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All members of the Commercial Collection AgencyAssociation of the Commercial Law League of America shallconduct their business in accord with this Code of Ethics,and their membership in the Association shall be conditionedon their continuing conduct in accord with this Code of Ethics.

Each member shall:(1) In general conduct:

(a) Maintain a high standard of fairness, honesty andcourtesy in the conduct of business and avoid anyactivity which would bring reproach on this profes-sion or this Association. *

(b) Provide efficient collection service in the territoryserved; protect the interest of creditors; and giveprompt and diligent attention to all claims receivedfor collection.

(c) Operate under a name which does not imply orsuggest that the agency is a branch of or associat-ed with any department of the federal government,a local government or any court. The letterhead ofthe agency should clearly indicate that the agencyis in the collection business.

(d) Make certain that all personnel are familiar with thisCode of Ethics and that they fully comply with it.

(e) Avoid the unauthorized practice of law by comply-ing fully with the Declaration of Fair Practices ofCollection Agencies approved by the Board ofGovernors of the Commercial Law League,appended hereto as Appendix 1.

(2) In relations with creditors:(a) Comply with instructions given by creditors in the

processing of a claim promptly or give reasons fornot doing so and ask for further instructions.

(b) Maintain a trust account separate and apart fromthe memberʼs operating account which should betitled as “Client” or “Customer” “Trust Account” andinto which all debtor payments and attorney remit-tances shall be deposited by the agency. All remit-tances to creditors should be from the trustaccount only.

(c) Identify clearly and accurately all charges to thecreditor. Suit requirements requested by an attor-ney should be communicated to the creditor ascommunicated by the attorney. Service and or

administrative charges by the member are sepa-rate and apart from commissions and fees earnedby a receiving attorney. Service and or administra-tive charges must be clearly identified and shownseparately from court costs and suit fees requestedby an attorney. Suit requirements received from acreditor should be sent to the attorney within sevenworking days of their receipt. A full accounting of anywithdrawal fees charged must be provided to thecreditor at the time withdrawal fees are assessed.

(d) Remit to creditors as specified by the debtor wherea number of claims against the same debtor arebeing collected.

(e) Within 30 days after the close of a calendar monthduring which monies are collected for a creditor,account in writing and remit to that creditor allmonies collected and received during the monthless commissions and service charges. If theamount due the creditor is less than $100., remit-tance may be deferred for an additional 30 days,provided such deferral of remittance is approvedby the creditor.

(f) Not permit any creditor to use any forms, letters orother material bearing the memberʼs name as apreliminary service for which no charge is made inthe collection of a debt (free demand service),unless such form, letter or other collection materialstates that the debt will be placed with the memberfor collection if it is not paid within a specified peri-od of time after the date thereon.

(g) Advance court costs and suit fees on behalf of acreditor only at the creditorʼs specific request, andbill the creditor for such costs and fees at the sametime they are forwarded to an attorney.

(h) Display the Official Association Logo on the letter-head of all correspondence sent to creditors andwhere other locations are listed, the identificationof Branch (full service), Sales or Collection officemust be shown.

(i) Marketing of services should be professional andcourteous. No activities should be engaged in thatwill bring reproach to this industry or Association.

(3) In relations with debtors:(a) Avoid deceptive practices, statements or materials

which would cause debtors to believe they are

Commercial Collection Agency Associationof the

Commercial Law League of America®

CODE OF ETHICSApproved by the Association - July 4, 1977

Amended July, 1991, July, 1998. May, 1999, April 2002, April 2003 & February 2004.

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dealing with someone other than the member. Amember when contacting a debtor shall notengage in any subterfuge such as stating they area private investigator conducting an investigationof the debtor.

(b) Show due consideration for debtorʼs problems anddeal with them according to the merits of their indi-vidual cases.

(c) In the event a claim is disputed, obtain from thecreditor and provide the debtor with such documentsor information necessary to validate the debt.

(d) Avoid any harassment by telephone or personalcalls.

(e) If the debtor states that he is represented by anattorney and identifies him or if the agency is con-tacted by debtorʼs attorney, then the agency shalldeal directly with the attorney. However, should theattorney fail to respond to calls or letters from theagency, then the agency may continue to contactand negotiate with the debtor.

