Pre-Collect, Billing and the FDCPA (Formerly Fastfax #1114)

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1 ACA International Compliance Updated Oct. 24, 2014 Pre-Collect, Billing and the FDCPA (Formerly Fastfax #1114) NOTICE SearchPoint access and content is a service provided exclusively to ACA Members; access and use is subject to the terms set forth at the end of this document. Overview: Pre-collect services provided by debt collectors must qualify for one of the exemptions from the FDCPA or the services will generally fall under the Act. Summary of Analysis: The true distinction among particular debt collection services such as outsourcing, billing, pre-collect, early-out, soft collections and servicing are often unclear. As such, the details concerning the actual provision of services are of greater importance than the phrases or words used to describe them. Simply labeling a particular program designed to induce payment as billing, pre-collect, early-out, servicing or soft collections, does not necessarily mean the service is exempt from the FDCPA. Practical Considerations: When performing or setting up any type of non-traditional collection program, you should: (1) obtain a clear understanding from your client as to when the accounts are designated as default; (2) decide in what name the service will be provided; (3) check to see if your Errors & Omissions insurance will cover the activity; and (4) most importantly, work with your own attorney and your client to develop policies and procedures to designed to comply with considerations noted throughout this document. Key Takeaways Debt collectors desiring to offer services free from the restrictions set forth by the FDCPA must ensure such services are truly exempt; if a careful examination reveals they are not, the FDCPA will apply, regardless of the service s description. Generally, third-party debt collectors have only limited options in offering services that are exempt from the Act. Related SearchPoint Documents Credit Grantors and the FDCPA # ACA International. All Rights Reserved.

2 Pre-Collect, Billing and the FDCPA #1114 Last Updated 10/25/14. Content updated and reformatted. Additional case law under footnotes 7, 9, 10, 11, 12, , and 29. NOTICE SearchPoint access and content is a service provided exclusively to ACA Members; access and use is subject to the terms set forth at the end of this document. The true distinction among particular debt collection services such as outsourcing, billing, pre-collect, earlyout, soft collections and servicing are often unclear. As such, the details concerning the actual provision of services are of greater importance than the phrases or words used to describe them. Simply labeling a particular program designed to induce payment as billing, pre-collect, early-out, servicing or soft collections, does not necessarily mean the service is exempt from the FDCPA. Debt collectors must be very careful and should consult with an attorney before engaging in these practices. Debt collectors desiring to offer services free from the restrictions set forth by the FDCPA must ensure such services are truly exempt; if a careful examination reveals they are not, the FDCPA will apply, regardless of the service s description. Generally, third-party debt collectors have only limited options in offering services that are exempt from the Act. The three most common ways debt collectors perform services unencumbered by FDCPA restrictions include: (1) collecting debt that is not subject to the FDCPA; (2) applying the not in default exemption; 1 or (3) applying the de facto employee of the creditor exemption. 2 Type of Debt If a person or entity is attempting to collect a debt that does not satisfy the definition of debt under the FDCPA, such collection efforts need not comply with the Act. A debt under the FDCPA is defined as any obligation or alleged obligation of a consumer to pay money arising out of a transaction in which the money, property, insurance or services which are the subject of the transaction are primarily for personal, family, or household purposes, whether or not such obligation has been reduced to judgment. 3 Some examples of debts not subject to the FDCPA include child support, 4 alimony 5 and commercial (business-to-business) debt. 6 Collection of Debts Not in Default If a debt collector is attempting to collect a debt that was not in default at the time the debt collector obtained the account, such collection efforts are generally exempt from the FDCPA. 7 Originally, this exemption applied to companies such as mortgage services in which business consisted of servicing current accounts. 