March 18, 2026 · Financial Institutions Committee · 11,601 words · 11 speakers · 71 segments
We have a quorum present, so we'll begin the meeting as a full committee. Please review the minutes from last week's committee meeting. Are there any objections to the minutes? Hearing none, they become part of the record. I will now call up House Bill 648 for its first hearing and invite Representatives Kishman and Representatives Miller to provide sponsor testimony.
Welcome. Chairman Osslager, Vice Chair Pizzulli, Ranking Member Russo, and members of the House Financial Institutions Committee, thank you for the opportunity to present sponsor testimony on House Bill 648, the Ending Loss and Deception in Electronic Resources, or ELDER Act. The ELDER Act is about protecting Ohio consumers, particularly our most vulnerable residents, from fraud and financial harm in an increasingly digital financial landscape. Across Ohio, digital asset kiosks, commonly known as cryptocurrency or Bitcoin ATMs, have proliferated convenience stores, gas stations, and other retail locations. Too often, these machines are used as tools to defraud seniors and other unsuspecting Ohioans out of their life savings. This bill sets common-sense guardrails to prevent that from happening. House Bill 648 requires anyone who owns and operates or facilitates digital asset kiosk in Ohio to be licensed as money transmitters under Chapter 1315 of the Ohio Revised Code. This ensures that kiosk operators are subject to the same financial oversight and accountability standards as other money service businesses operating in our state. Ohioans deserve to know that businesses handling their money are legitimate and properly regulated. The bill mandates robust consumer disclosures before any transaction takes place. Operators must clearly inform customers in plain English that no government agency or financial institution will ever ask them to use these machines to pay a debt or a fine, that digital asset transactions are irreversible, and these transactions are commonly exploited by scammers. These are the exact lies that fraudsters tell our neighbors and grandparents every day. At this time, I'd like to turn it over to my joint sponsor, Representative Miller, to highlight additional aspects of the bill.
Thank you, Representative Kishman. I'll now take a few moments to outline several additional protections included in the bill. House Bill 648 establishes several important consumer safeguards. Number one, there's a 72-hour hold for any new customers. New customers are subject to a 72-hour hold on their transactions, giving them time to reconsider or cancel if something feels wrong. Number two, reasonable transaction limits. The bill sets daily limits of $2,500 for new customers and $10,500 for existing customers to help prevent large losses from fraudulent activity. Number three, identity verification requirements. Operators must verify the identity of customers conducting transactions of $1,000 or more, adding another layer of accountability and protection. Number four, special protection for our older Ohioans. If a new customer, age 60 or older, attempts a transaction of $1,000 or more, the operator must speak with the customer by phone before the transaction can proceed. During this phone call, the operator must do two things. Number one discuss the purpose of the transaction and number two review common fraud and scam tactics used to target our seniors Scammers disproportionately target older Ohioans and this provision adds a critical layer of protection. Finally, the bill provides a clear path to restitution for victims of fraud. If a customer is defrauded and reports the crime to law enforcement within 30 days, The operator must refund transaction fees and commissions within 10 business days. Operators must also maintain full-time compliance staff and designate a chief compliance officer to ensure these protections are properly enforced. We have taken the time, Representative Kishman and I, to thoughtfully craft this legislation with the support of many individuals, including AARP, Bitcoin Depot, CoinFlip, and Coinbase, among others. House Bill 648 strikes a balance between enabling Ohioans to participate in the digital economy, ensuring that they are protected when they do. It holds an under-regulated industry accountable, deters bad actors, and gives Ohioans the information and safeguards that they need to make informed financial decisions. We respectfully ask for your favorable consideration of House Bill 648, and we would be happy to answer any questions that the committee has at this time. Thank you.
Thank you very much. Representative Russo has a question.
Thank you to the chair and to the sponsors for bringing this forward. First, I just want to say I appreciate this effort and support the intent of this effort. My big concern about this bill is that it doesn't go far enough. And I say that because I know that a couple of inquiries into these kiosks, my understanding is they represent only one-tenth of one percent of all crypto transactions. We're talking about very, very, very tiny percent of crypto transactions. And according to the Attorney General, they represent 93% of those transactions are fraud. So I guess my question is, why do sort of this piecemeal approach, as opposed to what our neighbors in Indiana have done recently, as well as Minnesota, and not just outright ban these kiosks? kiosks because it appears just based on both the number of transactions that we're talking about, this is such a minuscule part of cryptocurrency transactions, and the overwhelming majority of these are related to fraud. Why are we not just outright banning them? Because it doesn't seem like banning them is going to have an actual impact on the ability of people to access this currency?
Through the chair to the representative, we had numerous discussions. We talked about a total pretty much ban, and then we know there is a small percentage of people that do use these machines. We went back and forth with a year on this. And this is just introduced, so we can meet with both parties and maybe modify it down the road.
Quick follow-up. Yeah, and thank you for that. The only thing that I would add to this is that I think the state of Minnesota tried this piecemeal approach as well originally and found that there was still a significant amount of fraud because there are ways that these bad actors got around some of these constraints. and so that is why they most recently just outright banned them and we seeing other states follow along Democratic and Republican states follow along in doing that So I would just offer that as consideration because I think that this is a big problem Again, I support fully the intent of your bill. I just worry that we're adding an extra step here to what is inevitable and that these should be outright banned.
Also through the chair to the representative, I know, you know, I look at things like Western Union. People can go send Western unions, and we see more and more scams. But, you know, it's just people also use Western Union for legitimate purposes. So I kind of look at it. Through the chair to Representative Russo, I would just maybe add, we actually, Representative Kishman and I touched base this morning, and we came across a few recent podcasts just interviewing people that experience fraud at these type of kiosks. What I would mention is the state of California, I believe it's also Connecticut, have also found by putting some of these restrictions and putting some of these caps like we have in our bill, that has absolutely helped tremendously in preventing fraud in those states. So I'm hopeful that at least as we begin this process, this will be a starting point. but look forward to exploring if we need to go a little bit farther, and I appreciate your interest in that. Thank you.
Good. Representative Stevens and then Representative Ferguson.
Thank you, Chair. Thank you for the bill. How many states are there that are dealing with this issue? Through the chair to the representative, so far 17 states have put on consumer protections, and just 14 was passed in 2025. And I expect maybe all 50 states will have something like probably 2030.
Reverend Stevens, follow up?
No, thank you. You actually answered the second part of my question that I didn't even ask yet. So good job.
Representative Ferguson.
