Todd, Bremer & Lawson, Inc. | Educational Debt Recovery Since 1974
T B L TODD, BREMER & LAWSON, INC. ESTABLISHED 1974

Proud Member Of & Recognized By

Since 1974

Trusted Higher-Education Partners

One of the oldest privately held corporations in the nation dedicated exclusively to third-party educational debt recovery.

HomeAbout Us

Trusted Higher-Education Partners Since 1974

Five decades of specialized expertise in campus-based collection services for colleges and universities nationwide.

From Rock Hill to the Nation

Todd, Bremer & Lawson traces its origins to July 5, 1974, when James Harold Todd and Thomas Larry Gregory founded the company as Todd, Gregory & Associates in Rock Hill, South Carolina. The Firm quickly formed a foundational partnership with Winthrop University — TB&L’s first business partner and a lasting business relationship.

Following a pivotal ownership transition in 1976, the company was renamed TODD, BREMER & LAWSON, INC., with Hal Todd, Norm Bremer, and Charles Lawson as stockholders. Hal Todd was appointed president and led the Firm’s expansion and multiple relocations within Rock Hill, reflecting steady growth and a strong commitment to the local community.

In 1989, Hal became the sole stockholder and guided TB&L through decades of transformation in the credit and collections industry. In 2022, second-generation leadership was formalized when Shannon Todd Golightly and Kelly Todd Swicord each acquired a 20% ownership interest, preserving continuity, governance stability, and long-term alignment with the needs of colleges and universities nationwide.

1974

Founded as Todd, Gregory & Associates. First partner: Winthrop University.

1976

Renamed Todd, Bremer & Lawson, Inc. Hal Todd appointed president.

1989

Hal Todd becomes sole stockholder, leading decades of industry transformation.

2022

Shannon Todd Golightly & Kelly Todd Swicord each acquire 20% ownership.

Client Testimonials

What Institutions Say

I could not be happier with the folks at Todd, Bremer, & Lawson, Inc. They respond to my many questions and have been extremely helpful in educating me about collections processes. TBandL are patient and very responsive with every interaction. They are knowledgeable about the compliance and regulatory requirements regarding collections. They go above and beyond in terms of customer service.

University of Virginia

Texas A&M University–College Station has worked with Todd, Bremer, & Lawson, Inc. since 1994. All interactions have been professional, friendly, and informative. TBandL thoroughly address any issues I may have regarding a regulation or account matter, as well as draw my attention to questions I may not have considered.

Texas A&M University

I work daily with Todd, Bremer, & Lawson, Inc. and appreciate all they do for our students and clients. I value the work they do for our department, their feedback, the way they conduct business when assisting our students and clients, and their willingness to go the extra mile for our university.

Colorado State University

HomeConsumer Access

Consumer Access

Online Payment Portal

PLEASE NOTE: You will need the reference number from your letter and your last name.

If you are in a hurry to have your hold released or if you need a transcript, DO NOT continue on this website; call our office at 1-877-427-6544.

If you have multiple accounts listed with Todd, Bremer & Lawson, Inc. and you choose to use this site, please note that your payment may be split between all open accounts.

This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose.

Please click the button below to continue.

You are now leaving Todd, Bremer & Lawson, Inc. Payments are processed through a third-party billing service. Todd, Bremer & Lawson, Inc. is not responsible for its content. If you pay using this site we can clear your account the following business day.

I Agree

PRESS I AGREE TO CONTINUE TO PAYMENT PORTAL

HomeServicesThird-Party Collections

Third-Party Collection Services

Continuously serving higher education institutions since December 16, 1974.

Our Expertise

Campus-Based & Institutional Portfolio Management

TODD, BREMER & LAWSON, INC. has provided third-party collection services to higher education institutions continuously since December 16, 1974, exceeding the required five years of experience in the recovery of National Direct Student loans and Federal Perkins loans, Health Professions and Nursing loans, institutional student loans, and other university receivables.

TB&L manages campus-based and institutional portfolios for public and private universities nationwide and maintains documented expertise in Title IV accounting requirements, student-consumer entitlement protections, deferment and cancellation processing, and federal and state compliance standards.

