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LEADERS | STRATEGIES | COMMUNITY | TECHNOLOGY | COMPLIANCE
Take Aways to Empower Compliant Collections
HELPING CREDITORS SEE THE
Melissa Nash
PICTURE
5 PHASES TO GET THE MOST OUT
OF YOUR TRAINING PROGRAMS MCNAMARA OF CFPB PROVIDES HIS PERSPECTIVE ON COLLECTIONS
3 MAJOR STEPS TO MAINTAIN CONFIDENCE IN YOUR COMPLIANCE THERE ARE ALWAYS BAD GUYS Vol. 19, No. 1
DEBT BUYING LEADERS FORECAST 2019
January/February 2019
HOW THE TOP AGENCIES FOSTER INNOVATION
15 STARS OF COMPLIANCE 4 LAWS YOU CAN’T AFFORD TO BREAK WHEN SKIP TRACING
AGENCY LEADERS DISCUSS COMPLIANCE TOOLS
Collection Advisor P.O. Box 92342 Southlake, TX 76092
5 TACTICS TO BALANCE OPERATIONS AND COMPLIANCE
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Read everything published by the BCFP: such as SUPERVISORY HIGHLIGHTS, reports and enforcement actions, even if they are not actions against ARM firms.
THE NOTICE OF PROPOSED RULEMAKING in March is anticipated to provide clarity and bring issuers back to the debt buying market.
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Page 11
Have rookie collectors LISTEN TO VETERANS on a phone call and allow conversations afterward.
INVOLVE EMPLOYEES RUN ANALYTICS to see what your collectors are saying to consumers during conversations.
in mission-critical initiatives.
Follow regulators in their ENFORCEMENT ACTIONS, public meetings and speeches, reports and presentations to elected officials for clarification on their positions or interpretations of regulation.
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Take Aways to Empower Compliant Collections
LEADERS | STRATEGIES | COMMUNITY | TECHNOLOGY | COMPLIANCE
The Telephone Records Privacy Protection establishes A NEW CRIMINAL OFFENSE against anyone who attempts to obtain confidential phone records of a third party through any of the bill’s enumerated schemes to defraud.
HELPING CREDITORS SEE THE
Melissa Nash
5 PHASES TO GET THE MOST OUT
PICTURE
OF YOUR TRAINING PROGRAMS MCNAMARA OF CFPB PROVIDES HIS PERSPECTIVE ON COLLECTIONS
Page 19
3 MAJOR STEPS TO MAINTAIN CONFIDENCE IN YOUR COMPLIANCE THERE ARE ALWAYS BAD GUYS Vol. 19, No. 1
DEBT BUYING LEADERS FORECAST 2019
Page 12
HOW THE TOP 10 AGENCIES FOSTER INNOVATION
January/February 2019
LET ATTORNEYS BE EXPOSED to the entire process, from placement review to filing of postjudgment remedies.
Hold a WEEKLY COMPLIANCE MEETING with C-level executives to discuss issues, trends and potential red flags.
Page 4
Page 18
Train new hires to THINK LIKE DEBTORS.
Page 10
15 STARS OF COMPLIANCE 4 LAWS YOU CAN’T AFFORD TO BREAK WHEN SKIP TRACING
AGENCY LEADERS DISCUSS COMPLIANCE TOOLS
5 TACTICS TO BALANCE OPERATIONS AND COMPLIANCE
Take-Aways From This Issue
TELL THE CFPB what problems you are trying to solve. Page 22
Have a TRAINING SESSION where a manager sits with a collector and evaluates their file maintenance and talk-off. Page 4
NEVER ACCEPT, “That’s the way we’ve always done it.” Page 17
MEASURE EVERYTHING. Identify, monitor and control risk.
AVOID ONE-ON-ONE “vent” sessions with individual executives.
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Page 8
We are going into 2019 with more debt default THAN PRIOR TO THE LAST RECESSION, with a wage gap and unemployment rate that are once again “almost touching.” Page 11
Invest more in IT THAN THE INDUSTRY AVERAGE. Page 17
Have new hires CREATE THEIR OWN FDCPA. Page 22
JANUARY/FEBRUARY 2019
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AGENCY ADVISOR
5 Phases to Get the Most Out of Your Training Programs Sam Eidson
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COMPLIANCE ADVISOR
18
There are Always Bad Guys Debra J. Ciskey
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Debt Buying Leaders Forecast 2019 Economy Perched on the Edge of a Knife
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Top Technology Partners Reveal Latest Technology Helping Creditors See the Big Picture
Ron Brown
14 16 18 22
McNamara of CFPB Provides His Perspective on Collections
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Agency Leaders Discuss Compliance Tools: Reduce Risk and Save on Labor
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MANAGEMENT ADVISOR
5 Tactics to Balance Operations and Compliance Gordon C. Beck III
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SKIP TRACING ADVISOR
4 Laws You Can’t Afford to Break When Skip Tracing
LEGAL COLLECTION ADVISOR
3 Major Steps to Maintain Confidence in Your Compliance Michael L. Starzec
READ ONLINE TRAINING ADVISOR
Certified for Success in Debt Buying Harry A. Strausser III
READ ONLINE
COLLECTION INDUSTRY ADVISOR
What You Can Get Out of Collaborating with Others Nick Jarman
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How the Top Agencies Foster Innovation Stars of Compliance
EXCLUSIVE EDITORIAL FOR PRO MEMBERS ONLINE 7 Leading Attorney’s Provide Pitfalls You Must Avoid in 2019 Attorneys Explain What Creditors Should Do Now to Collect Later Key Advice from the Stars of Compliance What the Industry’s Most Innovative Agencies Hope the Future Will Bring 4 Myths in Telecommunication You Shouldn’t Believe Clamp Down On How You Are Discouraging Payments
...PLUS MUCH MORE SEE PAGE 21 FOR MEMBERSHIP DETAILS January/February 2019
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Agency Advisor I Sam Eidson
5 Phases to Get the Most Out of Your Training Programs
T
Director of Compliance Delta Outsource Group Board of Directors Member Missouri Collectors Association
hroughout my career I’ve either read or heard that companies are only as good as their employees. I’ve found this to be a true statement and that’s why we feel it’s extremely important to train and develop our most valuable resource. Those who value employee development will continue to grow while those who don’t tend to remain stagnant. Our new hire training program consists of five phases including:
accommodate each individual by using a different approach. One of our most valuable training practices is group round table call calibrations. We choose a few veteran collectors and a few rookie collectors and listen to a call from each. Once the call has ended each collector gets to speak on what they liked and what they may have done differently. The last collector to speak is the one whose call we just heard. Then the training manager adds their comments and suggestions. 1. Introduction to our company When we first started this including management team, practice I’d hear collectors moan Our collectors must pass with a minimum employee handbook and code and groan on their way to the of conduct. training room. By the time the score of 90% on our debt collection session was over each and every rules and regulations tests before they 2. Compliance with state and one of them came out of the federal laws including intertraining with a positive upbeat can even make a call. nal policies and procedures. attitude. Some even asking when Our collectors must pass with we were going to do it again. a minimum score of 90% on our debt collection rules and regulations tests before they can even make a call. The One-On-One Session Other forms of training include side-by-side sessions where a 3. System training including telephony, collection software manager sits with the collector and evaluates their file mainand file mechanics. tenance and talk off. We also have one-on-one call listening sessions where we listen to a right-party contact and allow the 4. Talk off training including required disclosures, call procollector to evaluate how they performed. Having the colgression and collection techniques. During this session we lector evaluate the call allows the manager to have a better like to perform role-playing scenarios to help the collector understanding of the collector’s job knowledge. Sometimes it overcome common objections. takes listening to yourself on the phone to realize when you’re leaving money on the table or whether you could’ve handled 5. Client specific training and special account handling. the call more efficiently. A few of the things we evaluate during the call include tone of voice, call progression, fact-finding A Valuable Ongoing Training Practice questions, psychological pause and urgency. Every so often we Training isn’t a one and done program for our collectors. add pop quizzes to our intranet and offer a prize for those who We feel like ongoing training for collectors with all ranges of score 100%. experience is important to their development. Our industry Once we identify each collector’s strengths and weakis ever changing so there is always new material to cover. nesses we cater our strategy to their strengths. All collectors Often times those with experience have some bad habits or are not created equally so it’s our job to place them in the try to take shortcuts that end up costing them or us adbest position for their success. Some agents are better suited ditional revenue. Employees need development not only to for a dialer while others are more effective skip tracing and make them better at what they do but also to feel valued by manual dialing. We have a nice blend of post date collectors their employer. versus our liquidators and need a mixture of both in order to Knowing there are multiple learning styles we try to continue our success.