Thank you, Chair. Thank you both for coming in. I appreciate the intent of the bill. I appreciate what our colleague Representative Russo said about the outright ban. But what I also applaud is that you are actually looking to not ban something. And so I always hesitate to ban things here in the state of Ohio, supporting freedom and things. And there are people that want to access as many different products and have differences. And so I guess I'll just leave it to you to say that I applaud that effort. And certainly I would guess and ask and feel free to comment that maybe that's your goal is to make sure that whatever small amount of people there are, you don't leave them behind.
Yep. Through the chair to the rep, we do understand that there is a small number of people that use these machines. So we talked about it first when we brought this up doing a total ban, but we do feel that there are some people that do use these machines.
Thank you. Other questions of the sponsors? Thank you very much. I do have an amendment. It's on your iPads. I will move Amendment 1873. Just a second. It doesn't do that. I'll help you do it. Go ahead. I recognize Representative Azuli for an amendment.
I move to amend Amendment 1873, which moves to name the act the ending losses and deception and electronic resources or elder act I second it That simply is naming it That all the amendment does Is there any objections to the amendment Hearing none it becomes part of the bill
This concludes the first hearing of House Bill 468. I now call up House Bill 560 for a second hearing. We will no longer be accepting the sub-bill for this, and the proponents will give their testimony as the bill is currently written. I would now like to invite Andrew Cannon with the Ohio Credit Union League to provide proponents testimony. Probably didn't say your name right, sorry. It's been a while since I called your last name.
Good afternoon, Andrew Cannon with the Ohio Credit Union League.
Thank you.
Chairman Olslager, Vice Chair Pizzulli, Ranking Member Russo, and members of the Ohio House Financial Institutions Committee, Thank you for the opportunity to support House Bill 560, the Protect Our Parents Act, which seeks to curtail fraud, an increasingly pervasive issue, an escalating problem affecting all consumers. The Ohio Credit Union League is the state trade association representing the collective interests of Ohio's 199 federally and state chartered credit unions and their 3.3 million members. As member-owned financial cooperatives, credit unions are committed to transforming lives and local communities. HB 560 provides financial institutions with a tool to combat fraudulent transactions as fraud continues to grow in frequency and sophistication. According to the Federal Trade Commission, consumers lost more than $12 billion to fraud in 2024, an increase of 25% from 2023. Of that total, Americans lost a combined total of more than $8.5 billion to investment and imposter scams alone. In Ohio specifically, financial losses jumped 14% from 2022 to 2023 per report from the Department of Commerce. By defining financial exploitation and providing an opportunity for financial institutions, such as credit unions, to place a temporary hold, this legislation could disrupt a fraudulent scam before it begins. Further, allowing for trusted contact provides a designated individual to serve as a second point of contact to authenticate whether or not a transaction is legitimate. Finally, as the bill sponsors highlighted during their sponsor testimony, HB 560 does not interfere with legitimate access to funds. Instead, it allows for appropriately trained professionals on the front lines to simply pause and further investigate suspicious financial activity to best protect members' money. While we know no single piece of legislation can eliminate financial exploitation entirely, we believe the intent of the bill sponsors with this legislation is a step in the right direction. Ohio credit unions remain steadfast in their commitment to member protection and fraud prevention. We appreciate the Ohio General Assembly's recognition of the need to equip financial first responders with additional tools to combat a rapidly growing and costly threat. Thank you to Representatives White and Swearingen for their continued work on this issue. We thank you for the opportunity to support HB 560, and I'm happy to answer any questions you might have.
Thank you very much. Are there questions of the witness? Representative Timms.
Thank you, Chair, and thank you, Andrew, for coming to testify today. We discussed this bill, I think, decently, a decent amount the last time it came up for a hearing, and one of the questions was about the training of staff given the 15-day hold. Is the Credit Union League, or are you aware of sort of the conversations around the employee training for these fraudulent scams?
Mr. Chairman, Representative, one of the things that we have discussed is pairing with the required training of the banks. Act, which includes suspicious activity reports. It would be similar types of transactions where something seems off that already frontline staff are reporting as part of the Bank Secrecy Act, and that has required annual training by financial institutions and their frontline staff. And so that's been a conversation with the bill sponsors as part of potentially taking care of that training requirement, as it's already something that they're looking for, something that seems off with, you know, that's out of character, for instance, for one of our members as they're coming in to, you know, do their transactions.
Follow up. Thank you, Chair. And if a credit union or a bank decides to place a 15-day hold or a 14-day hold, are you all thinking through parameters for what a release would look like if said owner of the account says it's not fraudulent, I actually want that transaction to go through?
Mr. Chairman, to the representative, I think, yes, especially with the trusted contact provision where there could be an opportunity. Obviously, this is looking at, you know, particularly with the original draft, looking at the elder population. And maybe it's a, you know, a child of the account holder that they could verify that, in fact, there is a legitimacy to the transaction. I think one of the concerns that our members did express as part of this conversation is, of course, that they know what kind of reaction they're going to get when they go place the hold. So this would be a case where they feel pretty confident that there's something being taken advantage of. I mean, we've heard of stories of members coming into the credit union. They actually are wearing like an earpiece and they're being coached as part of that process. Or, you know, your romance scams where, you know, I've heard of a story of. an elderly gentleman coming in all of a sudden starts taking out a few hundred bucks every week and then a thousand dollars and they're asking what's going on and come to find out unfortunately that he was being convinced that he was dating Kim Kardashian and when they raised this to him he said well yeah you know she's worth a billion dollars but she needs some weekend spending money and she wants to take care of her. And so I think you know there's it would be cases like that where you know clearly there's some fraudulent transactions going on and you know investigate it appropriately, contact the appropriate authorities, and if there's nothing weird going on, immediately release the funds. As I highlight in the testimony, we, of course, if it's a legitimate transaction, don't want to cause any harm to our members. We want to make sure that they're taken care of and that their money is protected.
Members of Timms? Thank you.
Other questions of the witness? Thank you very much for coming in.
Thank you very much.
I now invite Don Boyd with Hal Bankerslake to provide proponent testimony. Welcome. Thank you.
