I’m thrilled to announce that Frost Echols is the new sponsor for the Compliance Digest. Frost Echols reputation has been built on aggressively protecting the rights of businesses throughout our local jurisdictions. Founding partners, Mike Frost and Chad Echols, developed a deep understanding of regulatory compliance, commercial litigation and business operations through years of advising executives in the collection industry. We are committed to a strategic, economic, and aggressive approach to your legal representation.
Every week, AccountsRecovery.net brings you the most important news in the industry. But, with compliance-related articles, context is king. That’s why the brightest and most knowledgable compliance experts are sought to offer their perspectives and insights into the most important news of the day. Read on to hear what the experts have to say this week.
N.J. Supreme Court Rules Consumers Can’t Sue to Void Debts Bought by Unlicensed Debt Buyers
In a case that was defended in part by the team at J. Robbin Law, the New Jersey Supreme Court has ruled that the state’s Consumer Finance Licensing Act does not give borrowers a private right of action to void their loan contracts, affirming the dismissal of a class-action lawsuit against a group of debt buyers that allegedly purchased the plaintiff’s credit card debt without the required license. More details here.
WHAT THIS MEANS, FROM MIKE FROST OF FROST ECHOLS: The New Jersey Supreme Court recently issued a significant decision for the receivables management industry, holding that the New Jersey Consumer Finance Licensing Act (CFLA) does not provide borrowers with an implied private right of action to affirmatively seek to void a loan or credit agreement based solely on an alleged licensing violation. In Scott Diana v. LVNV Funding LLC, the Court unanimously affirmed the dismissal of a putative class action brought by a consumer who argued that a series of debt purchasers lacked the licenses allegedly required under the CFLA. Applying New Jersey’s well-established test for implied statutory causes of action, the Court concluded that while consumers are among the class the statute was designed to protect, the Legislature did not intend to create a private enforcement mechanism, instead reserving enforcement authority to the New Jersey Commissioner of Banking and Insurance and other governmental authorities.
The decision is an important victory for the debt collection and debt buying industries because it significantly limits the ability of plaintiffs to bring class actions seeking to invalidate debt purchases or collection efforts based solely on alleged licensing deficiencies. At the same time, the Court expressly declined to address the underlying question of whether purchasers of charged-off consumer debt are required to obtain a CFLA license, leaving that issue unresolved for another day. As a result, while the ruling removes a substantial source of potential private litigation exposure, creditors, debt buyers, and collection agencies should continue to monitor developments regarding New Jersey licensing requirements and maintain appropriate compliance practices until additional guidance is provided by the courts or the Legislature.
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Regulators Delay Sweeping HIPAA Cybersecurity Mandates as Privacy Rule Changes Move First
Federal regulators have delayed the most sweeping rewrite of the HIPAA Security Rule in two decades, giving healthcare providers and their business associates, including agencies that collect on medical debt, at least another year before new cybersecurity mandates arrive. More details here.
WHAT THIS MEANS, FROM LESLIE BENDER OF EVERSHEDS SUTHERLAND: The U.S. Department of Health and Human Services Office for Civil Rights (“OCR”) appears to be moving HIPAA Privacy Rule updates ahead of the agency’s more controversial proposed updates to the HIPAA Security Rule. The Privacy Rule proposal, first issued in early 2021, aims to support care coordination, individual engagement, reduced regulatory burden, and continued protections for protected health information, or PHI. Updates to the 2021 proposal may be released by the end of this summer.
The pivot is noteworthy because HHS received significant pushback on the Security Rule proposal from a coalition of health systems and healthcare professional associations, which warned that the proposal would impose substantial costs without corresponding benefits and would run counter to the Administration’s deregulatory priorities. The Security Rule rulemaking has been pushed back to 2027, while OCR appears prepared to proceed first with changes to the Privacy Rule.
The Privacy Rule protects medical records and other individually identifiable health information created, received, maintained, or transmitted by or on behalf of covered entities, and it regulates when covered entities and business associates may use or disclose PHI. If finalized substantially as proposed, the updates would affect HIPAA-covered entities, including healthcare providers, health plans, and healthcare clearinghouses, as well as business associates that support covered-entity obligations involving PHI. The key operational touchpoints are access requests, care coordination disclosures, fee transparency, Notices of Privacy Practices, and certain business associate arrangements. It is noteworthy that OCR has focused most of its enforcement efforts on the HIPAA’s Privacy Rule’s right of access compliance (or not) against a backdrop of nearly two dozen states’ evolving privacy laws that themselves may confirm individuals’ rights to access their personal data.