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January/February 2019
.com
THE ADVENTURES OF...
COLLECTOR
TM
CAPTAIN COLLECTOR Designed by Adriana Holland, Sales Assistant and Illustrator .com
January/February 2019
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Compliance Advisor I Debra J. Ciskey
There are Always Bad Guys
RECORDED MESSAGE “This message is intended for Diana Martinez. I received a fax order regarding a complaint that was filed against you. I have been retained to serve these documents at either your residence or place of business. If you have any questions or concerns about this complaint or wish to rectify the matter you can hit any key on your phone to speak to our office directly or call us at the following number 410-306-5975. When calling please reference file number CQY1237.
I
You have officially been notified.”
Calls From the Past
Think back to 1991 and the couple of years preceding that fateful year that gave us the Telephone Consumer Protection Act (TCPA). Calls from people selling light bulbs. Calls from the telephone companies themselves offering cheaper long distance rates than the one that called me the night before. For younger readers, let’s remember that long distance wasn’t always free like it is today on our cell phones. We thought 10 cents a minute was a pretty good rate until someone else offered us 8 cents, and then 5 cents. I think I changed long distance providers three times in just as many months because of the deals. Then I got sick of the calls and told people to stop calling me. Heck, I had little kids back then and the phone calls routinely interrupted dinner, bath or bedtime. This was also before caller ID was free, and you had to rent a box to hook up to your phone to see the caller ID message. Those were the days! This trip down memory lane is merely to illustrate that there are always bad guys. Enterprises or people use new or old and reimagined technology to such a degree that it starts to cause harm, or at least perceived harm, until somebody finally says, “there oughta be a law.” Telemarketing calls were labeled as “invasion of privacy” and the TCPA was conceived. After the genetic modification that we call the legislative process took its toll, the law was born. Today we are still fighting the battle so that our informational calls to consumers can be made using technology, legally and effectively. We know the arguments in favor—consumers need to hear from us to prevent potentially harmful consequences, nobody opens their mail anymore, etc. But it is bad guys, like the one who left me messages for poor Diana Martinez, that undermine our efforts to use technology for its intended purpose.
Make Change
In the meantime, we must remain active in our efforts to influence those in power at the Federal Communications Commission to give us rules or a resolution, because we aren’t the bad guys. January/February 2019
.com
online
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and intimidated by the caller, I get angry. Bad guys ruin it for everyone. They do things just because they can.
MEMBERS ONLY: FCC structure and contacts
received the recorded message above along with two others within three days of each other. No, I am not Diana Martinez — never have been — and I have had my same cell phone number for more years than I can remember. Of course, these calls are from scammers — unscrupulous types posing as debt collectors, if one can believe the posts that come up when Googling the number. These are the worst of the worst who threaten arrest, lawsuits and wage garnishments and apparently making random phone calls in some instances to do it. Unbelievably, some people do call them back, and an “account” is located. From the reports I have seen, when there is an actual debt it has been discharged in bankruptcy or paid off long ago. All appear to be out of statute. I am not about to call them back. Luckily, my iPhone makes it incredibly easy to block a number and stop the calls. But I am one of the lucky ones, I know this is a scam and I know better than to call back. When I think about the potential impact of this scam on elderly relatives who would be utterly convinced
Compliance Officer Wakefield & Associates. Inc. Board of Directors Member/ Certified Instructor ACA International, Inc.
DEBT BUYING LEADERS FORECAST 2019 ECONOMY PERCHED ON THE EDGE OF A KNIFE BY JOSHUA FLUEGEL
T
he debt buying industry has found itself in the spotlight in recent years leading to numerous changes and a fair share of uncertainty. This climate has let only agencies with the most steadfast of temperaments and industry-tested of business strategy remain successful. When asked for the recent industry-changing occurrences, Matthew Maloney, president and chief investment officer of the FFAM360 Group of Companies Matthew Maloney and First Financial Asset Management, saw multiple.
.com
January/February 2019
“With respect to ‘one of the biggest recent occurrences in debt buying,’ there seems to be several events or trends that could qualify for this: regulatory trends, technology trends, legal trends, capital-market trends, economy, etc,” said Maloney. “But from my perspective, the unexpected ‘exit’ of various debt buyers (some notable, others not as much) seems to be having significant ‘influence’ on the current state-of-affairs in today’s debt buying market as we head into the end of 2018/beginning of 2019. While various factors have played a role in why so many debt buyers have ceased to exist in the last 24 months (e.g. (1) foreclosed on by their lenders, (2) shut down by regulators,
or (3) simply sold-off their business/assets to pursue other interests outside of debt buying, the common thread amongst each situation is that the debt buyer(s) were running their businesses at unsustainable (unprofitable) levels, an intrinsic consequence of portfolio acquisition pricing far exceeding the appropriate quantitative value(s), which ultimately led to financial stress and caused those debt buyers to “exit” the market. “It’s affected the landscape in various ways, most of which seems to express a favorable influence. For example, deal-flow in certain segments of the marketplace has increased, and pricing in those same segments
Continued on page 9
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Management Advisor I Gordon Beck
5 Tactics to Balance Operations and Compliance
T
o all of you ARM industry CEOs out there: how many times have your Chief Operating Officer and Chief Compliance Officer come running to your office, at each other’s throats regarding a decision passed down from Compliance or a strategy executed by Operations? One of your most trusted people trying to protect the organization against one of your most loyal subjects trying to drive revenue legally, morally and ethically. It’s become a somewhat familiar theme for most agencies vying to be under the radar, but desperate to produce great results on the scorecards. In some cases, it can tear at the very fabric of the company and in other cases it can cause you to outright lose a C-Level employee that has dedicated years to the cause, while dividing the company down the middle. All of a sudden and without warning, a culture has been created: Operations versus Compliance, dividing the team and working against each other as opposed to working together against the competition. The question is, what can consistently be done to drive unity and team work in a world where compliance and performance equally reign supreme? Here are a few suggestions to help:
1. Compliance Meeting
Hold a weekly compliance meeting with C-level executives to discuss current issues in the company, trends in the industry and potential red flags that need to be looked at and addressed such as recent case law or client requirements. These meetings, if held consistently, strengthen the lines of communication with the team and prevents the emotional “scrambling” that occurs when problems arise.
2. Promote the Achievement of Common Goals
Compliance is not a “set it and forget it” matter, it is evolving, changing and almost always up for interpretation. If the goal is to address an issue to reduce liability while remaining productive then lay it out specifically, monitor the results of the collaboration and compensate your leadership for successfully working together as a team to make it happen. When there is a common reward, you will find common effort.