Operational workflows within the Flexible Automated Collection System (FACS®) collection platform support interest calculation under federal regulations, rehabilitation tracking, credit bureau reporting, and reconciliation with the creditor business offices, ensuring alignment with creditor policies and audit expectations.

Federal Perkins Loans

Full lifecycle management including deferment, cancellation, and Title IV compliance.

Health & Nursing Loans

Health Professions, Nursing, and Nurse Faculty loan recovery with specialized handling.

Institutional Loans

Private and institutional student loan portfolios managed with full audit documentation.

FACS® Platform

Federal-regulation-compliant interest calculation, rehabilitation tracking, and bureau reporting.

HomeServicesCredit Reporting

Credit Reporting

Compliance-driven credit reporting governance designed to protect institutional reputation.

Value-Added Service

Structured Credit Reporting Governance

TODD, BREMER & LAWSON, INC. delivers value-added services beyond basic third-party collections through a structured, compliance-driven credit reporting governance framework designed to protect the creditor’s reputation, ensure regulatory adherence, and reduce dispute and audit risk.

Accounts receivable balances exceeding $500 — or such lower reporting threshold as may be established by the creditor at the client level — are reported to a credit bureau repository in full compliance with the Fair Credit Reporting Act (FCRA) using the secure e-OSCAR® platform and the Metro 2® reporting format established by the Consumer Data Industry Association.

FCRA Compliance

Prior to reporting, student-consumers receive clear and timely notice of intent to report, satisfying FCRA disclosure requirements.

Multi-Layer Data Scrub

Validates identity and screens for deceased individuals, active bankruptcies, active-duty military, and other statutory exemptions.

e-OSCAR® Platform

Metro 2® reporting format. All disputes received, investigated, and resolved within required FCRA timelines.

Audit-Ready Documentation

Minimizes regulatory exposure, enhances data integrity, and delivers compliance value beyond routine collection services.

HomeServicese-OSCAR® Process

e-OSCAR® Process

A structured, auditable dispute-resolution process aligned with FCRA requirements.

Dispute Resolution

FCRA-Aligned Dispute Management

TODD, BREMER & LAWSON, INC. maintains a structured, auditable dispute-resolution process aligned with Fair Credit Reporting Act (FCRA) requirements and credit bureau standards.

Credit reporting disputes submitted through e-OSCAR® are received electronically and logged within the Flexible Automated Collection System (FACS®) collection platform for tracking and response management.

Dispute Resolution Process

1

Receipt & Logging

Disputes submitted through e-OSCAR® are received electronically and logged within FACS® for tracking and response management.

2

Review & Validation

Each dispute is reviewed against placement data, account history, payment records, and creditor documentation to validate accuracy and completeness.

3

Response Transmission

Verified responses are transmitted back through e-OSCAR® within required regulatory timeframes, including corrections, updates, or deletions where warranted.

4

Creditor Escalation

Disputes requiring creditor input are escalated promptly for review and instruction, ensuring transparent audit trails for both the creditor and the student-consumer.

HomeClient Access

Client Access

Secure portal for authorized institution representatives.

Please read the following information before continuing.

By accessing this portal, you acknowledge that you are authorized to view and manage the account information associated with your organization.

If you need immediate assistance, experience difficulty accessing your account, or require support regarding account information, please contact our office at 1-800-849-6669 before continuing.

This portal provides access to client account information and related services through a secure third-party hosting provider.

Please Note

  • Access to this portal is restricted to authorized users only.
  • Information contained within the portal may be confidential and protected by applicable privacy and data security laws.
  • Unauthorized access, use, or disclosure of information is strictly prohibited.
  • Activity within the portal may be monitored for security and compliance purposes.

By Clicking “I Agree” You Acknowledge That

  • You are an authorized representative with permission to access the portal.
  • You understand that you are leaving Todd, Bremer & Lawson, Inc. and entering a third-party hosted system.
  • Todd, Bremer & Lawson, Inc. is not responsible for the content, availability, or operation of the third-party portal.
  • You accept responsibility for maintaining the confidentiality of your login credentials and any information accessed through the portal.

Please click the button below to continue to the secure client portal.

I Agree

PRESS I AGREE TO CONTINUE TO CLIENT PORTAL

HomeServices

Our Services

Specialized collection services exclusively for higher education institutions — the TB&L difference.