Individual access could be the most immediate operational issue. The proposal would allow individuals to inspect PHI in person and use personal resources to take notes or capture images of their PHI. It would also shorten the response deadline for access requests from 30 calendar days to 15 calendar days, with one extension of no more than 15 calendar days. HIPAA-covered companies may want to test whether intake, verification, retrieval, and release-of-information workflows can meet that shorter window, particularly because OCR has focused on individual access for more than a decade.
The proposal also would clarify electronic form-and-format requirements, including that “readily producible” electronic PHI may include ePHI transmitted through secure, standards-based APIs to personal health applications chosen by individuals. It would create a pathway for individuals to direct covered healthcare providers and health plans to request electronic PHI from another covered provider or plan. The rule also would revise access-fee requirements by specifying when access is free, requiring posted fee schedules, and requiring fee information, individualized estimates, and itemized bills. HIPAA-covered companies may want to compare current fee schedules, web disclosures, API capabilities, and release-of-information processes against those proposed requirements.
Care coordination is another major theme. The proposal would clarify that “health care operations” includes individual-focused care coordination and case management, create an exception to the “minimum necessary” standard for certain individual-level care coordination activities, and expressly permit disclosures to social services agencies, community-based organizations, home and community-based services providers, and similar third parties. HIPAA-covered companies may want to map current care coordination relationships and identify where business associate agreements, state privacy laws, or other federal laws could still affect disclosures.
The proposal would also affect day-to-day HIPAA administration. It would replace the “professional judgment” standard with a “good faith belief” standard in specified contexts, add a presumption of compliance absent evidence of bad faith, and replace the “serious and imminent threat” standard with a “serious and reasonably foreseeable” standard. It would eliminate the requirement that direct treatment providers obtain and retain written acknowledgments of receipt of Notices of Privacy Practices, establish an individual right to discuss the notice with a designated contact, and require revised notice content explaining key individual rights. HIPAA-covered companies may want to identify NPP templates, training materials, escalation protocols, and verification procedures that could need targeted updates.
The compliance timeline will be important once HHS issues any final rule. The 2021 NPRM stated that a final rule would become effective 60 days after publication, that covered entities and business associates would generally have 180 days after the effective date to comply, and that OCR would begin enforcement 240 days after publication. Before then, HIPAA-covered companies may want to prioritize a short readiness review focused on access-response timing, release-of-information processes, fee transparency, NPP updates, care coordination data sharing, and business associate allocation of responsibilities.
For now, the key development is not only what HHS may change, but what it appears to be prioritizing. If HHS continues on this path, HIPAA-covered companies, including their vendors, may want to treat the next major HIPAA compliance project as one focused on access, transparency, care coordination, and operationalizing revised privacy obligations, rather than on cybersecurity controls.
Judge Dismisses Claims Against Two CRAs, But Lets FDCPA, FCRA Claims Proceed Against CU and Law Firm
A District Court judge in Louisiana has partially granted motions to dismiss a Fair Debt Collection Practices Act and Fair Credit Reporting Act lawsuit against a credit union, one of its employees, its collection law firm, and the three major credit reporting agencies over an allegedly concealed vehicle repossession. More details here.
WHAT THIS MEANS, FROM ISSA MOE OF MOE LAW GROUP: This case (like several before it) highlights that not all credit reporting disputes are created equal. In this decision, the court dismissed several FCRA claims against CRAs where the alleged inaccuracies were not sufficiently specific or turned on legal issues the agencies were not required to resolve in connection with a dispute. On the other hand, the court allowed claims to proceed where the plaintiff had identified concrete, objectively verifiable factual reporting inaccuracies. The court also reaffirmed that each alleged furnishing of inaccurate information, coupled with an alleged failure to conduct a reasonable investigation, may trigger its own FCRA violation and associated statute of limitations period.
In response to this opinion and other recent decisions, furnishers and CRAs may want to review their dispute handling procedures and test whether they are designed to identify and distinguish legal disputes from factual inaccuracies. That could prove significant if you face an FCRA claim where this distinction is at issue, as courts are increasingly focusing less on the existence of a dispute and more on whether the challenged information was objectively and readily verifiable and reasonably investigated.