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President/COO/ Minority Owner Valor Intelligent Processing
3. Air Out Grievances Try to avoid one-on-one “vent” sessions with individual executives that want to come in and speak negatively about the actions of another executive or department. This is not healthy. If someone approaches you about the issues of the other, stop them, bring the other person or department into the room and iron out the problem. When you only get one side of the story, you never get the whole story. This leaves the problem unresolved. These issues, when addressed, must be resolved right then and there and can only be done if all parties are involved.
4. Change Management
Change management is huge. There must be a process where all changes in compliance procedures or operational strategy is discussed, agreed upon and signed off on by all members involved in the change. These changes must be logged, reviewed regularly and results must be tracked. But at the end of the day, these changes must be a group effort with a resolution that is supported by both sides, again, promoting a culture of togetherness.
5. Delivery of Initiatives
Delivery of the agreed upon initiatives are sometimes as important as the initiative itself. When change is made in our industry it can be amazing or it can be crushing. When delivering the message to the team it must be a unified message, one that both sides unrelentingly support. Getting the team to buy into change is a lot easier when both Compliance and Operations are singing from the same songbook. In conclusion, it seems as if our industry and the great agencies representing it, all too often have internal finger pointing as to who gets the blame when things go wrong. This drives a culture of division and individualism. The bottom line is, the organization is either going to sink or it’s going to sail. Whether it sinks or sails, it’s going to happen together and together is the only way for Operations and Compliance to achieve the common goal of keeping the agency afloat and moving forward. January/February 2019
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CREDITOR SEEKS LONG TERM ECONOMIC PARTNERSHIP Debt Buying Leaders - Continued from page 7 has adjusted into risk-appropriate valuation ranges that are more sustainable for the debt-buyer(s) risk-adjusted returns for these types of accounts receivable assets. In one specific instance, I had a creditor contact me to work thru what they called a “long-range economic partnership” that both parties could rely on (versus their prior objectives of chasing a single buyer with the highest bid). I have seen this in both the performing and non-performing (charged off) segments of the auto-loan, healthcare, consumer loan, and card sectors. Ultimately, a balanced and fair valuation for these types of assets, with contractual terms that are well balanced will allow for the marketplace to have a sustainable life cycle for the future.”
Mark Naiman, president of Absolute Resolutions Corporation (ARC), also noted fewer participants in the market citing the CFPB and new regulations for Mark Naiman originating creditors. “After the rise of the CFPB (now BCFP), many of the smaller players dependent on resale had to shift their models almost overnight,” said Naiman. “The ones that could, either changed to a contingencybased model, or sought out similar players and through M&As, many smaller companies chose to merge with peers forming a larger more substantial market presence.
Admittedly, the newer regulations and scrutiny facing originating creditors was a tremendous burden on companies of any size, especially since the compliance requirements were reciprocal.” To adjust to these changes in the debt buying landscape, some professionals have taken to using internally developed tools to improve their data analytics, enhance performance and improve the consumer experience. This is the strategy that has worked for The Bureaus, Inc. according to its vice president, Marian Sangalang. Sangalang
Continued on page 11
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January/February 2019
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Skip Tracing Advisor I Ron Brown
4 Laws You Can’t Afford to Break When Skip Tracing
MEMBERS ONLY: Referenced regulation
online
I
n the previous article concerning skip trace training I mentioned that the actions of a professional tracer will fall under certain federal and state statutes. To insure compliance with these statutes and prevent litigation for violations it is imperative that the tracer know and follow these laws. I am often asked by tracers, “What are the tracing laws and where can I go to learn the compliance requirements and laws related to the skip tracing process?” Due to the brevity of this article I will not attempt to answer all of these questions but rather provide the reader with the “basics” and the “where to go to get information related to the subject”.
The FDCPA “Must-Knows”
First let’s look at the major federal law related to tracing activities: Section 804 of the Fair Debt Collection Practices Act, 15 U.S.C.§1692b, “Acquisition of Location Information.” Being unable to delve deeply into everything that is required under this section, I will just point out that all tracers should familiarize themselves with this section of the FDCPA and follow its requirements to the letter. Major points are: • Identify yourself and state you are confirming or correcting location information. • Identify your employer only if you are asked. • Do not state or imply the consumer owes any debt. • Do not communicate with the informant more than once unless certain conditions are present. Read and follow this statute closely and be sure to look in the ‘Definition Section” for the exact definition of “Location Information” as you are restricted to only ask for that information.
The Gramm-Leach-Bliley Act “Must-Knows”
Next let’s discuss a few of the many privacy laws which limit the information you may provide to others when you are attempting to locate a consumer. The Gramm-Leach-Bliley Act (GLBA) protects consumers’ non-public personal information (NPPI). The government-speak definition is, “any information which is not readily available through public sources” including but not limited to: date of birth, Social Security numbers, unlisted phone numbers, and all financial information. I suggest that the tracer locate online and carefully read the
10
Member National Association of Fraud Investigators Author “MANHUNT: The Book” Contact rbrown2150@aol.com
section of this statute which defines NPPI and prohibits the use of disclosing the information.
The HIPAA “Must-Knows”
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) has a very simple definition: Any information in any form that is medically related. The tracer should be very careful when contacting informants and not give out any information which could be medically related. Even telling a third party the subject is on disability would be a clear violation of this statute. I would suggest the tracer refrain from providing anyone any information that could be considered “medical related.” Again, find and read the law.
The TRPPA “Must-Knows”
The Telephone Records Privacy Protection Act of 2006 (TRPPA) should be of dire concern for any tracer as it is the first act which criminalizes a tracer’s actions and can result in hefty fines and prison time. First and foremost, it establishes a new criminal offense against anyone who knowingly and intentionally obtains or attempts to obtain the confidential phone records of a third party through any one of the bill’s several enumerated schemes or devices to defraud. Penalties for violating this prohibition include a fine or a term of imprisonment of not more than 20 years or both. Second, the bill establishes a new set of criminal penalties for anyone who knowingly and intentionally sells or purchases the confidential phone records of a third party without proper authorization or knowing that such records were obtained through fraud. Violators of either of these two provisions are subject to a maximum term of imprisonment of up to five years. Finally, to offer increased protection to the likely victims of such activities, this legislation includes a series of enhanced criminal penalties against any individual who engages in any one of the aforementioned crimes knowing that such information was sought in furtherance of or with the intent to commit any one of the bill’s dozen or so enumerated offenses. Individuals specifically protected under this provision include potential victims of domestic violence related offenses, jurors, criminal witnesses, confidential informants and law enforcement officers. Tracers should familiarize themselves with this law and to avoid the consequences of fines and jail time, follow it to the letter. January/February 2019
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CLARITY EXPECTED FROM MARCH 2019 BCFP RULEMAKING Debt Buying Leaders - Continued from page 9 also stated she has seen changes in what issuers are looking for in a legitimate debt buyer. “We are seeing some issuers taking a different approach to vendor Marian Sangalang oversight and are showing more interest in association certifications to work in conjunction with their existing review program,” said Sangalang. Regarding how that affects the debt buying landscape today, Sangalang said, “The level of oversight the issuers of credit are required to perform is understood by our industry, the opportunity to provide credible association certification in conjunction with the issuers requirements will provide a more seamless and streamlined review process for the debt buyer and the issuer.” Naiman noted the changing landscape as well and emphasized the importance of adaptability by making sure the accounts being worked align with the environment at large. “ARC’s philosophy has changed in parallel
with the environment, yet our strategy has remained focused on finding portfolios that make sense within the ever-changing regulatory whirlwind,” said Naiman. “Being dynamic, while simultaneously looking at asset classes that fall outside of standard credit card and installment loan markets allows us to maintain a fluid and adaptable presence in a market that is overwhelming dominated by large players. Maintaining a medium presence in the industry allows us to be both more patient and adaptable in times of economic uncertainty.” Fortunately, the debt purchasing landscape may be on the verge of more stability as regulation may soon find additional footing. Sangalang hopes upcoming developments will bring issuers back to the table. “We believe that there will finally be some clarity provided for our industry with the Notice of Proposed Rulemaking expected in March 2019,” said Sangalang, referring to the CFPB’s recent announcement in the Spring 2018 rulemaking agenda. “Many issuers have been hesitant to come back to the
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January/February 2019
From: Busin
market until such clarity was provided. We are hopeful that this will provide the level of clarification needed for those issuers to once again enter into the debt sales market providing additional markets for all debt buyers.” History and its tendency to repeat itself may provide some insight into the future of debt buying as well. Naiman sees indicators in the economy that suggest a continued increase in the number of accounts in default. “The abundance of product is a direct correlation to the amount of household debt, and synonymously the amount in default,” said Naiman. “We head into 2019 with more debt default than prior to the last recession, and a wage gap and unemployment rate that are once again ‘almost touching.’ If the past is any indication of the future, we know that the economy is perched on the edge of a knife, and 2019 should be a very interesting year.”
