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[Music] welcome to the debt collection drill the video cast featuring Mason Barnett shareholders John Rossman and Mike ponson providing Sage tips for collection and compliance [Music] welcome to another episode of the debt collection drill my name is Brad Armstrong Im an attorney with moss and Barnett Im here with my colleague Mike etmund today were going to chat about policies and procedures and privacy legislation thank you Brad I look forward to it uh so getting started with policies and procedures the first thing we typically think about when we talk about reasonable policies and procedures is the Bonafide air defense under the fdcpa which basically says that a debt collector cannot be held viable in an action uh if it can show by a preponderance of the evidence that the violation was not intentional and it occurred notwithstanding the maintenance of policies and procedures that are reasonably adapted to avoid the error asserted by the plaintiff now courts generally hold that d