Report: CFPB Shows Signs of Life, But New Direction Raises Questions About Who Gets Supervised
After months of moves that appeared designed to shutter the Consumer Financial Protection Bureau entirely, the agency is showing unmistakable signs of activity again. What that activity looks like, however, represents a sharp departure from the Bureau the credit and collection industry has known. More details here.
CFPB Takes First Step Toward Revisiting Credit Card Late Fee Rule
The Consumer Financial Protection Bureau appears ready to take another look at credit card late fees, an issue that most thought was settled when the Biden-era $8 fee cap was vacated last year. More details here.
WHAT THIS MEANS, FROM JOANN NEEDLEMAN OF CLARK HILL: It’s very hard to make heads or tails out of what is or what will be the Consumer Financial Protection Bureau (CFPB). It is a portrait of numerous contradictions which makes it hard for the financial services industry let alone the ARM industry to navigate compliance expectations.
Here is what we currently know. The CFPB is still very much alive, though operating with a narrower focus and reduced resources. The Bureau has published an ambitious rulemaking agenda, continues to process consumer complaints, and is aggressively pursuing a handful of enforcement matters. At the same time, supervisory activity and new investigations remain limited, while operational questions linger regarding its ability to accommodate employees under its return-to-office mandate.
Here is what we don’t know. Brian Johnson has been nominated as CFPB Director, with a Senate Banking Committee hearing set for July 23. If he is not confirmed before Acting Director Russell Vought’s term expires on August 1, Deputy Director Mark Paoletta will assume the role on an interim basis. Johnson’s policy priorities remain unclear, although reports that the Bureau may revisit credit card late-fee regulations are likely to make that issue a focal point of his confirmation process. Assuming Johnson is confirmed it is unclear what his priorities will be and whether he will have enough time to achieve them. Rumbles that the Bureau wants to revisit credit card late fees certainly do not align with Johnson’s role within the credit card industry. Look for Democratic Senators to grill him on that issue.
If I had to make a prediction, over the next few years the Bureau will be primarily a rulemaking agency with very limited enforcement and probably even smaller supervision efforts. The states have picked up the slack in those areas which unfortunately does not bode well for the ARM industry. Supervision and enforcement have ticked up significantly at the state level with many state AGs (both red and blue) coordinating on large sale actions.
My biggest concern is what happens when the political pendulum inevitably swings again. State regulators have become increasingly emboldened by their expanded role in consumer protection and are unlikely to relinquish that authority, regardless of changes at the federal level. Over the past decade, Congress had multiple opportunities to strengthen and stabilize the CFPB’s structure to reduce the impact of dramatic shifts in regulatory philosophy, but neither party chose to do so. As a result, if the Bureau returns to a more aggressive supervisory and enforcement posture reminiscent of the Cordray or Chopra eras, the ARM industry should not assume it will be spared. Rather, it may face a renewed wave of regulatory scrutiny from all sides, making continued investment in compliance and risk management as important as ever.
House Dems Seek Industry Input on AI Regulation in Financial Services
Democrats on the House Financial Services Committee, led by Ranking Member Maxine Waters [D-Calif.], yesterday issued a Request for Information seeking public feedback on how AI is being used across the financial marketplace and what a modernized federal AI framework should look like. More details here.
Warner Floats Federal Framework for AI Agents, Presses Treasury on Financial Services Risks
Sen. Mark Warner [D-Va.] has released a discussion draft of legislation that would create the first federal framework governing AI agents that act on consumers’ behalf online, pairing the proposal with a letter urging the Treasury Department to develop rules for agentic AI in financial services. More details here.
WHAT THIS MEANS, FROM STEFANIE JACKMAN OF TROUTMAN PEPPER LOCKE: The discussion draft of the AI AGENT Act proposes a foundational framework for regulating consumer AI agents, focusing on enabling interoperability across platforms while mitigating discrimination and provider abuse. A cohesive federal framework is necessary to replace a fragmented patchwork of state regulations and establish consistent baseline protections that safeguard user data nationwide. Specific to collectors and creditors, the draft legislation introduces pivotal guidelines for managing automated interactions and verifying authorized financial transactions, including proposing clear legal frameworks for how custodial AI agents can interact with debt management systems, communicate payment choices, and manage account settings on financial platforms.
