Article I Reasonable and Responsible Diligence will be done on All Assigned Accounts
- Prior to sending a first contact letter, we will make reasonable efforts to verify the accuracy of all consumer information, including full names as well as current addresses and phone numbers.
- Upon assignment of an account, we will confirm that documentation, such as invoices and agreements, exists to validate the debt amount.
- Confirmation of the originating creditor will be done and listed on the first consumer contact.
- We will not engage in purchasing large debt portfolios and will not accept assignment of accounts that do not have clear chains of ownership.
Article II Debt Validation will be Sent Upon Consumer Request
- If a consumer so requests, a debt validation letter with supporting documentation will be sent to the address on file or any other address provided by the consumer.
- We will ask an originating creditor to provide any additional information that a consumer may desire and which may prove helpful in resolving the account.
- Even if the statutory dispute period has expired, we will fulfill debt validation requests made in good faith by a consumer.
Article III Accounts will be Handled Responsibly and Honestly with the Goal of Settlement
- Our employees will be expected to comply with all applicable Federal, State and local laws and regulations regarding the fair and ethical collection practices and procedures.
- Any employee found to be conducting him or herself in an unethical manner will be terminated.
- Our employees will be trained to make every effort to work out a debt resolution strategy that accommodates a consumer’s personal and current financial situation.
- Different payment options will be offered and explained to a consumer that cannot pay their debt all at once.
- Agreed-upon payment plans will be confirmed in writing by a letter of agreement mailed to the consumer wherein the payment terms are clearly delineated.
- If an agreed-upon payment plan is instituted prior to the account being reported to a credit reporting agency, we will not report that account during the pendency of the repayment plan so long as payments are being timely remitted.
Article IV Accounts may be Suspended in Hardship Cases
- If a consumer’s account has been assigned in error as a result of identity theft or fraud, we will close the account and request that the credit reporting agencies delete any trade lines that we have reported for that account.
- We will recommend to the originating creditor that collection efforts be suspended on accounts where verifiable financial hardship has occurred due to medical issues.
- If a consumer who has entered into a payment plan contacts us to demonstrate an unforeseen change in circumstances that makes the payment plan untenable, we will work with the consumer to revise the terms to ones that are manageable given the consumer’s current state of financial affairs.
- If a consumer misses an agreed-upon payment, we will provide a grace period that may be extended upon a consumer’s reasonable request before cancellation of the payment terms takes effect.
- Immediately upon receipt of a bankruptcy trustee’s notice of petition, all collection efforts on the applicable account will be stayed during pendency of the bankruptcy action.
Article V Strict Adherence to a “No Harassment” Policy
- Our employees will be trained and monitored to ensure that all dialogue with a consumer is open, honest and respectful.
- The terms of an account or the documentation provided in connection therewith by the originating creditor will never be exaggerated or misrepresented in any regard.
- Unsolicited messages will not be left on a consumer’s voicemail.
- We will not email a consumer unless the consumer has specifically requested and authorized communication via an email address provided by the consumer for that purpose and in compliance with State laws.
- Any complaints received about our conduct will be promptly and thoroughly investigated by a manager. If it is found that we have acted in error or have fallen short of the standard to which we hold ourselves, time and attention will be dedicated to correct the mistake without delay.
Article VI Guidelines to Safeguard the Confidentiality of Certain Consumer Information
- We will enter into a Business Associate Agreement with any creditor that will be assigning medical debt accounts for collection.
- Any disputes filed with a credit reporting agency will be promptly investigated and we will instruct the applicable credit agency to correct any information that is found to be inaccurate.
- We have, and will maintain, an account with the Consumer Financial Protection Bureau and ensure that any inquiry filed is replied to in a timely manner.
- We will maintain reasonable internal safeguards and compliance controls to ensure that confidential consumer information is kept secure and not disclosed to any third party without the consumer’s prior authorization.
- Quality control and review efforts will be enforced on an ongoing basis with all employee personnel to ensure appropriate monitoring and oversight of collection practices and procedures.
- Software privacy controls will be maintained and implemented by managers and in-house counsel and, at the outset of our relationship, creditors will be asked to assign all account information through a secure file upload.
Article VII Responsible Use of Litigation and Judgment Enforcement Tools
- No account will be litigated without a specific suit authorization recommendation and approval following an internal review of the account by in-house counsel or a management-level officer.
- We will not commence suit unless there is sufficient documentation of the debt, chain of title and verification of a consumer’s identity and address(es).
- Only law firms and process servers that are reputable, licensed and in good standing will be engaged by us.
- We will not move forward with a recommendation for suit on any account where we or our attorneys confirm that the applicable statute of limitations on the debt has expired.
- Our consumer contacts will make clear that litigation may be forthcoming prior to its actual commencement in order to enable a consumer ample opportunity to settle the account prior to legal action being instituted.
- We will instruct our attorneys to confirm that a judgment has been appropriately docketed prior to engaging in judgment enforcement activities such as the issuing of restraints and information subpoenas.
- Our attorneys will be provided with full debtor cards and account information verifying the consumer and debt amount upon receipt of any case and no case will be so assigned without an executed suit authorization.
- No matter the stage at which a litigation or judgment enforcement action resides, we will always engage in good faith settlement negotiations in an attempt to amicably and respectfully resolve any case.
The use of the words “we” or “our” is meant to apply to Capital Resource Management, Inc. and our affiliated corporate entities and employees. It is our intention to try and ensure that all of our agents and attorneys adhere to these, or similar, standards of practice when representing us and our creditor-clients in any respect and in any forum.
If you feel that we or any employee or agent of ours has not abided by the standards set forth in our Consumer Bill of Rights, please contact us at 1-844-277-3277 and ask to speak with our compliance officer. If so requested, all complaints can be maintained as confidential.