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Legal Collection Advisor I Michael L. Starzec
3 Major Steps to Maintain Confidence in Your Compliance
MEMBERS ONLY: Referenced regulation
online
I
n the modern compliance era, collection law veterans have become inured to seemingly relentless rounds of annual, bi-annual, and quarterly testing, certification and recertification exams that we take on a yearly basis. For us, compliance is used to improve your practice, modernize workflow and protect against audit failures. Indeed, it becomes cost-effective as you avoid risk and attract business with robust compliance controls. However, your associate attorneys often do not perceive these impacts as they wrestle with compliance on a day-to-day basis. In the not-so-distant past, I managed our associate attorneys, that tenure ending just as the reality of CFPB oversight lead to compliance-heavy training and testing. Then, as now, the allure of collections was the promise of a steady diet of court, arguing many substantive motions and obtaining significant trial practice. At that time, after a few hours of FDCPA training and testing and a quick review of the employee manual, a new associate was with attorneys on day one, reviewing case law and learning how to prepare a court call. By day two, they were shadowing an attorney in court. Now, an associate won’t see an attorney or think about the law (other than the FDCPA) until their fourth day at the firm. In addition, depending on the client, a new attorney may take up to 14 different tests. And these tests cover areas as diverse as Fair Lending to the American with Disabilities Act to Anti-Money Laundering. In fact, at one point, for a mortgage lender we actually had a test on the federal Flood Insurance compliance. (Not surprisingly, flood insurance was never raised by a defendant in a single case we handled for that client.) But when we reflect on the training, it is not surprising a new associate leaves bewildered. First, they take a test on the FCRA but later are informed attorneys cannot discuss the implications of the FCRA in settlement discussions. While they never process an electronic payment, they learn about the Electronic Fund Transfer Act (EFTA). They wonder if they would confront claims of inappropriate access to bank facilities. And, from all of this testing most of the attorneys immediately realize that simple, honest mistakes can result in FDCPA lawsuits. One associate noted that as attorneys handle the case last, they are the line of last resort to prevent a lawsuit. This sobering realization is useful information for all of us with management roles. While we want to create a compliance culture, we do not want to have employees constantly on edge,
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Partner Blitt and Gaines, P.C Vice-president Illinois Creditors Bar
fearing decision making. For that reason, our firm has made efforts to ensure our attorneys can practice law and compliance with confidence.
1. See the Whole Process
First, we try to ensure that we don’t let our various departments work in a vacuum. Therefore, we expose our attorneys to the entire process, from placement review to filing of post-judgment remedies. Not simply to know how a file gets to court, but to let them know that there are people and processes in place to detect mistakes or changes in the circumstances of the file.
2. Someone to Summarize
Second, because we as partners and managers are engaged more often in disseminating information rather than having to act on that information, it is critical to come up with ways to cope with the sheer volume of material that falls upon the staff. On a monthly basis, think how many times we receive client updates or are issued an entirely new client guide comprising hundreds of pages. And all of these changes are acknowledged with a simple click of the mouse. With the amount of work an attorney must perform, synthesizing that information into actionable intelligence is nearly impossible. To combat information overload, at our attorney meetings, we have an attorney who is responsible for summarizing all the changes that may impact our attorneys over the course of that month. We quickly discovered that these summaries yielded discussion, questions and feedback. Something we rarely obtained by simple email dissemination.
3. Re-Familiarize with the Workload
Finally, it is important to re-familiarize yourself with the day-to-day work your attorney performs. Walk into their offices, find out what issues they are facing, find out how much the practice of collection law has changed since we were the ones running around the court house. Having effective lines of face-to-face communication leads great benefits to staff morale and leads not simply to work satisfaction but breeds a culture of cooperative compliance and teamwork that can only enhance the effectiveness of your practice. January/February 2019
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Reveal
TOP TECHNOLOGY PARTNERS
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n a continuation from last issue, technology leaders present their ideas to benefit the accounts receivable process based on their area of expertise and the impact of consumers having more money each paycheck due to recent tax changes.
PAUL GIES, President of VoApps said, “Timing is the best it has been in the past few years for agencies who have been afraid of technology to try it with better ways to communicate with customers. Finding the ways they like to communicate empowers the consumer. It gives them choices about how and when to respond. Clients today like to be contacted differently. “The current administration is pro business. The message is, if you are a good actor you have nothing to fear. Non-intrusive delivery into a voice mailbox does not interrupt their day. They are calling you back on their timeframe, which changes the tone of the conversation. It results in a better conversation. The response is based on the age and type of the paper. Generally it is a 20% increase in contacts. The quality of the call is better because they are calling back to get resolution. It empowers consumers, which leads to better interactions.” CHRIS CAMPBELL, CEO of Simplicity Collection Software said, “It is better for the software to identify the debtors who are going to make payments and are going to continue to stay on a payment plan. On the legal collection side the payment plans are usually signed documents with incentive to pay or the amount goes up with alerts if they miss the eCheck or an ACH. Legal has the advantage of filing suit and getting a face-to-face meeting. Sign a plan or get agreement which enables them to get a judgement where they get garnishment or a levy on tax refunds.” .com
January/February 2019
TOP TECHNOLOGY PARTNERS
LATEST TECHNOLOGY
CHRIS J. ROBERTS, President/Chief Operating Officer of Sentinel Development Solutions, Inc. (eCollections) said, “The next generation prefers to address their obligations in a different way. They may receive a letter or email and take care of it without getting a call from a collector.
“Time is of the essence; get your processes in place so when the account moves to collection status, because who knows how long this [economy] can last. Additionally there is a more favorable environment like changes in CFPB. Collections is an easy issue for politicians to speak about.”
This article is continued on www.CollectionAdvisor.com.
