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Trying to figure out whether collection agencies and firms qualify as "essential businesses" feels like one giant puzzle. Thankfully, states are trickling down specific guidance—New Mexico, West Virginia, and Arizona being the most recent.

New Mexico

According to New Mexico's Director of the Financial Institutions Divisions in a memo dated March 24, 2020:

For the purposes of the current public health order, all depository and non-depository financial institutions licensed and regulated by the Financial Institutions Division are considered “essential businesses” and may remain open.

However, the memo also discusses that just because a business is essential, it doesn't mean that it's business-as-usual. The memo advises essential businesses to minimize operational staff, void in-person contact, direct employees to wash their hands, and clean all surfaces frequently.

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West Virginia

The Governor of West Virginia issued an executive order on March 23, which allows essential businesses to stay open. The order explicitly lists "professional debt collectors and related creditor service workers" as essential.

Arizona

Arizona's governor issued an executive order on March 23, 2020, which clarifies what is deemed an essential business. Under the financial institutions category, the order lists banks, consumer lenders, and "affiliates of financial institutions."

We will continue providing updates as further clarification comes through from other states.


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