GOVERNMENT AFFAIRS may have more complaints than companies with fewer customers. We encourage you to pair complaint data with public and private data sets for additional context." This in part addresses concerns raised by ACA that beyond this mischaracterization, the bureau "fails to contextualize the number of complaints compared to the number of contacts the debt collection industry makes to consumers over a given year, which the Philadelphia Federal Reserve estimates to be well over one billion." Overall, many of ACA's concerns have not been fully addressed. Most notably, ACA has urged the bureau that more must be done to normalize the data being released to the public beyond just broad disclosures. For example, consumers and others in the marketplace may improperly look at the current number of complaints as an appropriate indicator of performance when, once normalized, the rate of complaints might be quite low compared to the number of contacts with consumers. 2020 ACA INTERNATIONAL ACA also remains concerned that the bureau cites much of its past flawed data in parts of its proposed rule for the Fair Debt Collection Practices Act. As the bureau moves forward in any areas of reevaluating the complaint database, ACA will continue to work to highlight our concerns. Leah Dempsey is ACA International's vice president and senior counsel of federal advocacy. MARCH 11-13 M RESORT LAS VEGAS SPRING FORUM INNOVATION & EXPO IN MOTION Stay in front of technology trends within our industry. This year's Spring Forum & Expo will focus on how technology will impact the way we do business while continuing to offer required courses for ACA's compliance designations. www.acainternational.org/events Register Early & Save 48 ForwardTECH Business Intelligence Compliance Designations ACAINTERNATIONAL.ORGhttp://www.acainternational.org/events http://www.ACAINTERNATIONAL.ORG