(f) Not represent that, if payment is not received by aspecific date, a claim will be placed with an attor-ney or litigation will be commenced, unless:

(i) the representation indicates that such actionhas been authorized by the creditor, and

(ii) such representation is true(g) Threaten to damage a debtorʼs credit reputation if

they do not pay or fail to cooperate by notifyingother vendors and financial institutions that dealwith the debtor.

(4) In relations with attorneys, comply with the OperativeGuides adopted by the Commercial Law League ofAmerica, appended hereto as Appendix 2, as they mayfrom time to time be amended, in the absence of spe-cific agreement to the contrary.

* The following Interpretations have been adopted underthe Code:

It shall be considered contrary to high standards of “cour-tesy in the conduct of business” within the meaning ofSection 1(a) of the Code of Ethics for an officer or partner ofa commercial collection agency to initiate communicationswith an employee of another agency for the purpose ofemploying that employee without first advising an officer orpartner of the other agency; but this does not apply where anemployee of an agency responds to a public advertisementor initiates discussion of employment with another agency.(Adopted by Association November 22, 1977)

It shall be deemed contrary to “high standards of fairness,honesty” in the conduct of business under Section 1(a) of theCode of Ethics for a member to give a credit manager anyinducement to place accounts with the member, other thannormal business entertainment or nominal gifts. (Adopted byAssociation July 13, 1981)

It shall be considered contrary to “high standards of fair-ness in the conduct of business” within the meaning ofSection 1(e) of the Code of Ethics for a member to requestthat a receiving attorney write a demand letter to a debtor fora stipulated fee, where the claim had not been forwarded tothe attorney on behalf of the creditor. (Adopted byAssociation July 25, 1998)

RESOLUTION APPROVING CERTIFICATESOF COMPLIANCE

Commercial Law League of America®

(As amended February 19, 2004)

RESOLVED, that the Commercial Law League of Americadoes hereby establish a Certificate of Compliance to beissued to commercial collection agencies, mercantile agen-cies and credit insurance companies (hereinafter collectivelyreferred to as “agencies”).

(1) Qualifications Necessary for a Certificate ofCompliance. Any agency shall be eligible to receive aCertificate of Compliance if it:(a) Has a manager, owner, officer or partner who is a

member of the Commercial Law League ofAmerica.

(b) Has been actively engaged as a commercial col-lection agency (i.e. engaged primarily in the col-lection of commercial accounts for creditors, not

only by letters, but also by telephone and/or per-sonal visits to debtors) for at least four (4) yearsprior to the date of application. The definition of“actively engaged,” means that the applicant hasdemonstrated continued and uninterrupted busi-ness operations for a period of four years from thedate of its inception and one or more of the appli-cantʼs principals have also been actively engagedas an owner of a commercial collection agency fora period of at least four years.

(c) Does not operate as a house agency or engage inthe practice of law.

(d) Must have a minimum of the equivalent of five fulltime employees including the agencyʼs principal(s).

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(e) Maintains separate bank accounts for all funds col-lected for its customers and does not comminglemoney collected for customers with the agencyʼsfunds or use money paid in any customerʼs namesin the conduct of agencyʼs business.

(f) Maintains accounting procedures and records inaccordance with generally accepted principles ofsound accounting practice.

(g) Complies with the Code of Ethics of theCommercial Collection Agency Association of theCommercial Law League of America, including theDeclaration of Fair Practices of CollectionAgencies as approved by the Board of Governorsof the CLLA.

(h) Files with the Commercial Collection AgencyAssociation within thirty (30) days after notice ofthe approval by the Certificate of ComplianceCommittee of its application for a Certificate ofCompliance, a single bond in the sum of $50,000,and an excess surety coverage bond in the sum of$250,000 in a form approved by the Committee foruse of the agencyʼs customers.

Such bond shall provide that coverage is providedto any of the agencyʼs customers who may bedamaged by wrongful conversion of any trust fundsheld by such agency and shall also provide thatnotice of cancellation of the bond must be given bythe surety company to the Commercial AgencyAssociation of the Commercial Law League. Suchbond shall be executed by such applicant as prin-cipal and surety companies approved by theCommercial Collection Agency Association of theCommercial Law League of America.

(i) No Certificate of Compliance shall be issued to anyapplicant until such time as a bond is in place anda representative of the applicant is admitted tomembership in the Commercial Collection AgencyAssociation.

(j) Encourages adherence to the practices of the tri-adic system and forwards wherever possibleaccounts to CLLA attorneys utilizing the services ofLaw Lists whose principals are members of theCLLA.