8 Courts, however, have expanded this exemption beyond such companies, noting The language of the exemption clearly says any person, it does not restrict this exemption to mortgage service companies and assignees. Just as [803(5) 's] definition of debt broadly encompasses any obligation or alleged obligation of a consumer to pay money; [803(6)(F)(iii)'s] exemption broadly encompasses any person collecting any debt which was not in default at the time it was obtained by such a person. 9 Determining Default Status Because the FDCPA does not define whether or not an account is in default, whether a debt collector qualifies for this exemption turns on the default status of the accounts being serviced. Courts have repeatedly distinguished between a debt that is outstanding and a debt that is in default, emphasizing that only after some period of time does an outstanding debt go into default. 10 A debt is not in default simply because it is outstanding. 11 Federal Trade Commission (FTC) Staff has stated the terms of the contract creating the debt and applicable state or federal law generally control when a debt is considered to be in default. 12 When a default date is clearly defined under applicable law, a contractual default period will not be necessary to declare defaulted status ACA International. All Rights Reserved. Page 2 of 7

3 In the student loan context for example, the Federal Family Education Loan Program (FFELP) regulations promulgated under the Higher Education Act (HEA) 14 define the default date as the failure of a borrower to make monthly installment payments when due, or to meet other terms of the promissory note for 270 days. 15 Therefore, a FFELP student loan 90 days in arrears is considered delinquent, but not yet in default, 16 and a debt collector s attempt to collect on delinquent (earlier than 270 days outstanding) student loans may not be subject to the FDCPA. 17 More often than not, however, there is a lack of statutory and regulatory guidance as to whether an account is in default. In the absence of statutory guidelines, FTC Staff and the courts look to the contractual agreement between the original creditor and the consumer to determine when an account is in default. 18 It is important to note, however, that even when a contractual agreement purports to control the default status date, at least one court has concluded the contractual agreement between the original creditor and the consumer should not control if the creditor has unilateral discretion under the agreement to determine when an account is in default. 19 In one such court case, the agreement between the creditor and consumer stated the consumer agrees the creditor may, in [its] sole discretion, terminate [the consumer s] Account or reduce [her] credit limit by declaring [her] to be in default. 20 The creditor subsequently forwarded the consumer s account to a collection agency to collect the delinquent amount, which sent a letter to the consumer. The collection agency asserted it was not acting as a debt collector because the consumer s debt was not in default when it was referred to the agency for collection. 21 The court concluded the consumer s account was referred to a collection agency for collection, not for servicing; permitting the agency to use the not-indefault exemption would aggravate the purpose of the FDCPA where a creditor has unilateral discretion to determine when and if an account is in default. 22 Where a debt is created without a contractual agreement, FTC Staff and the courts may look to the creditor s reasonable written guidelines to determine when an account is in default. 23 FTC Staff specifically noted that in evaluating the creditor s written guidelines, FTC Staff would consider the totality of the circumstances, including, but not limited to, whether the guidelines are applied consistently and whether they are designed for administering accounts, rather than for circumventing the FDCPA. 24 For example, a set of guidelines that deem an account in default for purposes of loan acceleration, but would not consider that same loan in default for debt collection purposes, would not constitute reasonable procedures. 25 Debt collectors attempting to qualify under this not-indefault exemption should also review the creditor/consumer agreement s operation governing the default date. In one instance, the contract between the creditor and the consumer defined default as failing to pay on time, failing to keep any promise or failing to fulfill any agreement or obligation under the contract. Under this contract, making one late payment or missing one payment entirely would cause the account to go into default. In contrast, the agreement between the creditor and the debt collector defined defaulted accounts as those being more than eleven days past due for loan payments and more than sixty days past due for other fees and dues. 26 When the debt collector was sued for violations of the FDCPA, the debt collector argued it qualified for the not in default exemption and that therefore its collection efforts were not subject to the FDCPA. The court disagreed, noting the threshold question was whether the consumer s account was in default under the express terms of the agreement between the creditor and the consumer. 