What We Do

Campus-Based Collection Services

TODD, BREMER & LAWSON, INC. has provided third-party collection services to higher education institutions continuously since December 16, 1974, exceeding the required five years of experience in the recovery of National Direct Student Loans and Federal Perkins Loans, Health Professions and Nursing loans, institutional student loans, and other university receivables.

TB&L manages campus-based and institutional portfolios for public and private universities nationwide and maintains documented expertise in Title IV accounting requirements, student-consumer entitlement protections, deferment and cancellation processing, and federal and state compliance standards.

Operational workflows within the Flexible Automated Collection System (FACS®) platform support interest calculation under federal regulations, rehabilitation tracking, credit bureau reporting, and reconciliation with creditor business offices — ensuring alignment with institutional policies and audit expectations.

01

Campus-Based Collections

Focused exclusively on higher education institutions. We understand the unique relationship between schools and their students, ensuring every interaction is handled with professionalism and care.

02

Contingency Fee Model

No recovery, no fee. Our service is charged as a contingency, meaning TB&L gets paid only when your institution does. Zero upfront cost, maximum alignment of interests.

03

24/7 Account Placement

New delinquent accounts can be submitted at any time through our secure client portal. We interface seamlessly with all major third-party billing servicers.

04

Federal Loan Programs

Deep expertise in Federal Perkins Loans, Health Profession Loans, Nursing Loans, and Nurse Faculty Loans — among the most complex programs in higher education.

05

Institutional & Private Loans

Comprehensive recovery services for institutional loans, private education loans, parking obligations, and general consumer receivable balances.

06

Reporting & Analytics

Real-time reporting through the client portal. Track account status, recovery progress, and financial summaries — all in one place, available 24/7.

07

Compliance-First Approach

Every interaction follows strict FDCPA, FERPA, FCRA, TCPA, and SCRA protocols. Annual third-party audits and SOC 2 Type II certification keep your institution protected.

08

Nationwide Coverage

We are licensed in all states that require it, with a dedicated team and established processes ensuring consistent service quality from coast to coast.

09

Consumer Communication

Professional, respectful outreach to consumers via phone, mail, and digital channels — protecting your institution's reputation while maximizing recovery outcomes.

Areas of Expertise

Programs We Service

Federal Perkins Loans
Health Profession Loans
Nursing Loans
Nurse Faculty Loans
Institutional Loans
Private Education Loans
Parking Obligations
Consumer Receivable Balances
HomeContact Us

Contact Us

We are here to help institutions and consumers alike.

Consumer Support

877-427-6544 collect@tbandl.com

Office

P.O. Box 36788
Rock Hill, SC 29732-0512

HomeSMS/MMS Opt-In

SMS/MMS Opt-In

Information collected here is never shared or sold by Todd, Bremer & Lawson, Inc. You may unsubscribe at any time.

Text Message Opt-In

Todd, Bremer & Lawson, Inc. — tbandl.com

By entering your phone number and checking the box, you consent to receive SMS/MMS text messages from Todd, Bremer & Lawson, Inc. regarding account notifications, payment reminders, and service-related updates. Message and data rates may apply. Message frequency varies. Reply STOP to unsubscribe or HELP for assistance. Contact 877-427-6544 or collect@tbandl.com. Review our Privacy Policy and Terms & Conditions.

Privacy: Your opt-in information will not be shared with or sold to any third parties.

HomeACA Board Election

Niel Welborn Elected to ACA International’s National Board of Directors

Representing higher education collection priorities at the highest level of industry policy development.

Industry Leadership

Active Governance at the National Level

TODD, BREMER & LAWSON, INC. delivers value-added services beyond traditional third-party collection activity through active leadership and direct participation in the credit and collection industry governance.

At ACA International’s 2025 Council of Delegates meeting, held in advance of the ACA Convention & Expo in Louisville, Niel Welborn was elected to ACA International’s national Board of Directors. This election ensures representation of the operational realities and compliance priorities of public universities, private colleges, seminaries, and trade schools at the highest level of collection industry policy development.

Board of Directors participation provides early visibility into regulatory trends, enforcement expectations, and emerging best practice standards, enabling institutions of higher education to benefit from proactive risk mitigation, informed operational alignment, and strategic advocacy that extends well beyond conventional third-party recovery services.