Chair Olschlager, Vice Chair Pizzoli, Ranking Member Russo, and members of the House Financial Institutions Committee, thank you for the opportunity to provide testimony in support of House Bill 560. The Ohio Bankers League is the state's leading trade association representing all types of FDIC, insured banks, and thrifts throughout Ohio. Our members include more than 170 financial institutions of all sizes employing 75,000 Ohioans. So my name is Don Boyd, Senior Vice President of Government Relations and General Counsel for the OBL. The OBL supports House Bill 560 because it provides additional tools for financial institutions to protect against fraud and financial exploitation, while preserving the fundamental principle that customers must have timely access to their funds. Banks often see the first warning signs that something is going wrong, sudden withdrawals, urgent wire requests, unusual account behavior, or transactions that simply appear inconsistent with a customer's history. Today institutions may identify these risks but lack clear statutory authority to pause a transaction long enough to determine whether fraud is occurring House Bill 560 helps address that gap by allowing financial institutions to place temporary holds where there's a reasonable cause to suspect financial exploitation. I'm not going to go through all the key components of the bill. I think based on earlier testimony and then last hearing, there's a pretty good understanding of the way it would work. But one thing I will highlight is that banks are already mandatory reporters of elder exploitation when we think something is going on. We are already making these reports to adult protective services in Ohio if we suspect something's going on. This simply adds the ability to hit the pause button while those reports are being made, while local law enforcement is getting involved and be able to essentially let everyone take a breath and really figure out what's going on when there is suspected fraud. And so that's the biggest piece of this. In all these scams, and I'll talk a little bit about it later, there is a sense of urgency created. They're trying to put pressure on people, and that's how these operate and how they work. So being able to hit the pause button is extremely beneficial to allow cooler heads to prevail, to think it through, and allow proper time to investigate. And so really the balancing act that all banks are under, and this bill I think does a very good job of navigating, is a dual responsibility. Banks operate under a constant balancing act. They are expected and required to detect and prevent fraud, money laundering and financial exploitation. At the same time, federal and state law require institutions to provide prompt access to deposited funds and avoid unnecessary delays in legal transactions. House Bill 560 helps institutions manage this tension by providing clear authority and liability protection and allowing trained professionals to pause suspicious activity briefly while coordinating with investigators. Fraud is growing more and more sophisticated. This is something where fraud is increasing in both frequency and complexity. Criminal actors now use artificial intelligence, impersonation tactics, spoof communications, coordinated social engineering campaigns, and more to try and trick people into getting their money. It's becoming more and more prevalent. We're seeing more and more of it across the state and across the country. National research shows that about half of banks and states with transaction hold authority, similar to what's being proposed in this bill, have used that authority to delay a suspicious transaction and prevent losses. While nearly 90% of banks and states without such laws believe authority would be beneficial to have. Once funds leave an account, particularly through wires, peer-to-peer platforms, or cryptocurrency channels, recovery becomes extremely difficult. Consumers recognize and value the role that banks play in fraud prevention. Surveys show that 9 in 10 customers believe their banks take proactive steps to protect them, and nearly all say that fraud alerts from banks are valuable. This trust carries responsibility. Customers want protection, but they also expect reliable access to their funds. This legislation helps institutions meet both of those expectations. And one of the key things that I think is beneficial for banks, legislators, the general public to really be aware of is just reducing some of the stigma related to fraud. As I said, these are getting more and more sophisticated. People are and it's happening more and more to people throughout the state. It's a deeply personal thing. Victims often feel embarrassed or hesitant to hesitant to report what has happened. we have to break down that stigma that often accompanies that victimization It is important to say clearly that no one should feel ashamed for being targeted or victimized by fraud Fraudsters are sophisticated They using all the tools out there that they have their hands on to create urgency, exploit trust and manipulate emotions. When fraud is suspected, time is of the essence. Immediate communication with banks and investigators can stop transactions and increase the likelihood of recovering funds. Time is of the essence to make those reports as quickly as possible. In conclusion, House Bill 560 represents a measured and practical step forward in strengthening fraud prevention efforts. It provides financial institutions with additional tools to intervene when warning signs appear, while preserving the core principle that customers must have timely and dependable access to their money. The Ohio Bankers League appreciates the sponsor's leadership and willingness to work with stakeholders. We look forward to continuing collaboration to ensure the final legislation protects consumers while supporting the safe and effective operation of Ohio's banking system. Thank you for the opportunity to testify. I'd be happy to take any questions.
Thank you very much for the questions of the witness. Thanks for coming in.
Thank you.
Our next witness is Ben Webb with AARP Ohio to provide proponent testimony. Welcome. Thank you.
Chair Olslegger, Vice Chair Pazuli, Ranking Member Russo, and members of the House Financial Institutions Committee, We thank you for the opportunity to provide proponent testimony on House Bill 560, Protect Our Parents Act. My name is Ben Webb, and I serve as an associate state director for AARP Ohio. AARP is the nation's largest nonprofit, nonpartisan organization dedicated to empowering Americans age 50 plus. To choose how they live as they age, with a nationwide presence, AARP works to strengthen communities and advocates for what matters most to more than 100 million Americans, 50-plus, and their families, health and financial security, and personal fulfillment. ARP Ohio is here today in support of House Bill 560. This legislation is a measured approach to providing protection from financial abuse and exploitation, a scourge that is traditionally underreported. In 2024, the FBI's Internet Crime Complaint Center, IC3, reported receiving 147,127 total complaints from individuals over the age of 60. This is a 46% increase from 2023. This group lost $4.885 billion in 2024, which is 43% more than what the same group lost in 2023. The report and hold language known here as Protect Our Parents Act is one of the most effective ways to stop the scam and abuse. by empowering financial institutions to protect accounts before the funds leave and providing means to ensure effective investigations will certainly protect our parents and with the possible sub-bill even more Ohioans. Another key provision of the bill that we not only fully support in theory but also in practice is requiring training for frontline workers who interface with their community. A recent AARP survey reported that 72% of older adults responded that their financial institution was at least somewhat helpful in helping them resolve issues caused by exploitation. Over 60% of adults are more likely to trust their financial institution based on how it responded when they were exploited. In partnership with over 2,000 industry professionals, ARP has developed a training platform that combines industry knowledge and experience with state-of-the-art online learning experience. The Bank Safe Initiative focuses on four key areas. Preventing financial exploitation empowering family caregivers helping those with dementia and making banking tools and environments easier to access The BankSafe training platform is designed specifically for frontline staff, call center representatives, financial advisors, supervisors, and risk management officers who are at the forefront of the fight against financial exploitation. BankSafe provides the best, most current, and engaging training available to protect older consumers and empower the financial industry, namely frontline staff. Institutions who verify that 80% of the frontline staff have successfully passed training and have proper compliance policies are eligible to receive the BankSafe train seal to use in their marketing. As a member of the Ohio Attorney General's Elder Abuse Commission, we plan to work with the Commission to further incorporate this impactful and free resource into communities across Ohio as soon as possible. For those interested in learning more about Banksafe, I've included a live link in the written testimony named Snapshots, Banks Empowering Customers, and Fighting Exploitation, which highlights ARP's research and provides case study examples on promising practicing for banking. Lastly, there are two areas of concern that we believe an upcoming sub-bill will address. We believe it's important for customers to have a defined time frame in which to receive an answer. Language that limits the amount of time the institution is able to hold funds to 60 days is fair. Secondly, currently a bill requires courts to hold funds in dispute for 30 days, which would be concerning if the rightful owner of said funds needs to pay living expenses, like rent or prescriptions and have no alternative funds available. Giving courts the discretion to release these funds is important. House Bill 560 provides customers with essential protections that allow their trusted institutions to participate in their financial safety. Knowing the frontline workers are trained to spot nefarious activity and how to address it provides yet another way to complement our continuum of anti-fraud measures, like House Bill 648, that safeguard financial security and ensure Ohioans can confidently save and choose how they live as they age. Thank you, Representatives White and Swearingen, for your leadership on this issue. I appreciate the opportunity to offer testimony on behalf of ARP Ohio. Thank you for your time, and I would welcome any questions.
