RAM Payment, LLC, also dba Reliant; Account Management Systems, LLC, fka Reliant Account Management; Gregory Winters; and Stephen Chaya
On May 11, 2022, the Bureau issued an order against Tennessee-based RAM Payment, LLC and Account Management Systems, LLC (AMS) and AMS’s co-founders, Gregory Winters and Stephen Chaya. Since January 4, 2019, RAM Payment has offered account maintenance and payment processing services to debt relief companies and to consumers. Until AMS sold its assets to RAM Payment on January 4, 2019, AMS operated as “Reliant Account Management” and offered account maintenance and payment processing services to debt relief companies and to consumers. The Bureau found that the respondents (1) substantially assisted student loan and traditional debt relief service providers in requesting or accepting advance fees for debt relief services in violation of the Telemarketing Sales Rule (TSR); (2) engaged in deceptive acts or practices in violation of the Consumer Financial Protection Act of 2010 (CFPA), including by misrepresenting itself as an independent third party and misrepresenting the companies’ actions before disbursing fees to student loan debt relief service providers; and (3) engaged in unfair acts or practices in violation of the CFPA by disbursing unearned fees for student-loan debt relief services after consumers had unenrolled from or canceled the services. The order requires respondents to pay $8,676,180 in redress to consumers, which reflects the amount of unrefunded fees charged by AMS or RAM Payment and, for consumers enrolled in student loan debt relief services financed by a company affiliated with the companies, any unrefunded consumer fee payments for student loan debt relief services that AMS or RAM Payment disbursed to the affiliated company. The order also bans AMS, Winters, and Chaya from the debt relief payment processing and account maintenance industry, and, among other things, RAM Payment must (1) stop providing services to both student loan debt relief service providers and debt relief service providers receiving funding from or owned by an affiliated company; (2) stop paying commission to third-party marketing companies for consumer referrals; and (3) consent to the Bureau’s supervisory authority. Respondents also must pay a $3 million civil money penalty.