Early Regulatory Visibility

Regulatory trends, enforcement expectations, and emerging best practice standards.

Proactive Risk Mitigation

Informed operational alignment for institutions of higher education.

Strategic Advocacy

Advocacy that extends beyond conventional third-party recovery services.

Visit ACA International →
HomeACA International

ACA International

The Association of Credit and Collection Professionals — TB&L’s commitment to ethical and compliant collection practices.

Membership

ACA International

The Association of Credit and Collection Professionals. TB&L is a proud member committed to ethical and compliant collection practices.

Join ACA International
Niel Welborn - ACA International Board Member

ACA International Board of Directors

Niel Welborn, PCS, IFCCE

Vice President — Sales & Service, Todd, Bremer & Lawson, Inc.

Niel Welborn is a Director on the ACA International Board of Directors, serving from July 23, 2025 through July 31, 2028. He is recognized for his commitment to ethical collection standards that benefit all stakeholders in the higher education collections sector.

His election was praised by colleagues as a way to strengthen ACA International’s leadership and ensure the board is well-equipped to guide the industry into the future.

HomeAccessibility

Accessibility Statement

Updated: May 2026

At Tbandl.com, we are committed to ensuring digital accessibility for all users, including individuals with disabilities. We continually work to improve the user experience for everyone and to apply relevant accessibility standards across our website.

Our Commitment to Accessibility

We believe every person deserves equal access to information, services, and online experiences with dignity, independence, and ease of use. To support this commitment, we have invested resources and technology designed to enhance the accessibility and usability of our website.

Accessibility Features

Tbandl.com utilizes the UserWay Accessibility Widget, powered by a dedicated accessibility server, to help improve compliance with the Web Content Accessibility Guidelines (WCAG) 2.2 AA. The accessibility menu can be activated by selecting the accessibility icon located in the corner of the website.

Ongoing Efforts

We are continually working to improve the accessibility of our website and services. While we strive to make all content fully accessible, some pages or features may not yet meet the highest accessibility standards.

Need Assistance?

If you experience difficulty accessing any part of our website, encounter an accessibility issue, or need assistance, we are here to help.

Email: Collect@tbandl.com  |  Phone: 877-427-6544

HomeConsumer Rights & Disclosures

Important Consumer Rights & Disclosures

Updated: June 1, 2026

This is an attempt to collect a debt and any information obtained will be used for that purpose. This communication is from a debt collector.

Todd, Bremer & Lawson, Inc. may contact you regarding any account at the email address or any future telephone number that is provided to REPAY® including your wireless mobile device using automated telephone dialing equipment or artificial or pre-recorded voice or text messages.

We are required under state law to notify consumers of the following rights. This list does not contain a complete list of the rights consumers have under state and federal law.

State-Specific Consumer Rights

California Residents

The state Rosenthal Fair Debt Collection Practices Act, and the federal Fair Debt Collection Practices Act require that, except under unusual circumstances, collectors may not contact you before 8 a.m. or after 9 p.m. They may not harass you by using threats of violence or arrest or by using obscene language. Collectors may not use false or misleading statements or call you at work if they know or have reason to know that you may not receive personal calls at work. For the most part, collectors may not tell another person, other than your attorney or spouse, about your debt. Collectors may contact another person to confirm your location or enforce a judgment. For more information about debt collection activities, you may contact the Federal Trade Commission at 1-877-FTC-HELP or www.ftc.gov.

As required by law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations.

Debt Collection License Number: 10657-99  |  NMLS No.: 373899

Colorado Residents

For information about the Colorado Fair Debt Collection Practices Act, see coag.gov.

A consumer has the right to request in writing that a debt collector or collection agency cease further communication with the consumer. A written request to cease communication will not prohibit the debt collector or collection agency from taking any other action authorized by law to collect the debt.

Todd, Bremer & Lawson, Inc., P.O. Box 36788, Rock Hill, SC 29732, 877-427-6544 Toll Free
Colorado office: 27 North Willerup, Suite B, Montrose, CO 81401 — 970-249-7514

Debt Collection License Number: 991365  |  NMLS No.: 373899

Connecticut Residents

The law limits how long you can be sued on a debt. Because of the age of your debt, Todd, Bremer & Lawson, Inc. and/or creditor(s) will not sue you for it. If you do not pay the debt, Todd, Bremer & Lawson, Inc. and/or creditor(s) may report or continue to report it to the credit reporting agencies as unpaid.