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Helping Creditors See the
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mong the towering mountains and roaring rivers, Melissa Nash, president/ CEO of ARI (Accounts Receivables, Inc.) and recently installed president of the Florida Collectors Association, likes to enjoy all the elements of the outdoors and take in the big picture. Similarly, her journey in the accounts receivable industry has taken her from the first step of invoicing to the final step in collecting on delinquent accounts. Nash started her receivables career with a produce company in the restaurant industry. She would start each week with a stack of green bar ledger paper fresh from a dot matrix printer and begin making calls. Working her way through the ranks she began to see how money flowed and, more importantly, what would stop money from flowing. The downturn in the economy in 2007 led friends in the construction industry to ask her opinion as to why their cash flow ceased and what they could do to remedy it. Since, Nash has worked in collections and consulting helping businesses collect on delinquent accounts and adjust their organization to optimize information flow. The big picture as she has experienced it helped her help creditors make sense of complicated situations. “Once I understood what happened from an accounts payable point of view I married that into an
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PICTUR accounts receivable perspective,” said Nash. “I try to teach my clients you need to make the A/P person in your client’s office your best friend because they have all the control in the world. They move your invoice or they can sit on your invoice.” “I see receivables as an arm of sales,” explained Nash. “Until you’ve collected your money, you haven’t really completed your business transaction.” Paperwork circulation is not a novel concept but it is one many companies let slip. Without a top-down examination of who is moving invoices and at what time, many companies will grow complacent with a dwindling cash flow. “What I saw in a lot of businesses is they would have an entry-level person in control of opening the mail and delivering the invoice to the right or wrong person.” Nash also stresses the importance of making sure contracts and assurances are in order. She stated she was shocked by how many companies were not protecting themselves with simple contracts. Especially when these same companies were coming to her with unpaid bills with the sum of $30,000. “Who does $30,000 worth of work without a contract,” exclaimed Nash? “Who does $30,000 worth of work without a personal guarantee?” Nash described several instances when she worked with companies that were suffering from cash flow problems and revealed it was done to help them see the whole picture and adjust accordingly. [See Right.] “It’s very hard to explain to a business owner why they might need to expand their overhead; they might need to hire someone a little more qualified, a little faster, a little more experienced or to add another position,” said Nash. “It’s very hard to try to quantify that upfront. But in the end they usually find the value in having cash flow.” Seeing the whole picture has also helped Nash in ARI’s third-party collections as well. Nash has aligned ARI’s brand with stand out colors and other more appealing aesthetics to improve open rates on letters and overall debt response. “We spend extra money to send our letters in color,” said Nash. “We are working on the font we use so it isn’t so negative. We use a colored logo. We don’t want dark boring colors. Our logo is orange. I want you to see something that’s a little vibrant. Something that’s a little happy.” January/February 2019
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RE PROBLEM ONE A business calls because they cannot seem to receive payment for jobs fast enough. This service provider does an average of 200 tickets a day in sales. The billing department requires bills be paid in 30 days. However, the invoices are dated for the day of the service but it takes 30 days to process and submit the invoices to the client. The invoices are already 30 days old when they are to be sent to the client. This problem is compounded when so much time passes that the job is already closed out of the company’s bookkeeping department without a way to job-cost the bill leading to it ending up in a problem pile, costing even more time
SOLUTION
Flowchart how the process is supposed to be, not how it is, from beginning to end. Start with macro-steps and then add the smaller steps. Using movable post-its on the wall will allow the process to evolve as problems or needed steps are discovered. The finished flowchart will either reveal where problems are or what your process flow needs to conform to in the future. .com
January/February 2019
PROBLEM TWO Many larger companies are moving to different online accounts payable systems for purchase orders. A company servicing these large companies now has to deal with different computer systems with various requirements. This leads to A/R employees being pushed out of their comfort zones and forced to adapt or drag the company down.
SOLUTION
To keep up with the growing demand, establish an internal training program or contact an external one to bring all employees to the required level of expertise. This will either lead to letting employees go due to technology fueled redundancies or the need for additional and/or replacement employees to keep workflow in the A/R department ideal.
TOP 10 INNOVATIVE AGENCIES
How the Top Agencies FOSTER Innovation
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ast issue of Collection Advisor the leaders of the Top 10 Innovative Agencies let us know what they had innovated to improve their collection practice. As the New Year is upon us and many are making their resolutions for the year, we asked them how does your agency create an environment of innovation. Dive in, take notes, implement in your office and make 2019 your best year yet!
How does your agency foster an environment of innovation?
AMERICAN PROFIT RECOVERY Jeff DiMatteo President Communication is key to our innovation. We are constantly involving our employees in not only mission– critical but also community service initiatives which fosters trust and collaboration. There is constant teamwork between departments, management and our software professionals to encourage best practices and to improve experiences for all. A major part of our culture is to be constantly thinking “How can we do it better?” Americollect Kenlyn T. Gretz President and CEO We have built an internal department of project analytics from the ground up. If you are a front-line collector and want to help build new tools to make us faster and nicer to the consumer, we have a career path to help you do that. We teach you report writing, project management and small amounts of programming. We also have our own staff of software developers. CACi Roger D. Weiss President I believe the best way to foster an environment of innovation is to look, study, watch, listen, network, and collaborate. Remain a student of the game. Talk to companies both inside the collections space, and those having nothing to do with collections to get a completely different paradigm of ideas. I’m a big advocate of attending the industry trade shows as well. ACA International offers tremendous opportunities to learn about new products and to network with those using them.
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January/February 2019
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CBC, LLC Marc A. Carter President An environment of innovation can best be fostered through the constant questioning of existing processes and the desire for improvement either through automation or consolidation of workflows. Similarly, a technologically inclined under-40 team member encourages thinking outside existing business boundaries while utilizing available technology and applying “why can’t we” to the equation.
TAKE AWAYS 1 - Cross-train employees based on interest. 2 - Invest more in IT than the industry average. 3 - Never accept “That’s the way we’ve always done it.” 4 - Involve employees in mission–critical initiatives.
CBE Companies, Inc. Tom Penaluna Chairman and CEO Actually “innovation” is one of our core values that we talk about often. Employees would all tell you our tag line, “Defining the future of debt collection,” which keeps innovation front and center to our work. We invest more dollars in IT solutions than the industry average to accommodate innovation. We have self-identified and defined problems the collection industry has been experiencing, and then we design and innovate solutions to many of those problems. Credit Bureau Services, LLC Debbie Frank CEO Our G.R.O.W. program is changing the way our account representatives interact with consumers, by training them to help consumers. G.R.O.W. stands for Gaining Resources, Opportunities and Wealth. The program assists consumers with finding employment, connecting them with local resources, and helping them build wealth. We know that life happens and we want consumers to G.R.O.W. through it! The Bureau is doing work that matters! Credit Collection Partners Rick Bonitzer President Culture. Your management team must make it known that ideas and outside-the-box thinking in all areas of the business are encouraged and desired from everyone. Never accept the answer, “Well that’s the way we’ve always done it.” Never be satisfied with the status quo; always look for improvement. This philosophy needs to be disseminated in board meetings, executive management meetings, supervisor/manager/sales huddles, with company-wide staff meetings tying it all together.
Jeff Freedman and Saul Freedman
CEO/Principal
I think the most important aspects of fostering an innovative environment are: never being satisfied, constantly looking for ways to improve (even if something is not broken), encouraging .com
January/February 2019
SOUTHERN OREGON CREDIT SERVICE Brian Watkins President You must want to innovate. It will not “just happen.” Your clients will not do it for you. Your company must make a decision to stay in the forefront of technology and not get left behind. I know of way too many agency owners who thought the world was not going to change, and they wake up one day very surprised their company is struggling to attract new clients. State Collection Service, Inc. Tom Haag Chairman and CEO Fostering an environment of innovation requires the freedom to think about solutions to the question, “How can we be better?” In fact, we believe so strongly in this that we dedicate offsite meetings to discussing innovation. Exploring leading-edge technologies like speech analytics, gamification, and advanced data science came from these meetings and our culture of communication that encourages staff to share solutions. We know that the “next big thing” is just a conversation away.
C B E CO M
PA N
IES
, IN
C.
MRS
everyone in the organization to question the status quo, being open to trying new things, not being afraid of failure, and finally, willingness to assume some risk.