27 Whether the debt collector considered the debt to be in default had no bearing on the court s decision. Because the terms of the contract between the consumer and the creditor stated an account was in default as soon as one payment was late, the debt collector did not qualify for the not in default exemption despite the debt collector s agreement with the creditor. 28 Courts have also held this exemption does not apply to an assignee of a debt that sends consumers a notice incorrectly stating the consumers were in default on their debts, but fails to advise them of their rights under the FDCPA to dispute the default. Thus, when an entity erroneously concludes an account is in default and treats the account as a debt, it cannot later claim a not-indefault exemption. 29 Debt collectors attempting to qualify under this exemption should consult with an attorney as to whether the FDCPA s notice requirements should be provided when attempting to collect non-defaulted accounts. One court found it suspicious that a debt collector would place FDCPA required language on the bottom of the letter and seemingly go out of their way to comply with the FDCPA, only to subsequently argue the FDCPA does not apply to them when faced with litigation. 30 Furthermore, any reference to accounts being past due or delinquent, should be removed from attempts to collect a not-in-default account ACA International. All Rights Reserved. Page 3 of 7

4 Name under Which Services are Provided If a debt collector is attempting to collect debts that are not in default, the debt collector may attempt to collect under its own name, the creditor s name or another name in which the collector is properly authorized to do business. In conducting business under a name other than the name of the debt collector, the collection agency must proceed with caution as the agency may risk running afoul of 807(10), (14) 32 and 812(a). 33 State statutes and regulations may further limit what debt collectors may do in attempting to collect non-default debts. If a collector provides collection services on debts not in default in the name of the debt collector, among other things, the debt collector should (1) review the contracts between the creditor and the consumer; (2) obtain satisfactory assurances from the creditor all accounts forwarded are not in default; (3) obtain satisfactory indemnification from the creditor in the event a court determines the accounts were in default; and (4) if using the name of the collection agency, the agency must be meaningfully involved in the collection process. It is vital debt collectors establish a clear distinction between the services performed for clients as a debt collector on accounts in default and the services performed as a servicing agent on accounts that are not in default. Although a debt collector may be performing services on debts not in default for a creditor, a creditor may still be subject to liability under the FDCPA. In one such court case, a collection agency attempting to collect debt not in default sent a letter on its own letterhead advising, [y]our account has not yet been placed for collection. This is a pre-collection message offering you an opportunity to pay your bill. 34 The letter served as the basis of a class action lawsuit in which the consumer alleged a number of FDCPA violations, including: (1) the creditor was subject to the FDCPA; (2) the creditor was flatrating; and (3) the notice on the collection agency s letterhead was false and misleading because the collection agency was not meaningfully involved in the collection process. 35 In its analysis, the court compiled a list of factors that may assist in determining a debt collector s involvement or lack thereof. The evidence that may indicate a collection agency s participation is so minimal the creditor should be deemed a debt collector under the FDCPA includes: (1) the collection agency is a mere mailing service or performs only ministerial functions; (2) the letters state if the [consumer] does not pay, the debt "will be referred for collection"; (3) the collection agency is paid for merely sending letters rather than on the percentage of debts collected; (4) the collection agency does not receive any payments or forwards all payments to creditor; (5) if the [consumer] fails to respond to the letter(s), the collection agency has no further contact with the [consumer] or the creditor decides whether to pursue collection; (6) the collection agency does not receive the files of the [consumers]; (7) the collection agency never discussed with the creditor the collection process or what steps should be taken with certain [consumers]; (8) the collection agency cannot initiate phone calls to [consumers]; (9) any correspondence received by the collection agency is forwarded to the creditor; (10) the collection agency has no authority to negotiate collection of debts; (11) the letters do not state the collection agency's address or phone number; (12) the letter directs questions or payments to the creditor; and (13) the creditor has substantial control over the content of the letters. 