(2) Oversight of Certification Program(a) Certificate of Compliance Committee. The respon-

sibility of this Committee is to review applicationsfor membership and to determine if the applicantmeets the requirements for certification and toreview and decide on all grievances and com-plaints filed against a certificate holder.

The committee shall be empowered to determinethe form of application to be required and to makesuch investigation, as it may deem necessary toinsure compliance with Article 1. All matters tocome before the Committee shall be strictly confi-dential and members of the Committee and otherparticipants in the process shall treat it as such.

The Committee will consist of five members select-ed from the ranks of past chairs of the CCAA bythe CCAA Chair and ratified by the CCAA Council.

If there are not sufficient numbers of past CCAAChairs to fill any open positions, members will beselected from the ranks of CCAA members whohave served on the CLLA Board of Governors. Ifthe ranks of past chairs of CCAA or CCAA mem-bers who have served on the CLLA Board ofGovernors does not provide a sufficient number ofindividuals who are able to serve on thisCommittee the CCAA Chair may select Committeemembers from the ranks of the CCAA generalmembership.

In addition the Committee will also have as a mem-ber a CLLA attorney. The CLLA attorney memberof this Committee will be selected by the CLLApresident from a list of three CLLA attorneys pro-vided by the CCAA Council. League Counsel willbe a resource to this Committee and may be calledupon from time-to-time to advise on legal issuesregarding the Certificate of Compliance programand other matters affecting the CCAA and theCLLA. The CCAA Executive Director will serve asSecretary to this Committee and is not a votingmember of this Committee.

All grievance/complaints must be acted upon with-in one-hundred-twenty (120) days of receipt. TheCommittee shall be empowered to determine theform the presentation of the grievance or complaintshould take regarding statement of the grievance/complaint, supporting arguments and evidence forthe grievance/complaint and length of the grievance/complaint.

The Committee will render its decision to theCCAA Council who will, within fifteen days of beingnotified of the Committeeʼs decision, either ratify orreject the Committeeʼs decision. The Council mayalso elect to return the decision to the Committeefor further consideration.

The Committee with the approval of the CCAACouncil shall have the power to employ counseland incur necessary expense for conducting aninvestigation of the matter before it. All matters tocome before the Committee shall be strictly confi-dential and all parties, members of the Committeeor other participants in the process shall treat it assuch. The Committee shall file its report of expens-es incurred as a part of its Committeeʼs report, andmay make recommendations to assess anyexpenses incurred against the complainant, if thatcomplainant is another agency, should theCommittee deem that the complaint is frivolous innature and has not been substantiated by the evi-dence the complainant has presented.

If any of the parties take issue with the decision ofthis Committee ratified by the CCAA Councilregarding a grievance/complaint, they may appealas outlined in paragraph 4 (d) of this Resolution. Ifan applicant takes issue with the decision of thisCommittee regarding their application, they mayappeal as outlined in paragraph 3 (c) of thisResolution.

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(b) Standards Committee. This Committeeʼs respon-sibility is to review and evaluate the standards orrequirements of the certification program as towhether they are responsive to the needs of thebusiness credit community. The Committee willnot be a standing Committee, but will meet everyfour years beginning April 2004. The CCAACouncil may elect to accelerate or delay the reac-tivation of this Committee. The Committee willremain in existence for a one year period in whichit will review the existing standards for awarding aCertificate of Compliance and make a report to theCCAA Council as to its recommendations. TheCCAA Council may extend the duration of thisCommittee. In performing their duties theStandards Committee may make recommenda-tions to reaffirm the current standards, proposechanges to the certification program and or pro-vide guidance on the interpretation of standards tothe CCAA Council for their review and approvaland subject to final approval by the CLLA Board ofGovernors. The Committee will sunset within 90days of rendering its report to the CCAA Council,unless its duration is extended by the CCAACouncil.

The Committeeʼs membership will consist of threeCCAA members of the Certificate of ComplianceCommittee selected by the CCAA Chair and rati-fied by the CCAA Council. It will also consist of theCLLA attorney member of the Certificate ofCompliance Committee. The CCAA ExecutiveDirector will serve as Secretary to this Committeeand will not be a voting member of this Committee.

