Compliance
Compliance
Capital Review Management is a licensed third-party collection agency. What follows is not a statement of intent — it is the framework we operate inside, the controls that enforce it, and the licenses and bonds that let us operate at all. Where a control is enforced by the system rather than by instruction, it says so.
The framework
Regulatory Framework
| Authority | Citation | What it governs |
|---|---|---|
| Fair Debt Collection Practices Act | 15 U.S.C. § 1692 et seq. | Who we may contact, when, how often, what must be disclosed, and what may never be said |
| Regulation F | 12 C.F.R. Part 1006 | The validation notice, call-frequency limits, time and place restrictions, and electronic communications |
| Fair Credit Reporting Act | 15 U.S.C. § 1681 et seq. | Permissible purpose for obtaining consumer report data, and accuracy of anything we furnish |
| Regulation V | 12 C.F.R. Part 1022 | Written accuracy and integrity policies required of a furnisher |
| Telephone Consumer Protection Act | 47 U.S.C. § 227 · 47 C.F.R. § 64.1200 | Consent before any call or text to a mobile number, and honouring revocation |
| Gramm-Leach-Bliley Act | 15 U.S.C. § 6801 et seq. · 16 C.F.R. Part 314 | Safeguarding non-public personal information, and the prohibition on pretexting |
| Servicemembers Civil Relief Act | 50 U.S.C. § 3901 et seq. | Protections applied on notice of active-duty status |
| Bankruptcy Code | 11 U.S.C. § 362 | The automatic stay — activity stops on notice of a filing |
| HIPAA | 45 C.F.R. Parts 160, 164 | Applies where we service healthcare receivables as a business associate under an executed BAA |
| Texas Finance Code | Tex. Fin. Code Ch. 392 | Third-party debt collector conduct and bonding in our home state |
| State collection and unfair-practices statutes | Varies by state | Applied per state of residence, alongside the federal floor |
Governance
Our Controls
| Control | Governing authority | Status |
|---|---|---|
| A Chief Compliance Officer with authority to halt activity on any account or portfolio | CFPB compliance management expectations | Standing |
| Written policies and procedures maintained, reviewed and updated | 12 C.F.R. § 1022.42(b) · Reg F | Maintained |
| Background screening completed before any employee is onboarded | Internal hiring control | Pre-onboarding |
| Training completed and competency demonstrated before an agent touches an account | Reg F · internal training program | Certified |
| Every inbound and outbound call recorded, archived and available for QA review | State consent statutes | All calls |
| Calls scored against approved scripts, including required-disclosure verification | 15 U.S.C. § 1692e(11) · 12 C.F.R. § 1006.18(e) | Monitored |
| Complaints investigated by Compliance, with root-cause analysis and corrective action | CFPB complaint-response obligations | Tracked to closure |
| CFPB portal complaints answered inside the Bureau’s response window | 12 U.S.C. § 5493(b)(3) | Tracked to closure |
| Litigation holds applied on notice, with evidence preservation | FRCP 37(e) · internal control | On notice |
| AI-assisted contact disclosed, with human oversight and sampled review | FTC Act § 5 · internal AI governance policy | Disclosed |
| Data encrypted in transit and at rest; MFA, role-based access and session timeouts enforced | GLBA Safeguards · 16 C.F.R. Part 314 | Enforced |
| Access to consumer data logged, reviewed, and limited to business need | 16 C.F.R. § 314.4 | Logged |
| Retention bounded by schedule, with documented secure destruction | 16 C.F.R. § 682.3 | Scheduled |
| Vendors and data suppliers subject to due diligence and ongoing monitoring | CFPB Bulletin 2016-02 | Audited |
| Consumer requests — validation, dispute, cease contact, bankruptcy, fraud — routed and actioned by system rule | 15 U.S.C. §§ 1692c, 1692g · 11 U.S.C. § 362 | System-enforced |
Bonding and Insurance
Surety Bonds
| State | Bond amount | Bond no. | Carrier |
|---|---|---|---|
| Arkansas | $10,000 | S-998565 | NGM Insurance |
| Colorado | $20,000 | S-998566 | NGM Insurance |
| Connecticut | $50,000 | S-998567 | NGM Insurance |
| Illinois | $25,000 | S-998568 | NGM Insurance |
| Indiana | $5,000 | S-998569 | NGM Insurance |
| Maryland | $50,000 | S-998570 | NGM Insurance |
| Massachusetts | $25,000 | S-998571 | NGM Insurance |
| Michigan | $5,000 | S-998572 | NGM Insurance |
| Nevada | $35,000 | S-998574 | NGM Insurance |
| North Carolina | $10,000 | S-998575 | NGM Insurance |
| Oregon | $10,000 | S-998578 | NGM Insurance |
| Tennessee | $15,000 | S-961504 | NGM Insurance |
| Texas | $10,000 | 101761016 | Merchants National Bonding, Inc. |
| Washington | $5,000 | S-998580 | NGM Insurance |
| Wisconsin | $35,000 | S-998581 | NGM Insurance |
| Wyoming | $10,000 | S-998582 | NGM Insurance |
Insurance
Errors and omissions coverage and cyber liability coverage are maintained continuously and reviewed annually. Surety bonds are secured in every jurisdiction that requires one, and adjusted when a state changes its requirement. Certificates of insurance and evidence of bonding are provided to clients on request.
Escalation
Contact Compliance
A complaint reaches our Compliance Officer, not the collector it concerns. It is investigated, root-caused, and answered — and if we got it wrong, the correction applies to the account and to the process that allowed it.
Compliance contact
Capital Review Management, LLC — Compliance
600 River Pointe Drive, Suite 200
Conroe, TX 77304
833-203-0445
Consumers can also use any of the direct requests on our Consumer Rights page, including filing a complaint. Every federal and state regulator with authority over us accepts complaints directly, and we cannot penalize anyone for filing one.