The Holy Grail of First Party Outsourcing: The FTC DeMayo Opinion Letter
The historical FTC guidelines for first-party outsourcing, recent developments for first-party collections with the FTC and the CFPB. First-party outsourcing is a significant component of the ARM industry. In all of its various shapes and sizes, some estimate it may be as much as 30% of the industry's revenue. Yet the practice is surrounded by undocumented industry pattern and procedure, mystery, speculation, and a single FTC Opinion from May 1, 2000: the infamous deMayo Opinion Letter.
Below is a photo of attorney John Rossman (seated far right) participating in a panel discussion at the October 2015 InsideARM First Party Outsourcing Summit. Also pictured is Tom Pahl (seated next to Mr. Rossman), Managing Regulatory Counsel, Office of Regulations, at the Consumer Financial Protection Bureau; and Christopher Koegel (seated far left), Assistant Director, Division of Financial Practices, at the Federal Trade Commission. Photo reproduced with permission from InsideARM©.