An Advisory Panel consisting of two representa-tives from the business credit community and a lawlist representative will be selected by the CCAAChair and ratified by the CCAA Council. TheAdvisory Panel will provide to the StandardsCommittee the perspectives of the business creditcommunity and other constituencies of the triadicsystem regarding the commercial collection indus-try. Members of the advisory panel will participatein the deliberations of the Committee, but will haveno vote regarding the recommendations theCommittee may propose. The term of the AdvisoryPanel will coincide with that of the StandardsCommittee.

(3) Application Procedure.(a) Upon the filing of an application with the Executive

Director of the Association, in the prescribed formand the completion of investigation as the commit-tee shall deem necessary or proper to insure com-pliance with Article 1, the Certificate ofCompliance Committee shall act upon the applica-tion within six (6) months of filing. An applicationfee will be assessed on all applications to defraythe cost of conducting background checks on theapplicant, its principals and officers. The applicantmay be asked to pay the travel expense of theExecutive Director or a member of his/her staffnecessary to conduct a visit to the applicantʼsplace or places of business.

(b) If the committee shall find the applicant qualified, itshall notify the Executive Director of theAssociation that the applicant has met the require-ments for membership. Upon receipt of verificationthat the conditions of Article (1) paragraph (h) havebeen met, the Executive Director shall cause aCertificate of Compliance to be issued and notifythe Executive Vice President of the CLLA that anew Certificate of Compliance has been issued.

(c) If the Committee does not approve the application,it shall notify the agency in writing of its findingsand the reasons therefor. The member of theLeague representing the agency shall have theright to request an appeal for arbitration on behalfof the agency within thirty (30) days after notifica-tion of such findings, either to the AmericanArbitration Association in Chicago, Illinois or anyother city the parties can agree upon, or alterna-tively to a three member panel of the CLLAArbitration and Grievance Committee. The threemembers of the panel must be approved by theparties. The decision of the American ArbitrationAssociation or of the Arbitration and GrievanceCommittee panel may be appealed to the Board ofGovernors.

The Board of Governors and the CommercialCollection Agency Association Council shall jointlyselect, predicated upon a selection procedureagreed to by the Board of Governors and theCommercial Collection Agency AssociationCouncil, five (5) individuals from the Arbitration andGrievance Committee to serve as arbiters onappeals from the Certificate of Compliance com-mittee. The parties to such an appeal shall selectthree of these five arbiters to hear and decide onthe decision being appealed.

(d) If an agencyʼs application has not been approved,the agency may reapply for a Certificate ofCompliance after it shall have taken the necessarycorrective action to remove the cause of the appli-cationʼs disapproval.

(4) Continuation.(a) A certificate of Compliance shall be issued for a

period of one (1) year. Upon application, it may berenewed for a period of one year if (i) the applicantcontinues to meet the qualifications imposed upona new applicant for a Certificate and (ii) the appli-cant shall have filed with the Executive Director ofthe Commercial Collection Agency Associationwithin 90 days following the close of its mostrecent fiscal year, and within 90 days following thedate six months after the close of such fiscal year,a Trust Account Verification Report prescribed bythe Commercial Collection Agency Association.

(b) When a change in ownership of a member agencytakes place through a merger or other businesstransaction, the holder of a Certificate ofCompliance must submit an application to theExecutive Director of the Association within thirty(30) days after the effective date of the transactionthat sets forth the changes that have occurred andprovide documentation that the requirements of

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membership are met by the successor or survivingentity. The applicant shall have all rights andresponsibilities of a holder of a Certificate ofCompliance pending review of the application anduntil a determination is made concerning the appli-cant’s continued entitlement to a Certificate ofCompliance.

(c) The qualifications of a holder of a Certificate ofCompliance may be subject to review upon writtencomplaint of any person or written request of twomembers of the Committee on Certificates ofCompliance. Such complaint or request shall con-tain specifications detailing the reason for review.Upon receipt of such complaint or request, theExecutive Director verifies with the complainantthat he or she wishes to go forward with the matterand initiate a formal complaint process. TheComplainant, if another agency, is advised at thistime that it may be assessed the cost of investigat-ing its complaint. When submitting its complaintthe Complainant, if another agency, will be askedto acknowledge that it will promptly remit anyassessment the Committee may render. Shouldthe Complainant wish only to alert the ExecutiveDirector of a situation but not pursue a formal com-plaint, then the Executive Director correspondswith the agency member requesting commentsregarding the complaint. In so doing the ExecutiveDirector does not disclose the name of the com-plainant to the agency or identify the file or files onwhich the complaint is based. The agency’sresponse is then transmitted to the Complainantand the matter is closed.

