ARM-U

COMPLIANCE • OPERATIONS • TRAINING

COMPLIANCE: NOT A BOOK ON A SHELF, BUT A STORY

Presented by:

insideARM.com & Anthony DiResta

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Published by insideARM.com

an imprint of the iA Institute

6010 Executive Blvd, Suite 802, Rockville, Maryland, 20850

editor@insideARM.com | 240.499.3834 | www.insideARM.com

Copyright © 2014

All rights reserved

Printed in the United States of America

14 November 2014

This publication is sold subject to the condition that it shall not, by way of trade or otherwise, be lent, resold, hired out, or otherwise circulated without the publisher’s prior consent in any form of binding or cover other than that in which it is published and without a similar condition including this condition being imposed on the subsequent purchaser.

The scanning, uploading, and distribution of this publication via the Internet or via any other means without the permission of the publisher is illegal and punishable by law. Please purchase only authorized editions. insideARM.com Presents: ARM-U Page | 1 © 2014 insideARM.com Anthony DiResta Keynote

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Legal Disclaimer

This information contained in this report is not intended to be legal advice and may not be used as legal advice. Legal advice must be tailored to the specific circumstances of each case. Every effort has been made to assure this information is up-to-date. It is not intended to be a full and exhaustive explanation of the law in any area, however, nor should it be used to replace the advice of your own legal counsel.

insideARM.com Presents: ARM-U Page | 2 © 2014 insideARM.com Anthony DiResta Keynote

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Contents

Introduction ....................................................................................................... 4

Keynote .............................................................................................................. 6

CFPB Examination Questions ........................................................................... 20

“My First CFPB Examination” ........................................................................... 21

How Soon After a Production Should You Reach Out to the CFPB? .................. 28

Agency Monitoring: What Should Agencies Focus On? .................................... 29

This transcript is taken from insideARM.com’s ARM-U conference, held on 14-15 October 2014 in Washington D.C.

To view video of this presentation, please click this link: VIEW VIDEO.

insideARM.com Presents: ARM-U Page | 3 © 2014 insideARM.com Anthony DiResta Keynote

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ARM-U Keynote: Tony DiResta 14 October 2014

Introduction Mike Bevel Good morning, and welcome and thanks to all of you for helping us inaugurate the first semester of ARM-U. I’m pleased so many of you were interested and able to take advantage of this educational networking opportunity. For those of you who don’t know me or who may not recognize my voice from all the webinars we do, I am Mike Bevel, an editor here at insideARM. I am joined today by Stephanie Eidelman, our President and publisher; Patrick Lunsford, who stands behind you. He is another editor at insideARM; and Lindsay is at the front desk, who probably helped you get your name badge. We had some generous help from sponsors to put this all together, and we’d like to acknowledge them now, and I’m going to do so by taking off my glasses. You don’t know who I am right now, do you? Because I just changed identities. Billing Tree, who is also sponsoring today’s afternoon break Columbia Ultimate, who was kind enough to lend us Lacy Jensen for

tomorrow’s CMS panel Lexus Nexus is sponsor of this evening’s happy hour NARCA, who is generously underwriting the recording of these sessions to

be available to you after the fact. Neustar, who is also sponsoring our first break of the day Ontario Systems, who is granting us the permission to use Rozanne

Anderson TECH LOCK is loaning us Todd Langusch.

They’re not only generous, but they have great insight, and they are here to add value as participants, in addition to their support.

insideARM.com Presents: ARM-U Page | 4 © 2014 insideARM.com Anthony DiResta Keynote

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So you’re all in this together, this being the debt industry, whether you’re a collection agency, a collection attorney or a debt buyer, a vendor or a regulator. Our goal for this two day event is to get everyone on the same page as far as compliance operations, challenges and best practices are concerned. The great thing about this forum is that it is small. Someone used the word intimate, but it’s too early in the morning and I wouldn’t let her do it. We are all here to learn from each other, so I expect everyone to feel empowered to ask any questions if they want to at any point. We really want to carry the through line of this collegiate idea through, so raise your hand to ask a question at any point. We’re packed pretty full of presentations, so I’m going to get our keynote kicked right off. Compliance should not be just a book on your shelf; it should describe your corporate philosophy. Anthony DiResta has some insight into how to share your compliance story. Tony’s practice focuses on governmental investigations, commercial litigation and business counseling that involves consumer protection issues, trade regulations, and unfair competition. Tony is a former Director of the FTC Southeast Regional Office and has an AV rating by Martindale Hubble. He is widely published in the areas of commercial litigation, FTC and CFPB practice, governmental investigations, consumer protection and antitrust, with many of his articles being cited by the courts and law reviews. In fact, one of his articles was cited with approval by the United State Supreme Court in a leading antitrust decision. He was elected to the membership of the American Law Institute in 1994, has been involved in the leadership of the ABA since 1992, and frequently serves as an expert on professional panels. I’m going to hand things over to Tony.

insideARM.com Presents: ARM-U Page | 5 © 2014 insideARM.com Anthony DiResta Keynote

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