Thank you very much for the questions of the witness. Thanks for coming in.
Thank you.
Is there anyone here today that's in the audience that wish to provide testimony in House Bill? 560. This concludes our second hearing on House Bill 560. I will now call up House Bill 534 for its third hearing. I'd like to invite Mark Dan with the National Association of Consumer Bankruptcy Attorneys to provide opponent testimony. Welcome, Mark. Thank you, Mr. Chairman.
If I can just take a minute of privilege on the previous two bills. Our office is flooded with calls from senior citizens scammed, taking money out of banks, putting them into ATM, Bitcoin ATM machines. We've brought dozens of lawsuits on this issue. It is a real and serious problem, and I urge this committee to address it expeditiously because there are lots of people losing lots of money, probably as we're standing here today. Thank you.
Thank you, Mr. Chairman.
Chairman Olsseger, Vice Chair of Pizzoli, Ranking Member Russo, and members of the Financial Institutions Committee, thank you for the opportunity to present opposition testimony to House Bill 534. Both as a former Attorney General and in private practice, I've dedicated my career to protecting consumers from financial predators, including those in the debt settlement industry. This year alone, we have brought multiple lawsuits against debt settlement companies and their affiliates. I urge this committee to reject House Bill 534, which would expose Ohio consumers to unlimited fees and harm an industry with a well-documented history of deceptive and predatory practices. The debt settlement industry preys on vulnerable customers. Debt settlement is an expensive scheme that lures in desperate consumers with false promises to negotiate steep discounts on unmanageable debts. A consumer who enters a debt settlement agreement is typically instructed to stop paying their debts and instead pay the debt settlement company. Months or years later, after the company has collected enough to pay its fee, the company then begins negotiations with creditors. In the meantime, the consumer's accounts go into default, credit is damaged, businesses who deal with the consumer are unpaid, and the consumer is exposed to collection calls and even lawsuits and judgments and late fees and interest on the debts continue to accrue, and the total debt grows larger month by month. All too late, consumers learn the truth that the promises of the debt settlement company has made has just made matters worse. People facing unmanageable debt are particularly vulnerable to aggressive marketing tactics and inflated promises of debt relief. It is difficult for consumers under financial stress to judge the relative benefits and risks of debt settlement as compared to other options, including bankruptcy. Chapter 13 bankruptcy is a debt settlement plan. The choice is made even more difficult when debt settlement companies mislead consumers about relief that they can obtain and the risks that are involved. Many major creditors refuse to work with debt settlement companies. Many of the nation's largest credit card companies, including Chase, American Express, Synchrony, Macy's, and Discover, simply refuse to work with debt settlement companies, providing no relief to the consumers who are hoping to address their debts. Even worse, consumers may be charged the debt settlement fee even when they've been forced to negotiate their own debts because the creditor refuses to work with the debt settlement company or because the consumer faces a collection lawsuit. In our experience representing consumers who have been misled by debt settlement companies, consumers believe their debts are being handled and defended, but when creditors refuse to work with debt settlement companies, they often sue and take judgment against those consumers. Consumers frequently do not find out until their home has been leant, their bank account attached, or their wages garnished. HB 534 would eliminate vital fee protections for Ohioans. So far, Ohio's been spared some of the worst abuses of this industry because our state law wisely imposes a cap on fees debt settlement companies can charge, a sensible 8.5% of any debt settled. But this greedy industry wants even more, and their full-time lobbyists have been working hard for years to achieve this goal. HB 534 would eliminate Ohio's fee caps and instead impose no specific dollar or percentage amounts on what debt settlements may charge customers. The bill purports to require performance-based fees, but unlike current law, HB 534 contains no ceiling on the actual amount that may be charged. Under current law, fees cannot exceed 8.5% of the debt settled. Under HB 534, there is no such limitation. Eliminating the fee cap would hurt both borrowers and lenders because it would decrease the amount of money available for settlement increase the time it takes to save enough money to begin negotiations and reduce the chances of settlement at all By encouraging customers not to pay their debts for months or years while money accrues for settlement, the debt settlement industry increases and prolongs consumers' exposure to continued collection calls, damage to credit, and debt collection lawsuits. Debt-burdened customers are far better off keeping control of their money and negotiating directly with their creditors, rather than paying a third-party debt settlement company to skim an even larger portion of their meager funds to settle debts. In addition, the debt settlement industry has a history of deception. Some of the largest operators in the industry have lied to consumers and violated even modest procedural consumer protections imposed under federal law. For example, the Consumer Finance Protection Bureau charged that Freedom Debt Relief, a founding member of the American Fair Credit Council and one of the largest debt settlement companies in the country, billed consumers without settling their debts as promised, charged consumers after having them negotiate their own settlement with creditors, and misled consumers about the company's fees and its ability to negotiate directly with all of a consumer's creditors. The Freedom Debt Relief lawsuit was settled with a multimillion-dollar restitution order and an order for the company to follow the law in the future. The CFPB found that Freedom Debt Relief lied to prospective customers about its ability to negotiate with creditors who knew it refused to deal with the company, including Chase, American Express, Discover, Macy's, Synchrony Bank, and other creditors known to have policies against working with debt settlement companies or with track records of repeatedly refusing to negotiate with freedom. Given this history, there is no reason to trust the empty promises of the industry's trade group to adhere to, quote, best practices as urged by lobbyists. Federal regulations are not sufficient. HB 534 relies heavily on compliance with the FTC's telemarketing sales rule. However, unlike state law, federal law only regulates the disclosure of fees and imposes no substantive limits on the fees a debt adjuster may charge. Under this framework, a debt adjuster could theoretically charge unlimited fees to desperate customers so long as those fees were disclosed. Customers targeted by debt settlement companies need the protection of state law, including the fee cap. In fact, the FTC rules contemplate concurrent enforcement and complementary regulation by state regulators. Only state regulators can rein in exorbitant fees charged by debt settlement companies. A better path forward would be to reform Ohio's debt collection laws. If the legislature is truly interested in providing