DECLARATION OF MICHAEL JARED MARSH PURSUANT TO 28 U.S.C. §1746

Sep 16, 2026

Declaration of Michael Jared Marsh pursuant to 28 U.S.C. §1746, describing his personal knowledge of complaint-related events tied to loan servicing for tribal lenders. The statement explains a rise in calls from non-customers alleging abusive collections by debt collectors claiming authority for tribally owned lenders, without records of such collection attempts by the servicing entity. It outlines creation of a tracking system, transfer of spreadsheet data to the FTC, identifies alleged Delaware Solutions/Clear Credit Solutions entries and referenced trade names, and describes cease-and-desist letters sent to address unauthorized debt collection activity.

LanguageEnglish

CategoryLetters

FormatPDF

Pages12

Reading Time4 min

AccessFree to download

Declaration of Michael Jared Marsh

Background and role

Unauthorized collection call pattern

Data tracking and transfer to the FTC

Identified entities and trade names

Cease-and-desist letters and asserted authority

Case 1:15-cv-00875-RJA-JJM Document 2-16 Filed 10/05/15 Page 2 of 28 DECLARATION OF MICHAEL JARED MARSHPURSUANT TO 28 U.S.C.§1746 I,Michael Jared Marsh,hereby state that I have personal knowledge of the facts as setforth below.If called as a witness,I could and would testify as follows: 1. I am a citizen of the United States and am over eighteen(18)years of age.I live in PrairieVillage,Kansas. 2. I am a practicing attorney,admitted in the States of Missouri and Kansas.From January 20,2009 until February 28,2015,I held the position of General Counsel at AMG Services,Inc.(“AMG”).Beginning on March 1,2015 to the present I have provided legal counsel toAMG as an independent legal advisor. 3. AMG provided loan servicing for a number of entities,wholly owned by federallyrecognized Indian Tribes and engaged in extending online,short term,small dollarconsumer loans.As General Counsel,I assisted management in monitoring and resolvingcustomer complaints and human resources issues,as well as coordinating with outside legalcounsel regarding regulatory compliance and pending litigation. 4. In early August 2014,a floor manager from one of the AMG customer servicedepartments came to my office to bring to my altention that an increasing number ofphone calls the customer service representatives were receiving were from non-customersand customers complaining about abusive collection calls from debt collectors claimingto be collecting on behalf of the tribally owned lenders that were serviced by AMG.AMG did not have any records of any collection attempts to these non-customers andcustomers. Case 1:15-cv-00875-RJA-JJM Document 2-16 Filed 10/05/15 Page 3 of 28 5. The floor manager indicated that these calls began coming into the call center beginningin late July 2014.The floor manager told me that most of these callers were notcustomers of any of the tribally owned lenders serviced by AMG. 6. AMG does not have,and never had,the authority to sell or place any consumer oraccount information it obtains during the provision of services to its tribal lender clients.Since 2008,to the best of my knowledge,AMG's tribal lender clients have never soldany of their customer or account information or placed or sold any of their charged-offaccounts to any third-party. 7. Once AMG management was alerted to this pattern of consumer calls,a system to collectand record the information was created.A form containing the name of the alleged lenderand account number,company and agent calling,the phone number on the consumer'scaller identification,any callback number,company address,and then notes about anyother details given by the consumer was utilized by the customer service representative tocollect this data.My assistant then transferred this data from the forms to a spreadsheet. 8. In late February 2015,I transferred a copy of this spreadsheet to the FTC via anencrypted file transfer protocol(“FTP”)website.At that time there were 818 entries onthe spreadsheet.Of these 818,185 entries were about Delaware Solutions,Clear CreditSolutions,or some close permutation of those names. 9. In the vast majority of the Delaware Solutions and Clear Credit Solutions entries(166),the lender was identified as 500FastCash.500FastCash is a trade name of Red CedarServices,Inc.(“RCS”).Delaware Solutions and Clear Credit Solutions also claimed to becollecting on behalf ofAdvantageCashServices,Ameriloan,OneClickCash,StarCashProcessing,UnitedCashLoans,and USFastCash. Case 1:15-cv-00875-RJA-JJM Document 2-16 Filed 10/05/15 Page 4 of 28 10. OneClickCash is a trade name of SFS,Inc.(“SFS”).Ameriloan,AdvantageCashServices,StarCashProcessing,UnitedCashLoans,and USFastCash are trade names of MNEServices,Inc.(“MNE”). 11. Red Cedar Services,Inc.is a wholly owned governmental instrumentality of the ModocTribe of Oklahoma,a federally recognized Indian Tribe located on Indian lands in theState of Oklahoma.SFS,Inc.is a wholly owned governmental instrum

FAQs

What event prompted the tracking of consumer complaint calls?

A floor manager reported that customer service representatives were receiving increasing calls from non-customers, alleging abusive collection calls from debt collectors claiming authority for tribally owned lenders.

How was the information about those calls recorded and shared?

A form captured alleged lender details, account number, caller information, and notes, which was then entered into a spreadsheet by the assistant and transferred to the FTC via an encrypted FTP in late February 2015.

What actions were taken to stop the alleged unauthorized debt collection?

Cease and desist letters were sent on behalf of Red Cedar Services, Inc. d/b/a 500FastCash and for other referenced parties, instructing recipients to stop collection activity identifying 500FastCash as a creditor and stating no authorization for third-party debt collection.

Sep 16, 2026

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