel at the Consumer Financial Protection Bureau, recently joined Arnall Golden Gregory LLP […] He will focus on representing consumer reporting agencies, debt collectors, debt buyers, creditors and other consumer financial services companies in his practice. Pahl led efforts for rulemaking, policy development and regulatory guidance to implement the Fair Debt Collection Practices Act, the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the Dodd-Frank Act and other regulatory requirements at the CFPB.” [“Former CFPB Managing Counsel Thomas Pahl Joins D.C. Law Firm,” ACA International, 09/22/16]

Pahl Worked “Closely” With Lead Consumer Regulatory Lawyer Robert Belair, Who Has Represented A Major Debt Collection Industry Trade Group That Had 575 Member Companies As Of Early 2017.

Arnall Golden Gregory (AGG) Claimed That Tom Pahl Was To ‘Work Closely” With Robert R. Belair, The Firm’s “Leader Of The Privacy And Consumer Regulatory Practice.” “Mr. Pahl will work closely with Robert R. Belair, leader of the Privacy and Consumer Regulatory Practice and the firm’s Washington office.” [Press Release, Arnall Golden Gregory LLP, accessed 07/03/19]

AGG Partner Robert Belair Has Been “Regulatory Council For DBA International.” “AGG Partner Robert R. Belair, who leads AGG’s Privacy Practice Group, is quoted in a May 23, 2012, Collections & Credit Risk article titled ‘Debt Collectors Ramping Up For CFPB Audits’ […]. The Consumer Financial Protection Bureau is expected to clarify its guidelines for audits on July 21, 2012, but in the meantime, organizations like ACA International and DBA International have created training modules regarding best practices for complying with the Fair Debt Collections Practice Act. Mr. Belair, who also serves as regulatory council for DBA, finds it highly likely that the CFPB will base its examination on the FDCPA, which is why DBA is developing a certification program for members to help them learn industry best practices and benchmark their performance against regulatory guidelines and the expectations of auditors.” [“Bob Belair Quoted in Collections & Credit Risk,” Arnall Golden Gregory LLP, 05/23/12]

In Early 2017, DBA International Became The Receivables Management Association, A “Trade Association That Represents More Than 575 Companies” In The Debt Collection Industry. “The receivables management industry is abuzz as newly elected association President Mark Naiman announced that DBA International is now Receivables Management Association. The membership voted to approve the new name today as part of a change in the association bylaws.” [“DBA International is now Receivables Management Association,”insideARM, 02/09/17]

Tom Pahl Is “A Frequent Speaker” At Conferences Hosted By ACA International, The Largest Debt Collection Industry Trade Group.

Tom Pahl Is “A Frequent Speaker” At Events Hosted By ACA International, “The Largest Trade Group For The Debt Collection Industry.”

Tom Pahl Is “A Frequent Speaker” At Events Hosted By ACA International. “As a frequent speaker at ACA events, Pahlalso appeared at ACA International’s Washington Insights Conference in both 2015 and 2016 and shared insights into the CFPB’s approach to developing rules to regulate the accounts receivable management industry, as well as debt collection research conducted by the CFPB to inform its decision making.” [“Thomas Pahl to Return to CFPB’s Rulemaking Division,” ACA International, 04/18/18]

  • ACA International Is “The Largest Trade Group For The Debt Collection Industry.” “ACA International, the largest trade group for the debt collection industry, represents approximately 2,500 members, including credit grantors, third-party collection agencies, asset buyers, attorneys, and vendor affiliates, who employ more than 129,000 employees worldwide.” [“ACA International Fact Sheet,” ACA International, January 2019]

In May 2019, Tom Pahl Was A Featured Speaker At ACA International’s 2019 “Washington Insights Fly-In.”

Tom Pahl Was A Featured Speaker At ACA International’s 2019 Washington Insights Fly-In That Took Place May 14-16, 2019. [“Washington Insights Speakers,” ACA International, accessed 07/01/19]

In May 2018, Tom Pahl And Then-CFPB Director Mick Mulvaney Were Featured Speakers At ACA International’s “Washington Insights Conference.”

Tom Pahl Was A Featured Speaker At ACA International’s 2018 “Washington Insights Conference” That Took Place May 21-23, 2018.“Mulvaney and Pahl are speakers at ACA International’s upcoming Washington Insights Conference, May 21-23. Members will greatly benefit from their insights on the FTC, CFPB and regulations for the accounts receivable management industry.” [“Thomas Pahl to Return to CFPB’s Rulemaking Division,” ACA International, 04/18/18]

In Both 2015 And 2016, Tom Pahl Was A Featured Speaker At ACA International’s “Washington Insights Conference.”