relief to working families burdened by debt, perhaps a better starting point would be to revisit our antiquated debt collection laws. While such states as Texas ban wage garnishment for most consumer debts, Ohio law permits creditors to seize 25% of a working person's wages to satisfy a debt. Our state exemptions fail to adequately protect cars and homes. With the highest wage garnishment rate in the nation, desperate customers facing a significant loss of income or loss of their sole means of transportation, and in many places in Ohio, losing your car means losing your job, as we all know. are driven into predatory debt settlement contracts or bankruptcy. Reforming our debt collection laws by reducing or eliminating wage garnishment increasing protections for cars and homes would be a great relief to struggling working families in these challenging times To unleash the debt settlement companies to exploit consumers economic pain by charging unlimited fees for services of dubious value would be a step in the wrong direction House Bill 534 would harm Ohio consumers by allowing an unscrupulous industry with a history of misleading and abusive practice to charge unlimited fees for service of a dubious value. Removing the cap on fees charged by debt settlement providers would provide consumers no benefit while exposing them to great financial risk. I respectfully urge this committee to reject House Bill 534 and consider other methods to protect debtors in the state of Ohio. And a number of opponents of the bill could not be here today, and there is written testimony from the National Consumer Law Center, from a nonprofit group of debt settlement nonprofits. I urge you all to read those because they raise other great points of concern with this bill. And with that, I'm happy to answer any questions the committee might have.
Thank you very much. Questions to the witness. Representative Rousseau.
Thank you to the chair. Thank you, Mr. Dan, for being here today. It's always good to see you. So as I'm trying to understand this, and I've tried to get my head around this for the last couple of months, would you say that the most vulnerable period here for potential damage to the consumer is when they have essentially stopped paying, interest is accruing, the debt settlement companies are presumably beginning negotiations with the creditors, and you point out some that may not work with these debt settlement companies. Then, of course, the customer realizes that the debt settlement is not going to work for them. But in that period of time, they have still been left open to nonpayment fees, penalties for non-payment interest. Am I understanding that correctly, that that is a particularly vulnerable period of time? Chairman Olslaeger, Representative Russo,
you're absolutely right. The big risk that we see in our office is judgments. It is, you know, courts, and talk to any municipal judge in your district, the bulk of their docket is debt collection cases. There are literally hundreds of thousands of those filed every year in Ohio. Consumers who engage with one of these debt settlement companies feel like they're solving their problem, and they are relieved and have the expectation, and sometimes encouraged by salespeople for these companies on the phone and on the Internet that will tell them anything to get them to sign on the dotted line, that these debts are being handled and dealt with, including defended in court. So even when they get sued by a company, they don't necessarily reach out and call a lawyer or go to court and defend their case. Those cases end up going to judgment. And once it goes to judgment, there's nothing a debt settlement company can do. They're stuck with that, and that judgment's accruing even more interest. So, yes, that's the vulnerable time. And it doesn stop credit reporting and it doesn stop interest from accruing on these debts And so what you end up with people with a bigger mess at the end of their engagement with a debt settlement company than they had when they started
Okay, thank you. Representative Zuli.
Thank you, Chair, and thank you for coming in, sir. I think I could speak for all the members when I would say we're all trying to help people, right? And you as well, I think all of us. We're trying to help families. And so what happens in this instance, the instance where maybe bankruptcy isn't necessarily successful, where it doesn't work, is that really the ultimate solution? We know that in a significant amount of cases, bankruptcy doesn't resolve the situation. So what options, in your opinion, are left for individuals who might be thinking about this as we consider this bill? Thank you.
Mr. Chair, Representative Pesui, I'm not sure where your information is coming from about bankruptcies, but for people under the median income in the state, a Chapter 7 bankruptcy would allow them to simply discharge all their debts. So there would be no negotiation. there would be, as long as they were without assets, trustees appointed to determine whether or not they have assets to pay their creditors. And if they don't, then they'll be discharged. If they do, those assets will be seized by the bankruptcy court and distributed to creditors. It's a system that's worked for 100 years in this country, and honestly, it's embedded in the Constitution, and the forgiveness of debts every seven years is in the Bible. This is something that's not new. In a Chapter 13 setting, for people above the median income, they have the ability to repay a percentage of their debts over a 60-month period. And honestly, if they're unable to complete that plan, then the bankruptcy court won't approve it, and then they're left to their own devices. If you limited, I suppose if you limited debt settlement companies to people who didn't qualify for Chapter 13 bankruptcies, which is a very, very, very small percentage of people. You can actually file, but you have to be able to demonstrate the financial ability to meet the terms of the plan. And the plan is based on, they look at your income and apply certain standard, kind of like federal tax returns, federal standard exemptions. How much should a family afford to spend for food, for daycare, for all these other things? And they only use the disposable income that that person has to pay those creditors. So if the disposable income leaves only 1% of the ability to pay 1% of unsecured debts, then 1% is what gets paid over 60 months. It is always geared to the ability of the borrower to make those payments. And it's overseen by a federal judge with the power of subpoena and perjury rules. None of that applies to the debt settlement industry. Mr. Pizzou, follow-up?
Thank you, Chair. Thank you for that follow-up. I guess my point is just that going through bankruptcy, that's a pretty big process, right? And it might not be a fit for everybody. I mean, to avoid that, you can't get a loan for the next seven years. I mean, to go through other alternatives, you know, why rule out all other, you know, possible things that could help people?
Mr. Chairman, Representative Pizzulli, actually, people's credit score actually improves after a discharge in a Chapter 7 bankruptcy and often improves and certainly would improve at the end of a Chapter 13. Look, a Chapter 13 bankruptcy is saying somebody committing under oath to take 100 percent of their net disposable income and use it to pay their creditors for the next five years. That means no movies, no dinners out. And so anybody who is serious about paying their debts, that provides a very safe and monitored way for them to be able to do that, with the protections of a federal judge overseeing the whole process. Okay.