Debt Collection License Number: 10210  |  NMLS No.: 373899

Maine Residents

Hours of operation: 8:00 a.m. – 5:00 p.m. EST Monday–Thursday and 8:00 a.m. – 4:00 p.m. EST Friday (except holidays). 877-427-6544

Debt Collection License Number: DCL11633  |  NMLS No.: 373899

Minnesota Residents

This collection agency is licensed by the Minnesota Department of Commerce.

Debt Collection License Number: 20470156  |  NMLS No.: 373899

New York Residents

Debt collectors, in accordance with the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq., are prohibited from engaging in abusive, deceptive, and unfair debt collection efforts, including but not limited to: the use or threat of violence; the use of obscene or profane language; and repeated phone calls made with the intent to annoy, abuse, or harass.

If a creditor or debt collector receives a money judgment against you in court, state and federal laws may prevent the following types of income from being taken to pay the debt: Supplemental security income (SSI); Social security; Public assistance (welfare); Spousal support, maintenance (alimony) or child support; Unemployment benefits; Disability benefits; Workers’ compensation benefits; Public or private pensions; Veterans’ benefits; Federal student loans, federal student grants, and federal work study funds; and ninety percent of your wages or salary earned in the last sixty days.

NYC License: 2102108-DCA  |  Buffalo: 561648  |  Yonkers: 9151

Todd, Bremer & Lawson, Inc. does not provide language access services; however, we do have Spanish speaking employees. A translation and description of commonly-used debt collection terms are available in multiple languages on the NYC DCA website.

Nevada Residents

Nevada Collection Agency Compliance Manager No. CM12651: James H. Todd  |  NMLS No. 938519

Debt Collection License Number: CAD11880  |  NMLS No.: 373899

North Carolina Residents

North Carolina Department of Insurance Permit #747. Physical address: 560 South Herlong Avenue, Rock Hill, South Carolina 29732.

Debt Collection License Number: 747  |  NMLS No.: 373899

Rhode Island Residents

The State of Rhode Island general laws prohibit credit bureaus from reporting medical debt or factoring medical debt into a credit score.

Debt Collection License Number: 201110736DC  |  NMLS No.: 373899

Tennessee Residents

This collection agency is licensed by the Collection Service Board of the Department of Commerce and Insurance.

Debt Collection License Number: 344  |  NMLS No.: 373899

Texas Residents

Physical address: 560 S Herlong Ave, Rock Hill, South Carolina 29732. 877-427-6544

Debt Collection License Number: No requirement

Utah Residents

As required by Utah law, you are hereby notified that a negative credit report reflecting on your credit record may be submitted to a credit reporting agency if you fail to fulfill the terms of your credit obligations.

Debt Collection License Number: 5072934-0131  |  NMLS No.: 373899

Washington Residents

Physical address: 560 S Herlong Ave, Rock Hill, South Carolina 29732.

Debt Collection License Number: CAD11880  |  NMLS No.: 373899

West Virginia Residents

The law limits how long you can be sued on a debt. Because of the age of your debt, Todd, Bremer & Lawson, Inc. and/or creditor(s) cannot sue you for it. If you do not pay the debt, Todd, Bremer & Lawson, Inc. and/or creditor(s) may report or continue to report it to the credit reporting agencies as unpaid.

Debt Collection License Number: 1048-9545  |  NMLS No.: 373899

Wisconsin Residents

This collection agency is licensed by the Division of Banking in the Wisconsin Department of Financial Institutions, www.dfi.wi.gov

Debt Collection License Number: 485  |  NMLS No.: 373899

HomePrivacy Policy

Privacy Policy

Last Updated: June 25, 2026  |  Effective Date: June 25, 2026

Todd, Bremer & Lawson, Inc. (“TBL,” “we,” “our,” or “us”) is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you visit our website at https://www.tbandl.com and when you communicate with us through text messaging (SMS/MMS) and other business communications.

By using our website or providing your information to us, you acknowledge the practices described in this Privacy Policy.