Tom Pahl Was A Featured Speaker At Both ACA International’s 2015 And 2016 Washington Insights Fly-Ins. “As a frequent speaker at ACA events, Pahl also appeared at ACA International’s Washington Insights Conference in both 2015 and 2016 and shared insights into the CFPB’s approach to developing rules to regulate the accounts receivable management industry, as well as debt collection research conducted by the CFPB to inform its decision making.” [“Thomas Pahl to Return to CFPB’s Rulemaking Division,” ACA International, 04/18/18]

In November 2011, Tom Pahl Led A Session At ACA International’s “Fall Forum,” Where He Claimed That The Fair Debt Collection Practices Act Was Intended “To Be Enforced Primarily By Private Actions Rather Than Through Government Enforcement.”

In November 2011, Tom Pahl Led A Session On “The FTC’s Enforcement Priorities Related To The Collection Industry” At ACA International’s 2011 Fall Forum. “ACA International’s 2011 Fall Forum conference brought together credit and collection professionals in Chicago. The event took place Nov. 9-11, 2011, with nearly 400 ACA members gathering for three days of education and networking. […] In a session led by Thomas Pahl, assistant director of the Federal Trade Commission’s Division of Financial Practices, attendees learned about the FTC’s enforcement priorities related to the collection industry.” [“Fall Forum Takes Chicago [Collector],” Insurance News Net, 01/02/12]

  • At The Event,Pahl Spoke About The “Value The Debt Collection Industry” Brings To The Economy And Claimed That The Fair Debt Collection Practices Act Was Intended “To Be Enforced Primarily By Private Actions Rather Than Through Government Enforcement.” “Pahl noted the FTC realizes the value the debt collection industry, working in compliance with the Fair Debt Collection Practices Act, brings to the American economy. […] Pahlalso addressed the future relationship between the FTC and the Consumer Financial Protection Bureau as it relates to collection industry oversight. He pointed out that when the FDCPA was originally passed, Congress intended for it to be enforced primarily by private actions rather than through government enforcement.” [“Fall Forum Takes Chicago [Collector],” Insurance News Net, 01/02/12]

In July, Tom Pahl Spoke at an “Executive Summit” Of The Receivables Management Association International, A Debt Collection Trade Group That Hosted Pahl At Its Annual Conference Last Year.

Tom Pahl Spoke At An “Intimate Gathering” Of Industry Insiders At An “Executive Summit” Of The Receivables Management Association International (RMAI).

Tom Pahl Spoke at RMAI’s Executive Summit On July 31 At 1:50 PM In A Session Titled “A Conversation With Our Federal Regulators.”[2019 Executive Summit Agenda, Receivables Management Association International, accessed 06/25/19]

  • RMAI Hosted Its 2019 Executive Summit, An “Intimate Gathering Of 125 Professionals,” From July 30 To August 1 In Sedona, Arizona. From July 30 To August 1 In Sedona, Arizona, RMAI will be holdingan “intimate gathering of 125 professionals provides attendees the opportunity to network with other executives, have conversations with policymakers, and receive education on executive-level operations.” [2019 Executive Summit, Receivables Management Association International, accessed 06/25/19]

RMAI Is A Debt Collection Industry Trade Group.

RMAI Is A Debt Collection Industry Trade Group That “Represents More Than 575 Companies That Purchase Performing And Nonperforming Receivables On The Secondary Market.” “Receivables Management Association is the nonprofit trade association that represents more than 575 companies that purchase performing and nonperforming receivables on the secondary market.” [“DBA International is now Receivables Management Association,”insideARM, 02/09/17] 

In February 2018, Tom Pahl Was A Featured Speaker At RMAI’s Annual Conference.

Tom Pahl Was A Featured Speaker At The 2018 RMAI Annual Conference In Las Vegas On February 7, 2018, Speaking On “Updates, Forecasts, And Financial Services: An In-depth Discussion With The FTC.”[RMAI 2018 Annual Conference Agenda, Receivables Management Association International, accessed 07/01/19]

Tom Pahl Is A Longtime “Opponent Of Regulation” Who Helped “Repeal A Rule Requiring Businesses Warn Consumers About The Potentially Lethal Danger Of Quick-Freeze Aerosol Spray” At The FTC.

Tom Pahl Is An “Opponent Of Regulation” Who Helped The Federal Trade Commission (FTC) “Repeal A Rule Requiring Businesses Warn Consumers About The Potentially Lethal Danger Of Quick-Freeze Aerosol Spray” In The 1990s.

Tom Pahl Is An “Opponent Of Regulation” Who Helped “Repeal A Rule Requiring Businesses Warn Consumers About The Potentially Lethal Danger Of Quick-Freeze Aerosol Spray” “During His Tenure At The FTC In The 1990s.” “Despite Pahl’s familiarity with the commission, he may appear an odd choice to run a bureau that aims to protect consumers. Pahl has long advocated for doing away with many of what he and fellow conservatives see as excessive regulation. During his tenure at the FTC in the 1990s, he helped repeal a rule requiring businesses warn consumers about the potentially lethal danger of quick-freeze aerosol spray. He also helped see the abandon of the FTC’s regulations on fallout shelters, first put in place during the Cold War.” [“FTC Taps Opponent of Regulation To Head Up Consumer Protection Efforts,” International Business Times, 02/09/17]

The Receivables Management Association International Has Spent $480,000 Lobbying The Federal Government, Including The CFPB, Since Donald Trump Took Office.