However, significant gaps remain regarding liability when probabilistic systems act unpredictably, hallucinate, or exceed authorization. Furthermore, the draft fails to address how to counter prompt injection attacks, how to police malicious sellers who manipulate agent behavior, and how agent-mediated commerce will disrupt existing online business models. In short, there is much more work to be done if Congress is going to establish an effective federal framework for business.
Judge Denies Motion to Compel Arbitration in FCRA Identity Theft Case
A District Court judge in Kansas has denied a defendant’s motion to compel arbitration in a Fair Credit Reporting Act case, ruling the defendant failed to show that the plaintiff was the same person who signed the underlying auto financing contract under a different name. More details here.
WHAT THIS MEANS, FROM AKEELA WHITE OF HINSHAW & CULBERTSON: This decision is a reminder that arbitration agreements are only as useful as the evidence connecting them to the plaintiff. When a consumer alleges identity theft and claims they never signed the underlying contract, the party seeking to compel arbitration must put forward some evidence (beyond the contract signatures themselves) that the plaintiff is the person who entered into the agreement. The court denied the motion despite the plaintiff’s failure to respond, underscoring that the initial burden falls squarely on the movant. This is similar to the approach taken in Garry v. Credit Acceptance Corp., No. 19-CV-12386 (E.D. Mich. Apr. 15, 2020), where a Michigan District court denied a motion to compel arbitration in an FCRA identity theft case because of genuine factual questions about whether the plaintiff entered the contract. Auto lenders and other furnishers that rely on arbitration agreements tied to accounts later disputed as fraudulent should ensure they can independently establish the identity of the person who signed the contract before moving to compel, or risk having the motion denied on threshold grounds.
Judge Rules CRAs Are Not Debt Collectors in Dismissing FDCPA, FCRA Suit
A District Court judge in Louisiana has granted motions to dismiss filed by three credit reporting agencies that were accused of violating the Fair Debt Collection Practices Act and the Fair Credit Reporting Act, ruling that the agencies are not debt collectors and that the plaintiff’s complaint offered nothing more than recitations of the statutes she claimed were violated. More details here.
WHAT THIS MEANS, FROM LORAINE LYONS OF MARTIN GOLDEN LYONS WATTS MORGAN: The Coleman decision reaffirms that consumer reporting agencies are neither “debt collectors” under the FDCPA nor “furnishers of information” under FCRA § 1681s-2(b). The court dismissed those claims with prejudice. The remaining FCRA claim under § 1681i(a), which applies to CRAs, was dismissed without prejudice. The Fifth Circuit’s insistence on pleaded, concrete inaccuracy and reinvestigation defects for § 1681i(a) claims means bare statutory recitations will not survive a motion to dismiss, as Reyes v. Equifax, 140 F.4th 279 (5th Cir. 2025), makes clear. Even though the court effectively gave Coleman a checklist on how to cure the § 1681i(a) deficiencies, she still needs specific facts to back up her claim. The decision also illustrates a court’s strategic use of 12(b)(6) over Article III standing, choosing the path that produced a with-prejudice disposition on the defective claims rather than a blanket jurisdictional dismissal that would have been entirely without prejudice.
Judge Dismisses FDCPA Class Action Over Collection Text Messages
A District Court judge in Minnesota has granted a defendant’s motion to dismiss a Fair Debt Collection Practices Act lawsuit after the plaintiff abandoned the claims in his complaint in favor of a third-party disclosure theory that the complaint never actually alleged. More details here.
WHAT THIS MEANS, FROM BRIT SUTTELL OF BARRON & NEWBURGER: The District of Minnesota dismissed a putative FDCPA class action alleging that a debt collector violated §§ 1692c(a), 1692d, and 1692e by sending unsolicited debt collection text messages to the Plaintiff. The Plaintiff argued that the mere transmission of collection texts constituted communications at an inconvenient place, harassing conduct, and deceptive practices. In opposing the motion to dismiss, the Plaintiff abandoned all theories, except the § 1692c(b) claim regarding impermissible third-party communication or disclosure. In granting the Motion, the court held there was no allegations that another person actually “saw—or even could see—any of the text messages. . .” The Plaintiff’s failure to include these critical facts doomed his Complaint.
Companies using text messaging should continue to maintain procedures for honoring consumer requests to “stop” or opt-out of texting, avoid excessive message frequency, and ensure text content is accurate and non-deceptive.