36 The court also noted evidence that would indicate the collection agency is meaningfully involved in the collection process and the creditor is not acting as a debt collector, including: (1) the collection agency provides traditional debt collection services for the creditor such as direct contact with [consumers], locating debtors' assets, and referrals to collection attorneys; (2) accounts remain with collection agency if [consumer] does not pay after receipt of a letter; (3) the collection agency has authority to decide to pursue debts that remain unpaid after letters are sent; (4) the collection agency provides follow-up services; (5) the creditor pays only for successful collection efforts; 2014 ACA International. All Rights Reserved. Page 4 of 7

5 (6) the creditor exercises only limited control over the collection agency; (7) the collection agency retains information about the [consumers]; (8) the letters state collection agency's telephone number or address; (9) the collection agency drafts the letters; (10) the collection agency collects debts for others; (11) the collection agency answers [consumer] inquiries; and (12) the collection agency recommends how to pursue stubborn [consumers]. 37 While the court in this suit ultimately determined the creditor had not merely used the collection agency s name in its own collection efforts, 38 debt collectors and creditors should carefully consider the court s analysis when determining what types of services the collector will provide, in whose name the services will be provided and whether the FDCPA applies to either the creditor or the debt collector. If services are provided in the name of the creditor, the debt collector should be invisible to the consumer. In order to remain invisible, letters should be sent out on the creditor s letterhead, with return mail directed to the creditor s office (or a P.O. box set up specifically for that creditor s non-default accounts), collectors should answer the telephone in the name of the creditor and pay particular attention to the name appearing on a consumer s caller ID. Although debt collectors, billing companies and creditors are familiar with the (sometimes subtle) difference in the services being provided, consumers may not be able to recognize the difference. The FDCPA requires a debt collector use its own name when corresponding with a consumer. If a collection agency s employees are in fact debt collectors, they will violate 807(14) if they represent to consumers (improperly) they are employees of the creditor, unless the collector qualifies for the de facto employee exemption. 39 If such services are provided in a name other than the name of the debt collector or the creditor, the debt collector must ensure it is properly authorized to conduct business under the name in each of the states it plans to use that name. Some state laws prohibit companies from communicating in a name other than their legal name or properly authorized doing business as (d/b/a) trade name. For example, a debt collector violated the FDCPA as well as state law when it conducted business under a name other than the name of the agency and the creditor, and the name was not listed as a name under which the agency was conducting as a doing business as (d/b/a) trade name or otherwise. 40 Regardless of which name a collection agency uses to conduct collection activity (whether or not the accounts being collected are in default), the collection agency should check its insurance policies to verify the agency has coverage for the services the agency provides as well as the names under which the agency will be covered for providing those services. De Facto Employee of the Creditor Under 803(6)(A), [t]he term [debt collector] does not include (A) any officer or employee of a creditor while, in the name of the creditor, collecting debts for such creditor. 41 FTC Staff has stated this exemption includes a collection agency employee, who works for a creditor to collect in the creditor s name at the creditor s office under the creditor s supervision, because he has become a de facto employee of the creditor. 42 It is important to note a debt collector may qualify for the de facto employee of the creditor exemption whether or not the accounts being collected are in default. 