Short answer
By mapping each activity separately, because states draw the line differently. Third-party collection is licensed almost everywhere; first-party servicing under a client's brand is licensed in some states and exempt in others, and the answer can change with whose name is on the letter. Cornerstone Licensing maintains both maps for clients that run both models and tracks the combined license set in Atlas.
The first-party question is the one companies get wrong most often, in both directions. Some assume servicing accounts in the creditor's name never needs a license and get caught in the states that license first-party activity; others over-file and pay for licenses they do not need. The determining facts are usually whose name appears to the consumer, whether the accounts are in default, and how the state statute defines a collection agency, and those facts have to be checked state by state, not assumed.
A company running both models, common in ARM as agencies add first-party servicing lines, should keep one inventory with each license tagged to the activity it covers, so adding a client program in a new state is a lookup rather than a research project. Cornerstone Licensing builds that dual map, files the licenses each leg requires, and keeps the record in Atlas so the compliance team can show any client or examiner exactly which authority covers which program.
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More questions about Collections licensing
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