Judge Denies MTD Where CRA Used the Same Furnisher to ‘Verify’ Its Own Data
A District Court judge in Massachusetts has denied a defendant’s motion to dismiss a Fair Credit Reporting Act lawsuit accusing a consumer reporting agency of falsely reporting that the plaintiff had sought treatment for alcohol abuse. More details here.
WHAT THIS MEANS, FROM SARAH DOERR OF COZEN O’CONNOR: The Gonzalez opinion is a timely reminder that reinvestigations of disputed consumer reports do not lend themselves to one-size-fits-all approach. Particularly where a consumer’s dispute includes a detailed account of the error and/or allegations of identity theft, CRAs are well-advised to maintain an escalated reinvestigation channel to ensure that incorrect information is not recycled and reverified from the same furnisher. Even with such an approach, claims may survive motions to dismiss because, as the Gonzalez Court noted, reasonableness is a question for a jury.
Judge Rules Time-Barred Collection Suit Violated FDCPA, Rejects Related Licensing Claim
A District Court judge in New Jersey has partly sided with a consumer in a Fair Debt Collection Practices Act lawsuit, ruling that a debt buyer and its law firm violated the Act by suing to collect a time-barred debt, while rejecting the consumer’s separate claim that the debt buyer’s lack of a state lending license also violated the statute. More details here.
WHAT THIS MEANS, FROM JAMES K. SCHULTZ OF SESSIONS, ISRAEL & SHARTLE: The Melly decision provides a great example of the near-impossible place that the courts (and some state laws) have imposed on debt collectors when it comes to collecting time barred debt. In this case, there was a legitimate dispute as to which state law applied for calculating the statute of limitation period. The debt collector, using its best, and reasonable efforts, concluded that the limitation period was controlled by a choice of law provision in the underlying promissory note in which the parties selected North Carolina law as the applicable law. Many third-year law students struggle with choice-of-law questions and frequently get it wrong. But as this court finds, debt collectors are held to a higher standard than law students, and if they end up reaching the wrong conclusion, it is not a failing grade but an FDCPA violation that results. In this case, the court found that the promissory note was governed not by North Carolina, but New Jersey law, making the collection lawsuit untimely and therefore a violation of the FDCPA. If there is a silver lining, the court did agree with defendant that consumers cannot brings claims for a debt buyer’s failure to be licensed under New Jersey’s consumer finance law. But at the end of the day, a reminder that perfection is the standard for debt collectors calculating the applicable limitation period is the lesson.
State Appeals Court Won’t Undo Judgment for Consumer Who Argued, But Never Proved, Lack of Notice
A state Court of Appeals in Texas has affirmed a lower court’s refusal to set aside a summary judgment in a credit card collection case, ruling the plaintiff never offered sworn evidence to support his claim that he was not notified of the hearing that produced the judgment. More details here.
WHAT THIS MEANS, FROM LORI QUINN OF MESSER STRICKLER BURNETTE: Plaintiff alleged that he ever received notice of a summary judgment hearing or subsequent filings. The only evidence provided was his unsworn statements and arguments. The Court held that this was insufficient, that certificates of service created a presumption of proper mail service under Texas rules that permit service by regular mail – this constituted prima facie evidence of service. The Appellate Court upheld the original judgment obtained by Discovery Bank because Plaintiff did not meet his burden for a bill of review.
What is learned from this decision – Despite plaintiff being pro se, the same standards must be met to obtain a bill of review – arguments are not enough, certificates of service without counter evidence are weighty and bills of review are difficult to win.
Judge Awards Reduced Attorney Fees in FCRA Case
A District Court judge in Maryland has granted in part and denied in part a plaintiff’s motion for attorneys’ fees in a Fair Credit Reporting Act case, awarding $24,080 in fees and $252.50 in costs after cutting the request for work performed after the plaintiff accepted an offer of judgment. More details here.
WHAT THIS MEANS, FROM JASON ESTEVES OF HUDSON COOK: This case shows that when it comes to Rule 68 offers of judgment, timing and words matter. An early offer can substantially reduce a defendant’s exposure to attorney’s fees, particularly if it clearly limits recoverable fees to those incurred before the offer is made. Here, the court enforced the plain language of the offer and declined to award more than $8,200 in fees incurred after the date of the offer. The decision also demonstrates that courts will closely scrutinize fee petitions and reduce requests that exceed the parties’ agreement or include otherwise unrecoverable charges. Companies defending FCRA claims should consider whether an early, carefully drafted Rule 68 offer can be an effective tool for controlling litigation costs while bringing greater certainty to the settlement process.