If the Executive Director, in the course of handlingthe foregoing informal complaint, discovers that theagency is in violation of the requirements of thisResolution or of the Association’s Code of Ethics,it shall be required that the Executive Director sonotify the Certificate of Compliance Committee fol-lowing, the procedure as if a formal complaint hasbeen filed.

In the formal complaint process, the ExecutiveDirector writes the Chair of the Committee onCertificates of Compliance with copies to otherCommittee members outlining the facts of the com-plaint. In so doing, the name of the complainant,the agency and the file or files that are the basis forthe complaint are not revealed to the CommitteeChair or its members. In all further correspon-dence or discussion, the names of the parties ininterest are deleted. The Committee deals onlywith a set of facts or reports. In this initial corre-spondence to the Committee, they are notified ofthe request for review of the holder’s Certificate. Ifa majority of the committee so authorizes in writ-ing, the Executive Director notifies the agency inwriting of the determination and issues a requestfor review. Such a request for review shall, if theExecutive Director so determines, include arequest for access to and review of the Certificateholder’s books, records and processes, and per-mission to contact customers, attorneys and other

parties deemed necessary regarding the filesfound during the review process that raise ques-tions concerning the Certificate holder’s compli-ance. Should the Certificate holder not allow or failto respond within ten (10) days, to a request for areview, the Executive Director shall so report to theCommittee. Such failure to comply with therequest for review is grounds for immediate dis-qualification of the agency, subject to appeal.

An investigation of the agency is then conductedby the Executive Director. All contact with theagency shall be by the Executive Director.Representatives of the agency are not required toappear before the committee, but are free to do soif they request this.

When the committee is satisfied that all the rele-vant data has been compiled, it makes its determi-nation as to the agency’s qualifications. If the com-mittee finds the agency has violated the Code ofEthics, it may elect to censure, either as a privateor public censure, suspend an agency’sAssociation membership and Certificate ofCompliance or find an agency disqualified andrevoke their Association membership andCertificate of Compliance. All parties to the com-plaint are then notified of the committee’s determi-nation by the Executive Director.

If the agency is found disqualified, the ExecutiveDirector must notify the Surety Company at theearliest time specified in the policy. Notice to thesurety states the finding of disqualification and pro-vides the surety with information on the appealprocess. Should the surety decide to cancel thebond, the Executive Director upon such notificationwill notify the agency that their bond has been can-celled and this will result in immediate revocationof the agency’s Certificate of Compliance andmembership in the Association.

(d) If the complainant or the agency is dissatisfied withthe decision of the Committee, either may appealfor arbitration within thirty (30) days after notifica-tion of such findings to either the AmericanArbitration Association in Chicago, Illinois or anyother city the parties can agree upon, or alterna-tively, to a three member panel of the CLLAArbitration and Grievance Committee. The threemembers of the panel shall be selected in accor-dance with the procedures described in paragraph3 (c) above and must be approved by the parties.The decision of the American ArbitrationAssociation or of the Arbitration and GrievanceCommittee panel may be appealed to the Board ofGovernors.

In order to initiate any appeal process, the com-plainant or the agency must notify the ExecutiveDirector of its intention to appeal within ten (10)days of being notified of the Committee’s decision.Failure to do so shall negate any right to appeal.

The Certificate of any agency found to be disqual-ified shall be revoked either at the expiration of the

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time for filing an intent to appeal or appeal, if nonehas been filed, or, if an appeal has been filed, atthe time of notice of an affirming decision uponappeal, whichever comes first.

An agency whose Certificate has been revokedcannot apply for another Certificate until a waitingperiod determined by the Certificate of ComplianceCommittee at the time of revocation has expired.Such waiting period, determined at the discretionof the Certificate of Compliance Committee, shallbe a minimum of six months and shall not exceeda maximum of two years, computed from the dateof Certificate revocation.

(5) Revocation of Certificate of Compliance. If theholder of a Certificate of Compliance shall cease tohave a representative who is a member of the Leaguefor a period exceeding ninety (90) days, its Certificateof Compliance shall be revoked.