Representative White.
Thank you, Chair. Thank you for your testimony today. I have wanted to follow up with a question going back to 2010. Didn't the FTC consider a cap at that time but did not include it?
Chairman Oslager, Representative White, it may have, but I know it's not included. I can tell you that the FTC rules are about disclosure. And disclosure is a good thing. But a cap is an absolute protection for Ohioans that would not exist if you pass this bill.
Representative White, follow up. Yes, so that was pretty much my question about the cap not being there, and also follow up that this program is voluntary, so then people are coming in, they're choosing to be a part of this program being explained. And so from what I'm understanding, they are explaining that they still have to make payments until that settlement is, until there's a settlement agreed upon because until they sign off, that there is not, they just don't stop making payments. So I'm not, for this I'm a little unsure. I do understand what you're saying, but for this, that settlement that I've been working on and going back and forth, that's why I'm taking everything in you're saying very seriously, is that, that was one of the things that we worked hard on to make sure that consumers are aware of what their rights are, where we're working on it, because they can also come back and say, no, I don't like that settlement. So if they have the right to say no and we have to keep moving forward, then it allows also that time that they continue to make payments in order to not fall into credit disrepair or where it's unrepairable. Mr. Chairman, Representative White, consumers can, anything that a debt, Settlement companies able to negotiate, a consumer can negotiate for themselves should they choose to do that, and without having to pay a fee of 8.5 percent or any amount to the debt settlement company. That's one. Two, in the bankruptcy court, which is accessible, people can file pro se bankruptcies as well. the percentage that they pay back on each of their debts would be governed by the available cash that they have. And that's fair to everybody. That's fair to the creditors. They're going to get their share of the available funds that that family has for five years if they're over the median income in the state. If they're below the median income, Chapter 7 is always 100% better than a debt settlement process. Reb. I just have one follow up if I could ask also For putting this together I know there are many people when it comes to filing for a bankruptcy there are certain debts that can't be included. And so, and there's also, if you think about timeshares, and you think about school loans and things like that. So there are also certain credit card companies that don't allow you to file, you can't file bankruptcy on everything. And so this gives people the option that also don't want that on their credit report, want to move forward. So is for this being an option that people can voluntarily choose, I'm just trying to understand why it's not, why couldn't it be an option for people to voluntarily choose on top of consumer credit counseling, filing bankruptcy, all of those things honestly have a negative impact, but we're trying to move people, choosing which impact is best for their lives and their situation or their income, and then working with the consumer, not on the cost of people, to be able to get back on track financially so they can move ahead with their lives. Chairman Elslager, Representative White, all debts are subject to the bank to discharge in bankruptcy, except for those that are specifically exempted by Congress, and that includes most student loans. However, even under the current administration, we are regularly negotiating discharge of student loans in bankruptcy. So it's happening on a regular basis. The Department of Education uses the bankruptcy court with all the sworn testimony that's in front of it to be able to determine the ability to repay of those borrowers. And some people just aren't going to be able to do it. And so there have been frequent and regular bankruptcy discharges of student loans. Now, this is new. This is in the last couple of years. And we were concerned that it wouldn't continue in the new administration, but it has continued in the new administration. And the Justice Department is negotiating and standing down on those loans. There are no private loans that are not subject to bankruptcy discharge. So that's just not accurate. Representative White. That was all my questioning. Thank you. I appreciate it, Chair. Thank you. Thank you very much.
Other questions to witness? Representative Miller.
Thank you, Chair, and thank you, Mr. Dan, for your testimony today. My question is, is if there were a fee cap imposed and greater transparency, I guess, in your eyes, would you be supportive of this legislation?
Mr. Chairman, Representative Miller, I would think there would have to be – there's another piece of this that is addressed in some of the other testimony that's in writing that I – not my – I didn't include it because it was already there. and that is that this creates an exemption from the Consumer Sales Practices Act for these debt settlement companies, and it creates exceptions for lawyers acting as debt settlement companies, and I think those propose some real risks. So if there is sufficient disclosure and there is the ability of – and almost every debt settlement contract includes a binding forced arbitration agreement. So if and I can share some amendment language that would allow people to opt out of those arbitration agreements in that setting But that prevents cases from being brought in court under the Consumer Sales Practices Act So right now debt settlement companies are subject to our very strong consumer protection laws in Ohio. This bill would exempt them. So there would have to be some other changes in the bill for us to be able to support it. But is there a world in which we could find a way to support this bill? Absolutely.
Representative Miller, follow up. Yes, thank you, Chair. I guess what I'm struggling with is my colleague's comment that says this is just another option, and I guess in my eyes that's what I see. This is just another option for folks. Ultimately, at the end of the day, if it doesn't work, my assumption is it would end in bankruptcy, which would ultimately end in representation by your firms. So I guess I'm looking at the greater picture here and just wondering why there would be such opposition to another option, I guess.
Mr. Chairman, Representative Miller, because the bankruptcy option is it provides so many more benefits. It's it's it's it has the best disclosure that one can have in the world. It's penalty of perjury disclosure. Everybody files their information publicly in bankruptcy court and under penalty of perjury, and it's being arbitrated by a federal judge with a 12-year appointment that's not subject to influence by anybody. There is lots of evidence of misrepresentations that have been made by these debt settlement companies to get people to sign up for this. and that is the kind of thing that just doesn't, is really impossible to happen. And I'm not suggesting, people also, and friends of mine, I lost my job suddenly 20 years ago or so, not quite 20 years ago in a way many people here are aware of, and I had to negotiate my debts directly with creditors because I wasn't in a position to pay. It happens. Things happen in people's lives. But to add additional mouth to feed while risking getting a judgment against you and a garnishment on your already not going far enough paycheck, I think is too great of a risk. And I don't think that risk is properly understood and properly explained in the process. Is there some disclosure that might get there? Maybe, and I'm open to trying to talk about it. But I think this is a solution in search of a problem. I don't know that this industry, unless it's really carefully regulated. Oh, by the way, that's one other change, Representative Miller, I'm sorry, is the oversight would go to commerce, which is really very shorthanded when it comes to oversight of financial institutions. and shift from the Attorney General's office, who oversees the Consumer Sales Practices Act, and has the ability to issue rules for this industry as well. So you're taking it out of the hands of the consumer protection lawyers and handing it over to an understaffed agency at the Department of Commerce. In my view, that's only going to make it less safe for people. So there's a lot of pieces of this bill that need attention.