Stars of Compliance T
he big ball in Times Square has dropped, 2019 has arrived and it looks like uncertainty in regulation is here to stay a while longer. However, the fight for meaning and clarity continues as professionals across the accounts receiv-
able industry band together. When the question is what path to take on a phone call, letter or data management, there is always a star professional who has taken the correct path and is willing to share it. This list compiles such compliance professionals as nominated by their peers and asks them where to find such information and which of it they have found to be most useful. When in question, look to the stars. WHAT IS SOMETHING ACCOUNTS RECEIVABLE PROFESSIONALS CAN DO TO CONTINUALLY IMPROVE THEIR COMPLIANCE WITH REGULATION?
BARBARA NILSEN Partner/CCO Blitt and Gaines, P.C. Accounts receivable professionals need to remember that compliance is fluid and the requirements are constantly changing which requires versatility. It is important to keep current on the latest consent orders, lawsuit theories, case law and pending changes to regulations. This information should be analyzed against current business practices, policies and procedures to ensure up to date compliance. The second part to any type of improvement is training. Training must include examples of the regulation that make it relative to a certain task or department within the organization in order for employees to truly understand how a regulation applies to them. The third part to improvement is controls. You can have the best policies, procedures and training program, but you have to set up controls to identify potential issues for remediation before they become a regulatory violation. DAVID J. KAMINSKI, ESQ. Partner and Chair of the Financial Services and Class Action Group Carlson & Messer LLP Routine audit of your systems to determine compliance performance is key. Running analytics to see what your collectors are saying to consumers during live conversations, and analyzing
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the codes agents use and the entries they make in your collection software may help isolate problems a company never knew existed. DEBRA J. CISKEY, IFCCE, CCCO Chief Compliance Officer Wakefield and Associates Inc. Read everything published by the BCFP — blogs, press releases and official publications such as Supervisory Highlights, reports and enforcement actions, even if they are not actions against ARM firms. While the current administration appears to have softened the previous administration’s approach that, “everything applies to everybody,” these documents are very instructional at least, if read with an attitude of “What can I learn from this that might help me in my compliance work at my company?” While state regulators are not as prolific, reading their publications and public enforcement actions is also extremely useful. DENNIS J. BARTON III Managing Attorney The Barton Law Group, LLC Companies can improve all aspects of their business, including compliance, with a holistic view of employment. An employee’s compliance failure is often symptomatic of a company’s inability to properly recruit, hire, train, and/or
motivate employees. Management should continually review and update its policies and procedures used to (1) attract and hire quality employees, (2) create and provide initial training, (3) measure skills and performance over time, (4) develop and deliver additional training and (5) tie compensation and bonuses to compliance. JOHN H. BEDARD, JR. Managing Attorney Bedard Law Group, P.C. If it moves – measure it! A great way to continually improve compliance processes is to be identifying, measuring, monitoring, and controlling risk. Measuring behavior is one of the most important pieces of the compliance puzzle. If collectors are not measuring and documenting behavior in a structured way (versus capturing unstructured data i.e. a natural language text field), then analyzing that data becomes difficult and inhibits full understanding of a company’s risk profile. JOHN MCNAMARA Assistant Director, Consumer Lending, Reporting, and Collections Markets Division of Research, Markets Regulations Bureau of Consumer Financial Protection I have always favored a black box like analysis of failures. Failure could be a complaint, a lawsuit, a substandard audit or other suboptimal outcome. By black box, I mean that you retrace the chain of events that eventually led to the undesired outcome, collecting data along the way. It’s easy to get defensive, and certainly that has place when you’re facing a lawsuit. That said I maintained a team whose job was not to get defensive but rather to get dirty with details and perform root cause analysis (RCA). Their job was to find the point or points where we could have altered the outcome. This same process created a great deal of data, and that data was used to look for trends and commonality in complaints. We could look at complaints by date, client, collector, unit, stage of collections, trainer, time of day, number of calls attempted, number of contacts, etc. We even added a recruiter to see if it was possible managers charged with staffing might cut corners and increase compliance risk. We performed RCA on every complaint, looking for a point where we could have avoided the bad outcome or at least minimized it. Since we had data, we were able to draw conclusions, finding faulty training, culture issues, or even lead us back to the trainer, or the recruiter involved in collectors who generated complaints. The team got really good at this, and drove what they learned through the organization, so each failure improved the organization.
KELLY KNEPPER-STEPHENS VP Legal & Compliance TrueAccord Take advantage of all the industry continuing education initiatives both at conferences or through online trainings and hot topic courses. Participate in benchmarking groups either formal or informal where you can share best practices and solve problems. Read all the industry publications (sign up for the daily news), listen to the industry blogs, and join the industry list-serves. LADONNA BOHLING VP Special OPS Contract Callers, Inc. Join an industry association that will provide you with regulatory updates and offer opportunities to network with peers to share best practices. Police yourself to ensure compliance with regulations by developing a robust internal auditing process to measure your performance against regulatory requirements. Use the data to make changes to mitigate risks and incorporate process improvements. LESLIE C. BENDER Chief Strategy Officer & General Counsel BCA Financial Services, Inc. There are few things an accounts receivable professional can do to continually improve their compliance with regulation that is more important than reading and listening to each and every communication from the regulator or law enforcer responsible for a particular regulation. Oftentimes regulators clarify their positions or interpretations of regulation in enforcement actions, public meetings and speeches, reports and presentations to elected officials, and in other types of bulletins or commentaries. All of these communications help an accounts receivable professional know what is important about particular regulations, pitfalls to avoid, and some practical insight into how to apply or scale a regulation to your own circumstances. MAVIS KOHN, CCCO Vice President of Compliance Diversified Consultants, Inc. Stay involved. From grass root efforts to national involvement, it is vital that agencies stay aware of ongoing changes and any potential new regulations. Whether you choose to do this as part of a local unit, an annual national visit to the capitol, or on your own, make an effort to meet with your local lawmakers and legislators. A thirty-minute meeting once a year to let them know who you are, how many jobs you create and what you bring to the community can go a long way when a bill is presented to them. You can also invite them to visit your offices when it’s close to re-election time. This gives them a few minutes of face time with their constituents and allows you to discuss any concerning legislation. Continued on page 20
TAKE AWAYS
Stars of Compliance
1 - Run analytics to see what your collectors are saying to consumers during conversations. 2 - Read everything published by the BCFP: blogs, press releases and official publications such as Supervisory Highlights, reports and enforcement actions, even if they are not actions against ARM firms. 3 - Measuring everything. Identify, measure, monitor and control risk.
Continued from page 19 MIKE BEVEL Director of Education insideARM LLC Challenge assumptions. I facilitate monthly peer calls with compliance professionals and where we’ve done our best is when we’ve put aside a lot of received wisdom – anything that starts with “we’ve always done it this way” – and look at compliance and operations questions with fresh eyes. This new perspective will absolutely help when the new debt collection rules are published in 2019. (By the way: that assumption that rules will be published in early 2019 is also one that should be challenged because we’ve been waiting on rules since I was a child.) I think it’s also important to widen your perspective. There are a lot of pro-industry resources with compliance info, and of course those should referenced regularly. But it can’t hurt to throw in some consumer-focused sites too. Perspective can build better processes. (And if you can stomach it, scrolling through consumer message boards where they swap info on how to challenge the collection process can also strengthen your compliance practices. Forewarned being forearmed, etc.) MIKE FROST Chief Compliance, Sales Officer & General Counsel CBE Companies Continuous improvement with operational and compliance efforts is a real testament to the compliance and operational departments of a given organization. Consistent review of case law, enacted as well as proposed legislation at the federal, state and municipal levels is the best way to ensure continuous improvement in compliance. It is also essential to maintain working relationships with other collection agencies’ compliance departments to seek and share assistance with one another. It is always best to collaborate with peers to ensure nothing is overlooked.