Furnishing Late-Rent Data Doesn’t Make Defendant a Debt Collector, Judge Rules
A District Court judge in New York has granted summary judgment to a defendant in a Fair Debt Collection Practices Act lawsuit, ruling that a company that furnishes tenants’ rental payment data to credit reporting agencies is not a debt collector subject to the statute, even if its actions “may scare tenants into paying on time or indirectly punish tenants for paying late.” More details here.
WHAT THIS MEANS, FROM DALE GOLDEN OF MARTIN LYONS GOLDEN WATTS MORGAN: “Definitions belong to the definer, not the defined.” That quote comes from Toni Morrison’s novel “Beloved.” But it’s also popped up in cases involving statutory definitions.
In Silver v Top Line Reporting, the consumer alleged the defendant violated the FDCPA by falsely reporting to one or more CRA that she was 60 days late on paying her rent. The court denied Top Line’s motion to dismiss arguing the plaintiff failed to allege facts sufficient to show it met the FDCPA’s definition of “debt collector.” It then filed a motion for summary judgment raising the same argument.
In its summary judgment order, the court rightly recognized that to meet the statutory definition of “debt collector,” the evidence needed to show that the defendant’s “principle purpose” was collecting consumer debts or that it “regularly collects” consumer debts.
While acknowledging that the defendant was “able to get business with landlords only because tenants sometimes don’t pay their rents,” the court concluded that fact was insufficient to meet the statutory definition of “debt collector.” In granting summary judgment, the court concluded that “there is no evidence from which a reasonable could find that Top Line’s ‘principal purpose” is to collect debts, or that Top Line ‘regularly collects’ debts.”
While acknowledging that credit reporting “may scare some tenants into paying on time,” that fact doesn’t alter the statutory definition. Accepting the plaintiff’s argument would essentially render all “furnishers” of credit information “debt collectors.” That was bridge too far for the court. And while the court didn’t cite Toni Morrison’s classic line, it’s reasoning echoes her statement.
The take away here may be as simple as, the line between “creative” arguments and “silly” arguments can sometimes be difficult to discern. But this wasn’t one of those situations.
Senate Dems Press CFPB’s Vought to Explain Record Deletions
Four Senate Democrats are demanding that Consumer Financial Protection Bureau Acting Director Russell Vought explain why the bureau scrubbed roughly 15 years of public content from its website, escalating a fight that touches directly on the records used by companies across the credit and collection industry to track their regulator. More details here.
WHAT THIS MEANS, FROM ROSHNI PATEL OF TROUTMAN PEPPER LOCKE: Four Senate Democrats (Ranking Member Elizabeth Warren [D-Mass.], Sen. Raphael Warnock [D-Ga.], Sen. Andy Kim [D-N.J.)] and Sen. Lisa Blunt Rochester [D-Del.]) sent a letter to Consumer Financial Protection Bureau Acting Director Russell Vought demanding answers about the CFPB’s removal of roughly 15 years of public content from its website, including press releases, consumer advisories, settlement notices, and all 35 Supervisory Highlights reports. The senators raised concern that the deleted material may have been destroyed internally in violation of the Federal Records Act and a 2025 order barring the CFPB from “destroying records and deleting data,” issued by U.S. District Judge Amy Berman Jackson in broader litigation over the Trump administration’s efforts to dismantle the agency. The letter also tied the purge to the CFPB’s broader retreat under Vought, who has dismissed or terminated at least 42 enforcement actions against major companies. The letter posed 15 detailed questions covering the decision-making process behind the deletions, whether CFPB officials coordinated with affected companies before removing settlement and advisory pages, and whether the CFPB plans to restore the deleted content or publish new consumer advisories going forward. The senators set a July 2, 2026 response deadline, which has now passed without any public response from the CFPB, leaving unanswered whether the deletions were part of a deliberate effort to obscure the agency’s prior enforcement record.
Frost Echols reputation has been built on aggressively protecting the rights of businesses throughout our local jurisdictions. Founding partners, Mike Frost and Chad Echols, developed a deep understanding of regulatory compliance, commercial litigation and business operations through years of advising executives in the collection industry. We are committed to a strategic, economic, and aggressive approach to your legal representation.