Representative Miller? One final question Thank you Chair I guess ultimately my question would be would you see these debt collection services or agencies as a competitor to the bankruptcy industry
Chairman O'Slager, Representative Miller, honestly, they've been a boon to my law firm because we sue them all the time. And they do so many deceptive acts that, frankly, they're great for me. It would be terrible for my business if these people were properly regulated. unfortunately. And look, everybody's got – there's a place for everything in – I'm sorry, let me start over again. I apologize. I don't see this as competition. I don't know bankruptcy lawyers that do. I think what they see is a problem that actually ends up landing more people in their office at the end of the time than would have otherwise been there if they had tried early on to negotiate their own debts without all these additional hurdles that are put in place. And a lot of the clients, by the way, that we represent against debt settlement companies are Chapter 13 and Chapter 7 trustees who have assumed that that that well, that's actually an asset of the estate, the claim against the debt settlement company. And we've actually gotten proceeds that have been used to pay other creditors when we've been successful at bringing cases against the debt settlement companies. So I don't see it as competition. It's a very different thing, and you just can't compare something like this full of deceptive promises to an under-oath system that's transparent.
Thank you, Chair.
I just wanted to ask one question when you said that, because going back, and thank you again, when you said right now the way things are that there are a lot more people filing and having to go back and forth, I'm just wondering, wouldn't that make it better then for it to go and be regulated under the Department of Commerce? Commerce because right now if we're having those many people coming in and you know having these issues that means that a switch from who is supposed to be taking care of consumers will be better under the Department of Commerce and then we work on making sure that is properly staffed or right-sized. Chairman Ouslager, Representative White. The Department of Commerce doesn't have the resources or the lawyers to bring the enforcement claims. The Attorney General has the ability to bring enforcement claims and to make rules that can guide these companies. I mean, you can't. Somebody who's out, as we've learned this morning or this afternoon from the previous two bills, people are out there committing, you know, if somebody's out there trying to deceive somebody, it's pretty hard to stop them. But the question is, what are the remedies when somebody's been deceived and how can you remedy those things? You take this away from the Consumer Sales Practices Act and not give borrowers or give these customers, consumers, a right of action if they've been deceived by these folks. Let's assume that some don't deceive them, but those that do ought to have to give the money back to the consumers and pay them for the damage that they've done to their lives and to their finances. Mr. White. Thank you, and I have one follow-up. This one will be more like what you think, or what you believe. So my question is, with consumers, even I can speak for myself, I do not know how to negotiate with a credit card company. I would use consumer credit counseling or death settlement because I wouldn't want to have bankruptcy, which is very negative for women, so that's why we don't file. And thinking about that, I'm not sure if consumers are not, if they can be taken, if we're saying that they're also having a problem with this, then I don't understand how then they feel empowered then to go out and resolve their own debt solutions with a credit card company because there's always has to be somewhere to help you do that. And so if we're saying that they're gullible, I hate to use that word, but kind of what we're saying if they're able to fall into these traps for someone that's more sophisticated, which we're trying to make sure that doesn't happen with this bill, then how would we assume that they're able to go out also then and resolve their own debts? Mr. Chairman, Representative White, this is a perfect segue, hopefully, to the next witness. So we have somebody here from one of the nonprofit credit counseling agencies. They're out there. They're available in every community in the state. that's an alternative that makes perfect sense. They're not there to make a profit. They're supported by foundations and by contributions, and there's no profit motive there at all. I mean, there's another piece of this bill, by the way, that I didn't even mention, but it's mentioned in some of the other testimony. This also, Bill, would allow these debt settlement companies to originate new loans for borrowers. So all of a sudden, not only are they advocates in debt settlement, but they're also going to get a commission for helping to originate a new loan for those borrowers. I mean, this is a cutthroat business, and it needs really strict oversight and regulation. And I hope that this committee will appreciate that. I understand it's hard to sort all this stuff out. I've sat on the other side of this, and I know there's a lot to learn, and you can't know everything about every industry. But I would look very skeptically at the business practices of the for-profit debt settlement companies in this state and in this country. Just for me, then it is that a lot of consumers do need someone, like whether it's a debt settlement company or whatever, to help them because it is very hard. Then for consumers to get their debt. There is an issue with debt in this country. as we know it's growing. And there is an issue also that a regular consumer does not know how to negotiate or can you negotiate or how to do any of that with a credit card company or otherwise so that we do have to have something in place as a choice for people to work through to have that happen because I don't think any consumer has been on their own unless you're already in the rears and it's already showing up on your credit card statement and you're getting everything in the mail that's saying you are delinquent, we're gonna start reporting, that's when they'll settle with you. But if you're trying to do that or be proactive beforehand, there's only so many choices that you have. So this, again, is a choice and I'm listening, but I still go back to the fact that consumers aren't able, they don really have the knowledge or the impact either to go back to any credit card or credit agency and say I want to settle my debt unless they already in serious default Mr Chairman Representative White the nonprofit agencies will assist and coach consumers in negotiating their debts as will lawyers. If people can afford lawyers, lawyers can be retained to do that negotiation. If they can't afford lawyers, every legal aid in the state will accept people in high debt and refer them to pro bono lawyers or handle their debt negotiations internally in legal aid. We are blessed in Ohio, and you'll see legal aid is also weighed in in opposition to this bill in the state. We are blessed with a great network of legal aid organizations in every corner of the state. And I've had the privilege, both as AG and in private practice, of working with every single one of them. And they are accessible, and they're available, and they are free, just like the credit counseling agencies are free. So there's a lot that's out there that's not driven by profit. And that's where the conflict of interest arises. No lawyer is allowed to help a client originate a loan to pay their debts and get a commission for doing that. That would be disbarrable. Right. Thank you, Chair.
You're welcome.
Thank you for it.
Thank you, Mr. Chairman. Thank you.
Appreciate everybody's attention. Thank you.
That is a good segue because Kelsey's going to hand out some material to our next witness, who's Todd Moore with Trinity Credit Counseling. Mr. Moore has submitted testimony on time, but he realized he had to make an adjustment. So we got it, and we're going to make sure all the members have a copy of it. Welcome.