43 FTC Staff has expanded this de facto employee exemption to include collection agency employees collecting debts on behalf of and in the name of a creditor even when the collection agency employees do not work on the creditor s premises. However, such instances have been limited to situations in which the creditor maintains an extensive degree of control and supervision over collection efforts. 44 FTC Staff has stated: The more agency employees are treated like creditor employees, the more likely it is that [the FTC] would deem them de facto employees. Whether agency employees working on the creditor s premises or on the agency s premises are treated enough like creditor employees to become de facto employees of the creditor will depend on the degree of control and supervision exercised by the creditor over the agency employees collection activity, and how similar that control and supervision is to that exercised by the creditor over its own employees. 45 Factors FTC Staff would consider in determining whether a debt collector qualifies for the de facto employee exemption include, but are not limited to: (1) whether and how the creditor supervises and monitors the collection activities; (2) who trains the collection 2014 ACA International. All Rights Reserved. Page 5 of 7

6 agency employees; and (3) whether the collection agency employees are subject to the same rules, procedures and disciplinary actions as the creditor s employees. 46 If collection practices and procedures are controlled by the collection agency, the collection agency will not qualify for the de facto employee of the creditor exemption. 47 FTC Staff has cautioned debt collectors attempting to collect in the creditor s name must ensure they properly qualify for this exemption if they are not employing FDCPA-compliant procedures in their business activity, stating If these exemptions do not apply and the agency s employee attempts to collect the debt in the creditor s name, the agency may violate Section 807(14) of the FDCPA which prohibits debt collectors from using any business, company, or organization name other than the true name of the debt collector s business, company, or organization. If the agency is a debt collector, it may not use the creditor s name when communicating with consumers from whom it is attempting to collect debts; it must use its own. 48 As previously discussed, it is important to understand when services are provided in the name of the creditor, the debt collector should be invisible to, and for the benefit of, the consumer. Although debt collectors, billing companies and creditors are familiar with the difference in the services being provided, consumers may not recognize the difference. Conclusion It is very important to establish a clear distinction between the functions performed for clients as a debt collector on defaulted accounts and those provided for non-defaulted accounts. The distinction between the two separate services should help to minimize any confusion between collectors, creditors and consumers as to the status of a receivable either being current or in default and whether the FDCPA applies. When performing or setting up any type of nontraditional collection program, you should: (1) obtain a clear understanding from your client as to when the accounts are designated as default; (2) decide in what name the service will be provided; (3) check to see if your Errors & Omissions insurance will cover the activity; and (4) most importantly, work with your own attorney and your client to develop policies and procedures to designed to comply with considerations noted throughout this SearchPoint. SearchPoint is a trademark of ACA International. Any content contained in this SearchPoint ( Content ) is presented for educational and general reference purposes only. ACA International ( ACA ) provides this Content as a courtesy to be used for informational purposes only. ACA does not represent or warrant that the Content is accurate, complete or current for any specific or particular purpose or application. This Content is not intended to serve as legal or other advice and should not replace the advice of your own legal counsel. ACA is the sole owner of the Content and all the associated copyrights. ACA hereby grants a limited license to the Content solely in accordance with the copyright policy provided at By using the Content in any way, whether or not authorized, the user assumes all risk and hereby releases ACA from any liability associated with the Content U.S.C. 1692a(6)(F)(iii) (2012) [ 803(6)(F)(iii)] U.S.C. 1692a(6)(A) (2012) [ 803(6)(A)] U.S.C. 1692a(5) (2012) [ 803(5)]. 4 See, e.g., Mabe v. G.C. Servs. Ltd. P ship, 32 F.3d 86, 88 (4th Cir. 1994). 5 Hicken v. Arnold, Anderson & Dove, P.L.L.P., 137 F. Supp. 2d 1141, 1143 (D. Minn. 2001). 