Receivables Management Association International (RMAI) Is A Debt Collection Industry Trade Group.

RMAI Is A Debt Collection Industry Trade Group That “Represents More Than 575 Companies That Purchase Performing And Nonperforming Receivables On The Secondary Market.” “Receivables Management Association is the nonprofit trade association that represents more than 575 companies that purchase performing and nonperforming receivables on the secondary market.” [“DBA International is now Receivables Management Association,”insideARM, 02/09/17]

In 2017, RMAI Spent $200,000 Lobbying Congress, The CFPB, The Treasury Department, The OCC, And The FTC.

In The First Quarter Of 2017, RMAI Spent $50,000 Lobbying Congress, The CFPB, And The FTC. In the first quarter of 2017 RMAI paid K&L Gates LLP $50,000 to lobby Congress, the CFPB, and FTC on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 04/21/17]

In The Second Quarter Of 2017, RMAI Spent $50,000 Lobbying Congress, The CFPB, The FTC, And The OCC. In the second quarter of 2017, RMAI paid K&L Gates LLP $50,000 to lobby Congress, the CFPB, the FTC, and OCC on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act” and H.R. 10 – the Financial CHOICE Act of 2017.[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 07/19/17]

In The Third Quarter Of 2017, RMAI Spent $50,000 Lobbying Congress, The CFPB, The FTC, And The OCC.In the third quarter of 2017, RMAIpaid K&L Gates LLP $50,000 to lobby Congress, the CFPB, the FTC, and OCC on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act;” H.R. 10 – the Financial CHOICE Act of 2017; H.R. 864 – Stop Debt Collection Abuse Act of 2017; and H.R. 1849 – Practice of Law Technical Clarification Act of 2017[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 10/17/17]

In The Fourth Quarter Of 2017, RMAI Spent $50,000 Lobbying Congress, The CFPB, The FTC, And The OCC. In the fourth quarter of 2017, RMAI paid K&L Gates LLP $50,000 to lobby Congress, the CFPB, the FTC, and Treasury Department on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act” and “H.R. 1849 and H.R. 4550, Practice of Law Technical Clarification Act of 2017.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 01/20/18]

In 2018, RMAI Spent $220,000 Lobbying Congress, The Treasury Department, The CFPB, And The FTC.

In The First Quarter Of 2018, RMAI Spent $50,000 Lobbying Congress, The Treasury Department, The CFPB, And The FTC. In the first quarter of 2018, RMAI paid K&L Gates LLP $50,000 to lobby Congress, the CFPB, FTC, and Treasury Department on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act,” and “H.R. 1849 and H.R. 4550, Practice of Law Technical Clarification Act of 2017.”[K&L Gates LLP, U.S. Senate Lobbying Disclosure Act Database, 04/18/18]

In The Second Quarter Of 2018, RMAI Spent $60,000 Lobbying Congress, The Treasury Department, The CFPB, And The FTC. In the second quarter of 2018, RMAI paid K&L Gates LLP $60,000 to lobby Congress, the CFPB, FTC, and Treasury Department on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act,” and “H.R. 1849 and H.R. 4550, Practice of Law Technical Clarification Act of 2017.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 07/18/18]

In The Third Quarter Of 2018, RMAI Spent $60,000 Lobbying Congress, The CFPB, And The FTC. In the third quarter of 2018, RMAI paid K&L Gates LLC $60,000 to lobby Congress, the CFPB, and FTC on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act,” and “H.R. 1849 and H.R. 4550, Practice of Law Technical Clarification Act of 2017.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 10/20/18]

In The Fourth Quarter Of 2018, RMAI Spent $50,000 Lobbying Congress, The CFPB, And The FTC. Inthe fourth quarter of 2018, RMAI paid K&L Gates LLP $50,000 to lobby Congress, the CFPB, and FTC on “implementation of Title X, P.L. 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act,” and “H.R. 1849 and H.R. 4550, Practice of Law Technical Clarification Act of 2017.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 01/19/19] 

So Far In 2019, RMAI Has Spent $60,000 On Federal Lobbying.

In The First Quarter Of 2019, RMAI Spent $60,000 Lobbying Congress, The CFPB, And The FTC. In the first quarter of 2019,RMAI paid K&L Gates LLP $60,000 to lobby Congress, the CFPB, and FTC on “Issues related to debt re-sales and collection.”[K&L Gates LLP LD-2 Disclosure Form, U.S. Senate Lobbying Disclosure Act Database, 04/19/19]

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