If a memberʼs collection agency license has beenrevoked or suspended because of a disciplinary pro-ceeding that action will require the CCAA ExecutiveDirector to investigate the circumstances surroundingthe matter and to report his/her findings to theCertificate of Compliance Committee. The ExecutiveDirector shall complete his/her investigation of the mat-ter within thirty (30) days of receiving notice of the rev-ocation or suspension. The Committee, after delibera-tion may decide to revoke or suspend the Certificate ofCompliance of the member agency. The Committeeshall complete its deliberations and reach its decisionwithin thirty (30) days of the Executive Directorʼs reportconcerning the revocation or suspension. Such a deci-sion must be ratified by the CCAA Council asdescribed in Section 2 (a) of this Resolution. If a mem-berʼs Certificate of Compliance is suspended, rein-statement of the certificate is not automatic and theagency must reapply for reinstatement at the expirationof their suspension. If the member takes issue with thedecision to suspend or revoke its Certificate ofCompliance it may appeal as outlined in Section 4 (d)of this Resolution.

Upon revocation, the Executive Director shall publish inthe next scheduled Associationʼs newsletter the revo-cation of the agencyʼs certificate and remove theagencyʼs name from all rosters and other Associationpublications and information.

(6) Amendments to Qualifications for Certificates ofCompliance. The Commercial Collection AgencyAssociation shall have the exclusive right to alter oramend the requirements for a Certificate ofCompliance subject to the approval of the Board ofGovernors of the League.

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1. A collection agency may engage in the business of col-lecting past-due accounts for customer-creditors (here-inafter “creditors”), provided, however, that the agencymay not, except where permitted to do so by applicablestate law:(a) Institute judicial proceedings on behalf of creditors or

other persons, or otherwise engage in the practice oflaw or represent that it is competent to do so;

(b) Communicate with debtors in the name of an attor-ney or upon the stationery of an attorney, or prepareany forms of instruments which only attorneys areauthorized to prepare;

(c) In dealing with debtors employ instruments simulat-ing forms of judicial process or forms of notice per-taining to judicial proceedings, or threaten the com-mencement of such proceedings;

(d) Employ or terminate the services of attorneys orarrange the terms or compensation for such ser-vices on behalf of creditors without written authorityto do so;

(e) Intervene between creditor and attorney in any man-ner which would control or exploit the services of theattorney or which would direct those services in theinterest of the agency;

(f) Demand or obtain in any manner a share of theproper compensation for services performed by anattorney in collecting an account, irrespective ofwhether or not the agency may have previouslyattempted collection thereof.

2. An agency may properly agree with creditors that theagencyʼs compensation will be contingent on success incollecting accounts, and the measure of compensationmay be a percentage of the amount collected.

3. When authorized by a creditor, it is proper for an agencyto recommend an attorney or attorneys to the creditorand to transmit accounts on behalf of the creditor to anyattorneys so recommended on terms and conditionsauthorized by the creditor.

4. When authorized by a creditor, it is proper for an agencyas agent for the creditor, to conduct correspondence of aroutine nature (such as inquiries and reports with respectto status of the claim) on behalf of the creditor with theattorney to whom the creditorʼs account has been trans-mitted for collection, and, in general, to carry on activitiessimilar to those ordinarily carried on by the collectiondepartment of a creditor organization provided that theattorney shall be free at all times to communicate withthe creditor and provided further (i) that the agency maynot attempt to control or in any way suggest or imply thatit has any right to control the actions of the attorney orotherwise interfere with the attorney-client relationshipbetween the creditor and the attorney, and (ii) that deci-sions as to the manner in which the claim is to be han-dled by the attorney, whether suit is to be brought, theclaim is to be compromised or settled, whether the claimis to be returned, and any other matters requiring thedecision of the creditor shall in each instance be left tothe creditor and the attorney in direct communicationwith each other when the attorney or the creditor sodesires and the attorney shall be so advised in the for-warding letter. Copies of correspondence between theattorney and the agency need not be forwarded to thecreditor unless the creditor requests otherwise. When theagency receives from the attorney an accounting con-cerning a collection made by the attorney, such account-ing or the details thereof shall be promptly transmitted bythe agency to the creditor.

DECLARATION OF FAIR PRACTICES OFCOLLECTION AGENCIES*

Approved by the Board of Governors of theCommercial Law League of America®

July 16, 1981

*This statement of proper activities of collection agencies from the standpoint of the unauthorized practice of law is intended toapply only where, and to the extent that, applicable statutes, court decisions, and regulations promulgated by governmentagencies do not conflict with the provisions of the statement.