Thank you. And Mr. Chairman, I appreciate you accepting that into the record. Dear Chairman Auslager and honorable members of the Financial Institutions Committee, my name is Todd Moore and I am the Director of Education at Trinity Credit Counseling, a non-profit credit counseling agency located in Cincinnati, Ohio, that has served financially distressed Ohio families for more than 30 years. We work to help families eliminate unsecured debts and work with non-profits, banks, and credit unions to improve credit capacity for low-moderate income borrowers. We also work to promote policy goals such as homeownership and minority small business development. For more than 17 years, I have counseled families on debt management issues and worked to improve access to credit in underserved communities across Ohio. I want to thank you for the opportunity to testify before you today. Trinity Credit Counseling is opposed to House Bill 534 because it would eliminate the fee cap that has protected Ohio consumers from excessive fees charged by settlement companies to consumers who are at their most vulnerable. As an organization, we have seen the impact of excessive fees and how settlement practices often weaken the ability of consumers to improve their credit. The current 8.5% cap is sufficient, especially when one considers that very few consumers actually settle the accounts they enroll with a settlement company. As far back as 2010, the Government Accounting Office estimated that only 10% of consumers settled most or all of their accounts. It is doubtful that completion rates have improved since the report was issued because little in the industry has changed since then and regulatory oversight is still virtually nonexistent The FTC does not actively regulate debt settlement companies nor do they cap fees in Ohio as under the Debt Adjusters Act While we would like consumers to have choices in the market for debt management services, as was argued by the Columbus Chamber of Commerce in their testimony before the committee, the practical reality and the data regarding debt settlement practices is one of frustration and confusion. Chamber President Derek Clay testified, and I quote, Ultimately, House Bill 534 is about balance, protecting consumers, supporting fair-minded businesses, and strengthening the economic foundation that communities like ours depend on. When consumers have access to trustworthy options, everyone benefits. The reality is consumers who come to nonprofit credit counseling agencies like Trinity, after having ended doing business with a settlement company, report that they thought their bills were being paid or that a settlement company had already negotiated or paid off their debt. But they were unaware that they could be sued at any time, nor did they see the significant damage that was being done to their credit after being advised by settlement companies not to make payments to their creditors. These are hardly the trustworthy options that the Chamber believes is practiced. And perhaps the most egregious problem with debt settlement practices is that a borrower can settle outstanding debts under Ohio's statute of limitations on debt collections themselves without paying any fees, which is the way we counsel our clients that need settlement options. So increasing fees under the current proposal only seems to move in the wrong direction. Therefore, rather than repealing the Debt Adjusters Act, we would argue for changes that meet the practical realities of Ohio families and the need for debt settlement services, but balance the fees and protections of other states and federal agencies have done. And I'm just going to go through a range of these for the committee. For instance, fees under the federal bankruptcy provisions are capped at $50 as reasonable or in line with 150% of the federal poverty line. The committee could also look at state fee caps for settlement services as between 15 and 25 percent charge when an account is settled, not promised to be settled. These are the fees in states such as Kentucky, Indiana, Virginia, Texas, and many other states. The committee could look at federal credit counseling fees, which are capped by the IRS at $50 per month to manage accounts. The point that I'm trying to make is regardless, as a policy, a fee that is percentage-based rather than performance-based is best to serve Ohio's families and less arbitrary for consumers. We would like the committee to rethink the process and use other state and federal fee examples as you write or revise House Bill 534 and not allow unclear or unlimited fees the settlement companies are asking you to approve in the bill's current form. And for these reasons, we would request a no vote. And I thank you for your time and ability to testify, and I would look forward to any questions that you may have.
Thank you very much. Other questions of the witness? Thanks for coming in.
Mr. Chairman, may I respond to a couple of comments? There were several comments here. I found many of these comments very, very interesting. There were questions about options for our consumers and whether that is a good option through a debt settlement One thing I would ask the committee to think about and I want to speak on behalf of just practicality as someone who practiced in this area for many many years, more than 17 years. So when we think about a borrower that is having hardship, we don't think about this as a continuum. So when a borrower comes in and they're looking for an option, they don't want to go through a bankruptcy, but they are looking for an option. If they enroll in a settlement company, what typically will happen there is the same rules will apply under the Fair Credit Reporting Act. So all sorts of other, in terms of your credit report, these things have to be, I didn't see a lot listed in the bill itself and how that plays out for our consumers. Let me be specific. So if a person is in excessive debt and they're looking for an option, there are only so many options. If they can't get a consolidation loan because their credit score is already, their capacity is too high, they're carrying too much debt, that option is not available. If they go through a process where they're looking at a debt settlement option, in most cases, families that enroll in debt settlement have already had charge off. So that's 90 to 120 days where accounts are written off as bad debts. And at that stage, that's where I wanna focus our attention now. At that stage, when it's in the charge-off status, that's why I referenced the statute of limitations in Ohio being six years on unsecured debts. So at that point, what would typically happen is if someone enrolls in, let's say that they're six months delinquent, they enroll in an option for debt settlement. Typically, and I know in the last committee here in Kentucky was referenced, I work with a lot of families out of Kentucky, typically what will happen is they will start going into a debt settlement process and then realize that they're not making much progress. They'll withdraw from that program, and that's when I begin to do counseling at Trinity Credit Counseling. That's when we see them. But the damage to their credit score is already done, and the same rules that would apply under credit scoring would apply regardless. So the damage oftentimes that we see is that we can't buy time. Once we have that opportunity cost gone, we could have offered other options, but as an option, debt settlement tends to be costly. And also, we come to find out that they've spent six or eight months in a program trying to raise funds to pay off debts, where we could have worked with them and counseled them to take the funds that they have and actually presented a lump sum payment to settle those accounts without paying excessive fees. So it's that fee-based structure. Also, I know that the current structure that we have at 8.5%, it is a reasonable fee. When we look at other states, they have raised those caps. There's a whole range of other states where they look at the caps. But the weakness that I see here is just completely eliminating the fee. I think the goal here is to try to provide a remedy for consumers who are indebted. We want to look for various remedies. But we also have to think about what that implication truly is. You know, if it's accepted in its current form, we're carving out an exception for the private market that none of us in the public sector who are serving consumers, we don't have these same rules apply to us. So it's somewhat an unlevel playing field at that point. Already, in terms of our business practices, we're confined by IRS and $50 caps in the state of Ohio. Under these rules, what we do is we open up an entirely different set of rules and no percentage is listed, at least in the current form, that the private sector or debt settlement would work under that others who are serving our communities, and it's two different sets of rules. I would just ask the committee to take that into consideration. Thank you very much.
Thanks for coming in. Thank you. Is there anyone else today in the audience that wanted to testify in this bill? Seeing none. Remember, members, before I adjourned this out, that there are other written testimonies in your iPad you want to take a look at. Since there aren't anybody else in the room, this concludes the third hearing of House Bill 534. Seeing no further business before the committee, the House Financial Institutions Committee stands adjourned. Thanks for coming, everybody.