1. Introduction & Contact Information

This Privacy Policy applies to personal information processed by Todd, Bremer & Lawson, Inc. in connection with our website and communications services.

Todd, Bremer & Lawson, Inc. — P.O. Box 36788, Rock Hill, SC 29732
Phone: 877-427-6544  |  Email: collect@tbandl.com

2. Information We Collect

Personal Information may include: name, mobile telephone number, email address, mailing address, account-related information, records of communications, and SMS consent and opt-in records.

Information Collected Automatically: When you visit our website, our hosting provider may collect IP address, browser type, device information, and date/time of access. We do not use advertising technologies, behavioral tracking tools, or marketing pixels.

We do not intentionally collect sensitive personal information through our website.

3. SMS Communications & Consent

We may collect your mobile telephone number and consent information when you voluntarily opt in to receive SMS/MMS communications. We use this information solely for account communications, customer service notifications, payment-related communications, and other authorized communications.

SMS Consent Protection: Text messaging opt-in data, consent records, and mobile telephone numbers will not be sold, rented, shared, or disclosed to third parties for marketing or promotional purposes.

4. How We Use Your Information

We use personal information to communicate regarding accounts and services, provide customer support, send authorized SMS messages, maintain consent records, comply with legal obligations, protect against fraud, and establish or defend legal claims. We do not use personal information for targeted advertising or behavioral profiling.

5. How We Share Your Information

We may share information with trusted service providers including: Hostinger (website hosting), Microsoft (email and productivity), and FACS – Flexible Automated Collection Software (business operations). These providers may access information only as necessary and are required to maintain confidentiality.

We may also disclose information when required by law. We do not sell personal information.

6. Data Security & Retention

We maintain reasonable administrative, technical, and physical safeguards to protect personal information. We retain information only as long as necessary to fulfill business purposes, comply with legal obligations, resolve disputes, and enforce agreements.

7. Your Privacy Rights

Depending on your location, you may have the right to know what information we collect, access or correct your information, request deletion where permitted, and withdraw consent. Contact us at collect@tbandl.com or 877-427-6544.

8. Opting Out of Text Messages

You may withdraw consent to receive SMS/MMS communications at any time by replying STOP to any text message, or by calling 877-427-6544. You may receive one final confirmation message after opting out.

9. Children’s Privacy

Our website and services are not directed to children under the age of 13. We do not knowingly collect personal information from children under 13.

10. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Any updates will be posted on this page with a revised “Last Updated” date. Continued use of our website constitutes acceptance of the revised Policy.

Questions or Complaints

Todd, Bremer & Lawson, Inc. — P.O. Box 36788, Rock Hill, SC 29732
Phone: 877-427-6544  |  Email: collect@tbandl.com

HomeTerms & Conditions

Terms & Conditions

Text Messaging Consent

By providing your mobile telephone number and opting in to receive text messages from Todd, Bremer & Lawson, Inc., you expressly consent to receive SMS and MMS communications regarding your account and our services at the number you provide.

Communications May Include

  • Account notifications
  • Payment reminders
  • Account updates
  • Customer service communications
  • Other information related to services provided by Todd, Bremer & Lawson, Inc.

Message frequency may vary depending on your account activity and communication preferences.

Message & Data Rates

Message and data rates may apply to text messages sent to you and messages you send to us. Charges are determined by your wireless carrier and your mobile service plan.

Opting Out

You may opt out of receiving text messages at any time by:

  • Replying STOP to any text message you receive from us, or
  • Contacting our office at 1-877-427-6544

After opting out, you may receive a final confirmation message confirming your removal from future text communications.

Help & Support

For assistance regarding text messaging communications:

  • Reply HELP to any message you receive from us, or
  • Contact our office at 1-877-427-6544

Privacy & Data Use

Your text messaging consent, mobile number, and related personal information will be used solely for communication purposes authorized by you. Todd, Bremer & Lawson, Inc. does not sell, share, transfer, or distribute SMS opt-in information or consent to third parties for marketing or promotional purposes.

For additional information, please review our Privacy Policy.

Changes to These Terms

Todd, Bremer & Lawson, Inc. reserves the right to modify or update these Terms & Conditions at any time. Any updates will be posted on this page with the revised effective date.