6 Utility Metal Research Inc. v. Coleman, No. 03 CV 1463(SLT)(SMG), 2008 WL , at *6 (E.D.N.Y. Mar. 28, 2008); Elwood v. Cobra Collection Agency, No. 2:06cv91- DCB-RHW, 2007 WL , at *4 (S.D. Miss. Dec. 3, 2007) U.S.C. 1692a(6)(F)(iii) (2012) [ 803(6)(F)(iii)]; See e.g., Carter v. AMC, LLC, 645 F.3d 840, (7th Cir. 2011); Alamo v. ABC Fin. Servs., Inc., Civ. A. No , 2011 WL , at*4-6 (E.D. Penn. Jan. 20, 2011). 8 FTC Statements of General Policy or Interpretation Staff Commentary on the FDCPA, 53 Fed. Reg , (Dec. 13, 1988). Note, however, that several courts have found that a mortgage servicer is subject to the FDCPA if they became servicers after the serviced debt was declared defaulted. 9 Kvassay v. Hasty, 236 F. Supp. 2d 1240, 1270 (D. Kan. 2002). 10 See Alibrandi v. Fin. Outsourcing Servs. Inc., 333 F.3d 82, (2d Cir. 2003); Roberts v. NRA Grp., LLC, F. Supp. 2d, 2012 WL , at *5 (M.D. Pa. Aug. 10, 2012); Roberts v. NRA Grp., LLC, Civ. A. No. 3: , 2012 WL , at *5 (M.D. Penn. Aug. 10, 2012) (citing Alibrandi); Skerry v. Mass. Higher Educ. Assistance Corp., 73 F. Supp. 2d 47, ACA International. All Rights Reserved. Page 6 of 7

7 54 (D. Mass. 1999); Jones v. Intuition, Inc., 12 F. Supp. 2d 775, 779 (W.D. Tenn. 1998). 11 Alibrandi v. Fin. Outsourcing Servs. Inc., 333 F.3d 82, 87 (2d Cir. 2003); Roberts v. NRA Grp., LLC, F. Supp. 2d, 2012 WL , at *5 (M.D. Pa. Aug. 10, 2012). 12 de Mayo, FTC Informal Staff Letter (May 23, 2002). See also Prince v. NCO Fin. Servs., Inc., 346 F. Supp. 2d 744, 747 (E.D. Pa. 2004). 13 See, e.g., Trapper v. Credit Collection Servs., Inc., No. 10- CV RJA-JJM, 2011 WL , at *2 (W.D.N.Y. Aug. 31, 2011). 14 Higher Education Act of 1965, Pub. L. No C.F.R (b) (2013) (The current regulations state an account goes into default when the borrower fails to make monthly installment payments when due or meet other terms of the promissory note for 270 days). 16 Skerry v. Mass. Higher Educ. Assistance Corp., 73 F. Supp. 2d 47, (D. Mass. 1999). 17 Id. 18 Alamo v. ABC Fin. Servs., Inc., Civ. A. No , 2011 WL , at*5 (E.D. Penn. Jan. 20, 2011); Prince v. NCO Fin. Servs., Inc., 346 F. Supp. 2d 744, 747 (E.D. Pa. 2004); Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031, 1042 (W.D. Wis. 2002); de Mayo, FTC Informal Staff Letter (May 23, 2002); Isgrigg, FTC Informal Staff Letter (Nov. 10, 1992); Cranmer, FTC Informal Staff Letter, n. 2 (Apr. 25, 1989). 19 Magee v. AllianceOne, Ltd., 487 F. Supp. 2d 1024 (S.D. Ind. 2007). 20 Magee v. AllianceOne, Ltd., 487 F. Supp. 2d 1024, 1026 (S.D. Ind. 2007). 21 Magee v. AllianceOne, Ltd., 487 F. Supp. 2d 1024, (S.D. Ind. 2007). 22 Magee v. AllianceOne, Ltd., 487 F. Supp. 2d 1024, 1027 (S.D. Ind. 2007). 23 de Mayo, FTC Informal Staff Letter (May 23, 2002). See also Prince v. NCO Fin. Servs., Inc., 346 F. Supp. 2d 744, 747 (E.D. Pa. 2004). 24 de Mayo, FTC Informal Staff Letter (May 23, 2002). See also Prince v. NCO Fin. Servs., Inc., 346 F. Supp. 2d 744, 747 (E.D. Pa. 2004). 25 de Mayo, FTC Informal Staff Letter (May 23, 2002). 26 Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031, 1036 (W.D. Wis. 2002). 27 Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031, 1042 (W.D. Wis. 2002). 28 Hartman v. Meridian Fin. Servs., Inc., 191 F. Supp. 2d 1031, (W.D. Wis. 2002). 29 Scholosser v. Fairbanks Capital Corp., 323 F.3d 534, (7th Cir. 2003); Belin v. Litton Loan Serv. LP, No. 8:06-cv- 760-T-24 EAJ, 2006 WL , at *3 (M.D. Fla. July 14, 2006). 30 Healy v. Jzanus, Ltd., No. 02CV1061CBAASC, 2002 WL , at *2 (E.D.N.Y. Nov. 20, 2002). 31 Using a false representation or deceptive means to collect a debt. 15 U.S.C. 1692e(10) (2012) [ 807(10)]. 32 The use of any business, company or organization name other than the true name of the debt collector s business, company or organization. 15 U.S.C. 1692e(14) (2012) [ 807(14)]. 33 Designing, compiling or furnishing any form knowing such form would be used to create the false belief that a person other than the creditor is participating in the collection of or in an attempt to collect a debt when such person is not participating. 15 U.S.C. 1692j(a) (2012) [ 812(a)]. 34 Larson v. Evanston N.W. Healthcare Corp., No. 98 C 0005, 1999 WL , at *1 (N.D. Ill. July 19, 1999). 35 Id. 36 Larson v. Evanston N.W. Healthcare Corp., No. 98 C 0005, 1999 WL , at *4 (N.D. Ill. July 19, 1999). 37 Id. 38 Larson v. Evanston N.W. Healthcare Corp., No. 98 C 0005, 1999 WL , at *6 (N.D. Ill. July 19, 1999). 39 Hartman v. Meridian Fin. Servs. Inc., 191 F. Supp. 2d 103, (W.D. Wis. 2002). 40 Id U.S.C. 1692a(6)(A) (2012) [ 803(6)(A)]. 42 FTC Statements of General Policy or Interpretation Staff Commentary on the FDCPA, 53 Fed. Reg , (Dec. 13, 1988). 43 de Mayo, FTC Informal Staff Letter (May 23, 2002). 44 de Mayo, FTC Informal Staff Letter (May 23, 2002); Shapiro, FTC Informal Staff Letter (Oct. 1, 1997). See also Vandenbroek, FTC Informal Staff Letter (Apr. 20, 1981). 45 de Mayo, FTC Informal Staff Letter (May 23, 2002). 46 Id. 47 Id. 48 Id ACA International. All Rights Reserved. Page 7 of 7