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4 - Follow regulators in their enforcement actions, public meetings and speeches, reports and presentations to elected officials for clarification on their positions or interpretations of regulation.
NICK JARMAN Owner The RightAway Staying on top of the compliance trends that tend to sway on a consistent basis. There are numerous resources available through industry trade associations along with news sites that continually provide the latest information and insight. Making a habit of monitoring these resources and articles on a daily basis will assist in staying on top of the ever-changing trends. RICK PERR Partner Chair, Financial Services Practices Group Fineman Krekstein & Harris, P.C. Stay up to date on a daily basis. A day doesn’t go by without a new case, a new regulation or a new outcome in a financial services matter. It is imperative that these situations be digested by every company, lawyer and compliance professional and disseminated throughout the company. The law can change daily. One cannot afford to be behind – regulators and plaintiff’s attorneys surely are not. TIM KOSKOVICS CEO USA Meridian Int’l Inc. I believe the best way to improve on compliance is to be a part of a group, i.e. Eagle Group XX, that specializes in compliance. Eagle Group has regularly scheduled compliance training plus yearly face to face training. The group enable me to have a culture of compliance in my company.
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A
Provides His Perspective on Collections
s many professionals will recall from the recent Fall Unified Agenda, March 2019 is heralded as the month the CFPB will release its Notice of Proposed Rule Making (NPRM). Professionals are speculating what the bureau will decide is fair for both collectors and consumers and if the rules will keep the needs of the industry in mind. Fortunately the CFPB does have subject matter experts who happen to be veterans of the collection floor and familiar with what must be done to keep the economy rolling. One such veteran is John McNamara, the CFPB’s assistant director, consumer lending, reporting and collections markets. Years before he was working to find the balance between consumer rights and responsibilities, McNamara was a kid fresh out of college looking for a desk. “I started as a collector trainee out of college,” said McNamara. “It’s funny. I think I took the job because they would have me… I didn’t even know what I was getting into. Found out I was pretty good at it. I did really well as a collector and rapidly moved up to collection manager. This was with American Creditors Bureau. “Within about a year I was promoted to collection manager and then a couple years later I transferred to San Antonio [TX]. Within three years I was running the San Antonio site. Then I moved around with American Creditors Bureau to numerous sites, running them, typically taking over sites that were underperforming and fixing them. At one point I was promoted to operations manager which was the equivalent to a regional VP.” Not only did McNamara flourish in the collection environment, he took pride particularly in his ability to educate fledgling collection professionals. In this instance he literally wrote the book. “This is probably the thing I’m most proud of in the debt collection space,” said McNamara. “I moved over as the director of training and quality and rewrote our training programs. It was based on principles of adult learning. We typically hired folks who didn’t have prior collection experience. We just didn’t want to inherit any bad habits. One of the things we tried to do with this training was to get new hires to understand what it was like to be a debtor.” “The other thing we did in this training program that I thought was really novel was we had the new hires create their own FDCPA. The hypothesis was much of the FDCPA was highly intuitive. If a new hire came up with their new guidelines for debt collection and they got them right then that would be internalized and they would never forget that.” In 2006 McNamara took to entrepreneurialism and cofounded Fidelis Recovery Services. Eventually the opportunity
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TAKE AWAYS 1 - TRAIN NEW HIRES TO THINK LIKE DEBTORS. 2 - HAVE NEW HIRES CREATE THEIR OWN FDCPA. 3 - UNDERSTAND CONSUMER ADVOCATES’ PERSPECTIVES. 4 - TELL THE CFPB WHAT PROBLEMS YOU ARE TRYING TO SOLVE. to influence the industry arose again in July 2014 when McNamara leveraged his industry experience in accounts receivable to become a subject matter expert for the CFPB. “When I heard that the Bureau was considering a debt collection rule I realized I had been subject to the FDCPA for almost my entire adult life and I would love to be part of that, to be a subject matter expert and help them be as informed as possible in the rule making,” said McNamara. “A big part of the role is industry engagement. We try to translate government to industry and industry to government and that involves speaking at a lot of conferences trying to educate the industry on what is going on relative to compliance, relative to the BCFP. It’s a very fulfilling role.” McNamara truly has a perspective on the industry that not many have. He has seen accounts receivable from the ground up and regulation from both sides of collector/debtor relationship. From this experience he encouraged others to seek out varying opinions and listen for the truth within. “My personal opinion is it’s healthy for industry to listen to and engage with consumer advocates, to understand where they’re coming from and understand the kind of consumer harms they’re seeing,” said McNamara. “I think most people are surprised at how willing the Bureau is to talk to individual players. We certainly value getting a steady diet of industry practices and understanding what problems the industry is trying to solve.” John McNamara
T. Steel Rose
Agency Leaders Discuss Compliance Tools: Reduce Risk and Save on Labor A
n adequate compliance management system (CMS) is mandated by the CFPB, to have documented policies, procedures and work instructions which are monitored with corrective action. According to the CFPB, an effective CMS will have a board of directors and management oversight and employee training. A necessary cornerstone of this system is a Consumer Complaint Management Program (CCMP) which includes Independent and Internal Compliance audits to ensure all complaints are addressed including complaints received directly from consumers from the CFPB, BBB or state attorney generals. Concerning the benefits to using a compliance solution, LADONNA BOHLING,
“It saves on labor and time when you have to gather documents for audits.
"
IFCCE, CCCO, VP Special OPS at Contract Callers, Inc., said, “The biggest benefit in my opinion is all your compliance ‘materials’ can be stored in one central location. This includes policies, procedures, licensing info and vendor auditing. Users access by individual log-ins…and everyone sees the same information…always up to date…no storing fragments of info on various drives which eliminates the worry of information that is not up to date being shared.” CHRIS DUNKUM, president of First Collection Services said, “Some of the most significant benefits of using a compliance solution include being able to monitor and meet deadlines; track and trend issues by client, by type and by source; and identify unusual issues as they occur in real time.” “It saves on labor and time when you have to gather documents for audits,” Bohling noted, while Dunkum said the benefit of, “Being able to turn around and provide that information back to a client about their own accounts and data has been an unexpected and value-added service they appreciate.” .com
January/February 2019
“Being able to turn around and provide that information back to a client about their own accounts and data has been an unexpected and value-added service they appreciate.
"
Concerning how processing and staffing may optimize the use of a compliance tool, Bohling said, “Most compliance tools have dashboards that will allow you to see complaint data at a glance on which you may perform trend analysis which allows you to mitigate risks by changing processes and workflows. “Workflows are documented which eliminates guesswork on what to do from front line management. Labor saving processes include online employee testing and the ability to upload client information such as contracts and scopes of work which enables adherence to client requirements.” Dunkum, said, “There is a lot to be said about automation and digital processes to eliminate the element of human error as much as possible, but there is no substitute for qualified, attentive and knowledgeable staff who care about what they do. Good people optimize even the best process.” Something Bohling hopes compliance solutions will be able to do in the future is integrate with collection software for more seamless complaint management. “Typically, complaint logging and tracking can be labor intensive and often there is duplication of efforts – account records are documented in the collection software and then entered in your compliance management tool,” Bohling said. “If the compliance tool interfaced with the software there would only be one entry and documentation of the complaint.” Dunkum was matter of fact when he said, “Ultimately, any compliance solution is developed to reduce risk (for consumers, clients and agencies) yet still increase productivity and efficiency. However,” he noted, “many compliance solutions are cost-prohibitive.”
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Business Directory
Collection Agencies IC System, Inc. 3rd Party Collections icsystem.com 651-481-6531 ejohannes@icsystem.com IC System provides secure and compliant third-party bad debt collection services to a wide array of markets. Over 80 years of family ownership and consistent, trusted results. United Collection Bureau, Inc. 1st and 3rd Party Collections ucbinc.com ssharma@ucbinc.com 954-236-6027 UCB, Inc. provides national debt programs for creditors in all markets from fully-secure high performance collection centers located in the U.S. and Latin America.
Collection Solutions Software, Inc. CSS IMPACT! HD™ 2.0 cssimpact.com arielb@cssimpact.com 818-593-4830 CSS IMPACT! HD™ 2.0 (Enterprise), the industry’s leading ARM | Collections & Compliance Platform delivering decades of deep rooted industry acumen for the ARM, Collections & Compliance sectors. IXP (Lite) also available. The Computer Manager, Inc. Debt$Net Collection Software debtnet5.com | sales@debtnet5.com 800-552-8397 Since 1987, Debt$Net collection software has provided collection agencies, law firms and in-house collection departments with one of the most comprehensive collection systems in the industry.
Debtmaster® Debtmaster® 360 debtmaster.com 800-414-2814 Debtmaster®360 gives you a cloud hosted, costeffective, flexible, secure, collection solutions that helps you manage compliance and provide quality service for Clients and Debtors. Quantrax Corporation Inc. RMEx quantrax.com marketing@quantrax.com 301-657-2084 Quantrax is a high-end collection technology company that has marketed and supported an intelligent collection software platform for over 25 years.
Simplicity Collection Software SimplicityCollect Comtech Systems simplicitycollectionsoftware.com Collect! sales@simplicitycollect.com Credit and Debt Collection Software 866-791-0224 Collection Software As an industry leader, Simplicity is the only software procollect.org | info@collect.org CDS Software vider to offer a web solution with unlimited users, clients, 800-661-6722 CollectOne accounts, and custom fields at an affordable price! Collect! combines ease of use with total integration collectone.com of functions. Accounts are efficiently tracked from info@collectone.com Sentinel the time you receive them until activity is concluded 888-816-3333 Development and they are closed. Collect! keeps track of critical CollectOne is an award winning suite of debt colSolutions, Inc. information automatically. Total integration provides lection solutions that provides a feature-rich set of eCollections for seamless and accurate month end invoices and automated business processes designed to minimize ecollections.com | sales@ecollections.com statements with full account histories. costs and maximize results. 515-564-0585 DAKCS Software The result of 20 years of industry-leading collections/recovCODIX ery platform development, eCollections is a comprehensive Systems iMX Collection, enterprise collection system with flexible configuration, Beyond ARM Legal and Recovery Solution ease-of-use, powerful payment features, workflow automadakcs.com | sales@dakcs.com codix.us/debt_collection tion, and unparalleled reporting and tracking. 800-873-2527 bquinn@codix.us DAKCS Software Systems is an industry leader in simpli404-790-0998 fying the process of collections and accounts receivable iMX is a complete centralized debt collection and Collection Support Services management. By creating highly configurable, innovarecovery software solution. Based on the latest tive cloud and on-premise software solutions, DAKCS of- Cornerstone technologies, iMX Debt Collection includes all the fers a way to run your business faster and more efficient. Support most advanced business functionalities supported by DAKCS is committed to providing the tools necessary for State Licensing native tools. success in the ever evolving ARM industry. and E&O Insurance cornerstonesupport.com info@cornerstonesupport.com 888-445-8660 Cornerstone Support is the premier licensing and insurance provider to the collection industry; professionally trained to assist you with all of your state licensing needs.
LISTINGS AVAILABLE
1 issue - $500 | 2-6 Issues - $300 each
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January/February 2019
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Skip Tracing
VoApps DirectDrop Voicemail voapps.com sales@voapps.com 855-639-4907 VoApp’s patented DirectDrop Voicemail service delivers a voice message directly to a consumer’s voicemail server – without calling the phone in question.
Compliance LexisNexis® Risk Solutions LexisNexis ® Accurint ® for Collections lexisnexis.com/risk/receivables-management 800-869-0751 LexisNexis Risk Solutions assist debt recovery professionals with increasing workflow efficiencies, gaining greater insight into debt portfolios, collecting more in less time and achieving greater profitability.
Electronic Payments BillingTree Payment Solutions Credit, debit & ACH processing
IDI idiCORE ididata.com sales@ididata.com 855-842-1410 Trusted for over a decade by collection agencies and collection attorneys. IDI provides fast, accurate and cost-effective consumer verification and skip-tracing solutions via online, API, and batch processing. Reduce Cost, Not Quality. LexisNexis® Risk Solutions LexisNexis® Accurint ® for Collections risk.lexisnexis.com 800-869-0751 LexisNexis® Risk Solutions assist debt recovery professionals with increasing workflow efficiencies, gaining greater insight into debt portfolios, collecting more in less time and achieving greater profitability. U.S. Tracers Proprietary Place of Employment VeriFacts Payroll Promise verifactsinc.com sclark@verifactsinc.com 800-542-7434 Payroll Promise is designed to support a legal strategy by locating verified full time places of employment. The information returned is 100% guaranteed to be accurate.
Innovative E-Pay Virtual Collections Solutions, Inc. Electronic Applied Innovation Inc. Payments ClientAccessWeb, innoepay.com PayStream, sales@innoepay.com GreenLight, and Papyrus 855-888-3729 appliedinnovationinc.com Specializes in providing Credit Card and Electronic 800-589-5651 Check processing accounts to the Collections Industry mjeffers@appliedinnovationinc.com for over 15 years. FDCPA Certified Agents, longtime Applied Innovation provides a suite of compliant members of ACA. solutions for the ARM industry. Our solutions have proven to increase your bottom line with improved efficiencies, increased client sales and retention, and Mail Services increased web services. Designed for your continued growth and success. CompuMail Inc. Print & Mail InterProse Services, Communications ACE - Virtual compumailinc.com Agent Collector info@compumailinc.com interprose.com/collection-advisor 360-260-1888 aaron.reiter@interprose.com In addition to providing print and mail services, CompuMail's solutions include email, online archiving, 844-244-1135 and real-time review & approve capabilities - coupled Add InterProse’s consumer-friendly, patented Virtual Agent Collector to your existing software or ask about with superior service. ACE for a full conversion to a true, web-based collection platform, open to third-party integrations and packed with process automations. .com
January/February 2019
January/February 2019 Volume 19, No. 1 Editor-in-Chief Joshua Fluegel josh@collectionadvisor.com Editor T. Steel Rose, CPA, ACG editor@collectionadvisor.com Copy Editor Myrna Nelson Advisory Board/Columnists Gordon C. Beck III Ron Brown Debra Ciskey Sam Eidson Nick Jarman Michael L. Starzec Harry A. Strausser III Publisher Angie Rose angie@collectionadvisor.com Sales Assistant/Illustrator Adriana Holland adriana@collectionadvisor.com Production Andrea Bergeron Paul andrea@collectionadvisor.com Subscription Changes Joshua Fluegel josh@collectionadvisor.com The opinions given by contributing authors are their own and not necessarily the opinion of our staff and ownership. All trademarks used are the property of their respective owner.
Collection Advisor (ISSN# 1556-0813) is produced six times a year by Abide Media, P.O. Box 92342, Southlake, TX 76092, 888-610-1144. Standard Mail postage paid at Sussex, WI 53089. ©2019 All Rights Reserved Magazine Publishing Group, Inc. Printed in the U.S.A.
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